Medicare, Mange Care & Medicaid Changes in the New World we live in

85
Medicare, Mange Care & Medicaid Changes in the New World We Live In, Julie Kearney Kearney & Associates, Inc. 1

Transcript of Medicare, Mange Care & Medicaid Changes in the New World we live in

Page 1: Medicare, Mange Care & Medicaid Changes in the New World we live in

Medicare Mange Care amp Medicaid Changes in the New

World We Live InJulie Kearney

Kearney amp Associates Inc

1

Medicaid What are we seeing

2

NEW Medicaid Change MIloginbull File Transfer to send information to the State On May 20th 2016 users will access File Transfer

through MILogin rather than Single Sign-On

bull httpsmilogintpmichigangovuisecuretpselfserviceanonymouslogout

bull What is MILogin MILogin is the State of Michiganrsquos new Single Sign-On or SSO Very soon you will begin using MILogin to access some of the State of Michigan systems or applications MILoginwill improve overall functionality security and compliance with Federal and State regulations such as HIPAA

bull When will I use MILogin bull MILogin will be rolled out in phases MDHHS DCH Legacy systems and applications that are

currently on Single Sign-On will be accessed through MILogin by October 2016 For a listing of the systems and applications currently on MILogin please visit httpwwwmichigangovMDHHS-MILogin-Info

bull If I currently use SSO and am a Provider or Advocate do I need to set up a MILogin account bull Current Providers or Advocates who access Single Sign-on (SSO) will not need to create a MILogin

account You will use the same log in information that you currently use to access SSO MILoginwill eventually provide access to all applications needed to conduct business with the State

3

Blueprint for Health Innovation MIbull Michigan announces pilot regions for the Blueprint for Health Innovationbull LANSING Mich ndash In moving forward to better coordinate care lower costs and improve the

health of Michigan residents the Michigan Department of Health and Human Services has selected the five pilot locations for the Blueprint for Health Innovation

bull The identified regions are Jackson County Muskegon County Genesee County Northern Region and the Washtenaw and Livingston counties area Final boundaries will be determined after working with partners to target investments and impact Additional development will begin this summer across the five regions over the three-year project period

bull Launching the pilot regions this summer will help us affect payment reform and lower costs for our residents said Tim Becker chief deputy director of the MDHHS Through the pilots MDHHS will work with the healthcare community to find the best ways to implement changes going forward

bull The phased approach and timelines will be included in the Operational Plan due to Centers for Medicare amp Medicaid Services at the end of May 2016 The pilot regions will play an important role in developing a stakeholder engagement process to gather feedback on the Operational Plan prior to submission

4

Provider Enrollment Electronic Signature Form Submission Process

MSA 15-54Medicaid

5

Provider Enrollment Electronic Signature Form Submission Process

bull In compliance with 42 CFR 455104 the Michigan Department of Health and Human Services (MDHHS) is establishing a new process associated with Medicaid provider screening and enrollment requirements related to program integrity for the Medicaid Fee-for-Service (FFS) program Providers were previously notified of the changes required under 42 CFR 455105 in bulletin MSA 12-55 This bulletin describes the process for assigning additional domain access rights to the Community Health Automated Medicaid Processing System (CHAMPS) Provider Enrollment (PE) subsystem on a providers behalf

bull These forms do not need to be completed if no new domain access rights are needed

bull Issued 12302015bull Effective on 02012016

6

Provider Enrollment Domain Administrator

bull Electronic Signature Agreement Form bull To obtain the required information mandated under 42 CFR 455104 any

provider wishing to appoint another person access to their CHAMPS information must submit an Electronic Signature Agreement form (DCH-1401) and the Electronic Signature Agreement form cover sheet (MDHHS-5405) The two completed forms must be submitted to the MDHHS Medicaid Provider Enrollment Unit for processing MDHHS recommends the provider retain a copy of these forms for their records

bull The Electronic Signature Agreement form is also being updated to include additional language certifying the enrolled provider understands he or she is liable and bound by all information submitted on his or her behalf

7

Medicaid Coinsurance Medicare Advantage

bull Attention Nursing Facility Medicaid Fee for Service Providers

bull As part of the December 11 2015 CHAMPS system update the final phase of the Medicare Advantage Coinsurance Pricing Logic was implemented For claim dates of service 2010 and prior please refer to the Medicaid Provider Manual under General Information for Providers Chapter Section 124 Provider Returning Overpayments

bull For claim dates of service 2011 and forward MDHHS will be initiating the claim adjustment within the next few weeks Providers with further questions can contact Provider Support by phone 1-800-292-2550 or email ProviderSupportmichigangov

8

The State has been paying the wrong coinsurance amount for Medicare Advantage since 2008 Per below they will be doing a claim adjustment in the next few weeks for dates of service 2011 going forward If you have refunded the State by a check watch and make sure they do not double recover the money If they do you will have to get your check and list of people you refunded and send it to providersupportmichigangov They have stated they have fixed the pricing logic to pay it correctly going forward Watch and make sure they are paying the correct amount if not you will have to again pull the information from the coinsurance payer and send it to providersupportmichigangov

For dates of service prior to 2011 you will have to return the Money per the Medicaid manual

Medicaid providers performing self audits may discover an overpayment situation and wish to return theMedicaid overpayment to MDHHS This process should only be used when the provider is unable to claimadjust or it is not practical to claim adjust Sending in a check will not correct the underlying claim(s)data Providers must

10487071048707 Document why the money is being returned (ie provider self audit) and identify provider NPIinformation address dates of service and specialty area (ie durable medical items pharmacyphysician practice hospital etc) and include a basic information letter

10487071048707 Attach an excel spreadsheet document with the Tax ID billing NPIs and associated amounts (ifmultiple IDs exist for the entity) for the MDHHS Accounting Office to apply credit to

10487071048707 Make check payable to State of Michigan and mail to the MDHHSCashierrsquos Unit - Attn Bureauof Finance-MCU (Refer to the Directory Appendix for contact information) 9

Lawsuit DHS Changes on Caregivers

bull A recent Michigan Court of Appeals decision has played havoc on the rules surrounding payments to non-family caregivers DHS rules regarding payments to caregivers state that payments are divestment in two situations 1) prospective payments made to any caregiver (family or non-related) before care is provided and 2) payments to family caregivers absent a Medicaid qualified caregiving contract The Court of Appeals decision Jensen v Department of Human Services confuses the rules and applies the family caregiving contract requirements to all caregivers even professional caregiving agencies The result of the case is that payments to non-family caregivers may be divestment unless the Medicaid applicant has a contract with the caregiver meeting the extremely specific rules found in the Medicaid manual

10

TPL Medicaid Changebull Attention Providersbull Effective October 26 2015 the MDHHS Third Party Liability (TPL)

Update Other Insurance Now Online form will be updated You will now receive a confirmation number when you submit your request If an email address is added within the Requestor Information section once TPL completes your request you will receive an email with the confirmation number and the status of your request Please allow up to 10 business days for information to be verified and updated in the system Please check your spam or junk email folders if you do not receive the email after 10 business days

bull Providers with further questions can contact Provider Support by phone 1-800-292-2550 or email ProviderSupportmichigangov

bull httpsminotifytplstatemiustedpubliccoveragerequestsindex11

CHAMPS Member Screen

bull Attention Providersbull Effective September 25 2015 a change was made to the CHAMPS

system This change modified the provider view for the Member Eligibility Inquiry screen If a member no longer has active Medicaid the hyperlink to view ldquoCommercialOtherrdquo Third Party Liability (TPL) information is disabled Because TPL does not always maintain TPLOther Insurance information for members that do not have active Medicaid coverage this information was disabled to prevent inaccurate information from being reported

12

LOC dropping off Not Due to MI Health

bull If after 30 days the county hasnrsquot processed the 2565 that you have send via the central scan (517-346-9888) AND other methods you choose to use you can email the 2565 to ArdeneMartin

bull At the following mailbox I ask that you put the beneficiaries name in the subject line

bull MSA2565michigangov

13

Issues

bull PPA going all over the place

bull LOC 02 dropping off not related to MI Health

bull LOCD tons of money written off

bull Must check CHAMPS member screen all the time and you must check pending

14

Secure Email Information

bull The State of Michigan asked me to remind you when you are communicating with them regarding residents to not send Resident names Birthdates or Social security numbers in those emails What you send is the Medicaid ID and they can look it up Or if it is a billing issue send them the TCN and the Medicaid ID We have been in the practice of emailing DHS Ardene Martin Integrated Health and Provider Support with all the resident name and such

15

Medicaid amp Hospicebull LOC 07 Manage Medicaid Hospice included so plan would pay

provider and not switch to a LOC 16

bull LOC 02 Medicaid (Regular Medicaid) Hospice not included so switch to 16 Hospice and Hospice pays provider

bull LOC 11 Healthy Michigan is included in plan so plan would pay provider and not switch to LOC 16

bull LOC 005 amp 015 MI Health is up in the air waiting for CMS Currently Hospice is now included

bull LOC 16 is Hospice when they switch from Regular Medicaid only and Hospice pays provider

16

Medicaidbull Going forward please make sure that your Champs ID amp NPI on your member screen matches your facility CHAMPS ID

amp NPI for each resident and matches for all new admissions or new approved Medicaid going forward

bull The edit will be turned on soon to stop the payment of these claims if the CHAMPS ID and NPI do not Match your facility on the Medicaid member screen

bull Make sure you are putting the information correct on the 2565 you send in to DHS

bull 1 I attached a 2565 When you fill this out for new people make sure in box 12 a you put your NPI and 12 b you put your CHAMPS ID This will help the DHS case workers assign the person to your facility

bull 2 I would check all your residents CHAMPS member screens and make sure the NPI and CHAMPS ID are your facilities If not you will have to work with the DHS worker to fix this The DHS worker is the only one that can fix this

bull 3 We are having some issues where the DHS case workers will not change this NPI and CHAMPS ID to your facilities You have to get them to change it or you just will not get paid

bull 4 We situations where the resident is in a facility in Kent County (as an example) but the family lives in Livingston County and completes the applications in Livingston County You will have to get the DHS worker in Livingston to fix it not the local DHS worker in Kent County where your facility is

17

Medicaid Medicare Buy Inbull Based on the information from the Office of Personnel Management Federal

Employeersquos employed as of January 1 1983 are eligible for Medicare Part A(see page 5 of attached document) This was also confirmed with our Social Security liaison If the beneficiary did not retire before 1983 he can enroll in Medicare Part B and pay the premium and then he can enroll in Medicare Part A and pay that premium as well or may qualify for Medicare Buy in of Part A

bull If a beneficiary has an SSA document stating they are not eligible for Medicare as they do not have enough work credits the beneficiarybeneficiary representative needs to go to SSA and let them know that while they know they are not eligible for Medicare Part A free or reduced however they are eligible for Medicare Part B and would like to enroll Once the beneficiary enrolls in Medicare Part B (enrollment period January 1st ndash March 31 each year) and pays the premium then the beneficiary is eligible to either pay for Medicare Part A or that beneficiary may qualify for Medicare Part A buy in through Medicaid Once the beneficiary is enrolled in Medicare Part A and Medicare Part B Medicaid will begin to make payments on claims

18

Manage Medicaid Where are we

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Healthy Michigan Residents

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Healthy Michigan Medicaid Days

21

McLaren Health Plan

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Manage Medicaid Plans January 1bull Region 1 ndash Upper Peninsula Health Planbull Region 2 ndash McLaren Health Plan Meridian Health Plan of Michigan Molina Healthcare of Michigan

UnitedHealthcare Community Planbull Region 3 ndash McLaren Health Plan Meridian Health Plan of Michigan Molina Healthcare of Michigan

UnitedHealthcare Community Planbull Region 4 ndash Blue Cross Complete of Michigan McLaren Health Plan Meridian Health Plan of Michigan Molina

Healthcare of Michigan Priority Health Choice UnitedHealthcare Community Planbull Region 5 ndash McLaren Health Plan Meridian Health Plan of Michigan Molina Healthcare of Michigan

UnitedHealthcare Community Planbull Region 6 ndash Blue Cross Complete of Michigan HAP Midwest Health Plan McLaren Health Plan Meridian Health

Plan of Michigan Molina Healthcare of Michigan UnitedHealthcare Community Planbull Region 7 ndash Blue Cross Complete of Michigan McLaren Health Plan Meridian Health Plan UnitedHealthcare

Community Planbull Region 8 ndash Aetna Better Health of Michigan McLaren Health Plan Meridian Health Plan of Michigan Molina

Healthcare of Michigan Priority Health Choice UnitedHealthcare Community Planbull Region 9 ndash Aetna Better Health of Michigan Blue Cross Complete of Michigan McLaren Health Plan Meridian

Health Plan of Michigan Molina Healthcare of Michigan UnitedHealthcare Community Planbull Region 10 ndash Aetna Better Health of Michigan Blue Cross Complete of Michigan Harbor Health Plan McLaren

Health Plan Meridian Health Plan of Michigan Molina Healthcare of Michigan Total Health Care UnitedHealthcare Community Plan 23

24

MI Health LinkWhere are we

25

MI Health Link 2565

bull This notification is being sent to providers of long term care services including nursing facilities county medical care facilities and hospital long term care units to provide clarification on the process involved with the submission of the Facility Admission Form (MSA-2565-C) for an individual enrolled in the MI Health Link program

bull The MI Health Link program covers the custodiallong term nursing facility service benefit When an individual who is enrolled in the MI Health Link program is admitted to a nursing facility for custodiallong term nursing services a disenrollment from the Integrated Care Organization (MI Health Link health plan) is NOT REQUIRED The Facility Admission Form (MSA-2565-C) should NOT be sent to the Michigan Department of Health and Human Services (MDHHS) Enrollment Services Section for a disenrollment to be processed

26

What are the Names

bull Started as Integrated Health

bull Then called MMP (Medicare Medicaid Program)

bull Duals (Also Known as Duals as in Dual Eligible)

bull Now called MI Health Link

bull Total confusion

27

MI Health Dual Eligible28

MI Health LOC

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LOC Medicaidbull We have the new pilot program which started on March

1 2015 in Southwest Michigan Region 4 Counties Macomb Wayne and the UP You could see these patients they are dual eligible in the Pilot program in counties surrounding the pilot

bull MHL-LOC 005 (All other Facilities) or LOC 015 (County Care) These residents have to call Michigan Enrolls to dis-enroll toll-free at 1-800-975-7630 (TTY 1-888-263-5897) Monday-Friday from 8 AM to 7 PM Once they dis-enroll they will go to a LOC 02 you have to do a new LOCD

30

Medicaid Redetermination and MHL Enrollmentbull At the time of re-determination for Medicaid financial eligibility the MI

Health Link (MHL) program will not be sending beneficiaries information about this program Beneficiaries who previously opted out will not be passively enrolled according to an email from the MHL staff The MHL staff wrote

bull ldquoThere is currently no MI Health Link enrollment letter sent to beneficiaries when eligibility is re-determined A person who becomes eligible for MI Health Link enrollment may opt-in at any time

bull When Medicaid re-determination takes place the beneficiary remains in the same ICO unless that beneficiary lost Medicaid coverage If the enrollee loses Medicaid coverage and later regains it they are not passively enrolled into MI Health Link The beneficiary may choose to opt back in to the program at that time if desiredrdquo

bull MHL staff did state that about 1500 beneficiaries will be passively enrolled effective January 1 2016 These specific individuals were given normal notice of 60 and 30 days in which to opt-in or opt-out if they so chose No other large scale passive enrollment is scheduled according to the MHL staff 31

MI Health Link Portals

bull Meridian Health Planbull httpwwwmhplancommibull Amerihealthbull httpwwwamerihealthcaritasvipcarepluscomproviderself-service-

toolsindexaspxbull AetnaCoventrybull httpwwwaetnabetterhealthcomMichiganprovidersportalbull Molinabull httpwwwmolinahealthcarecommembersmien-usmemPageshomeaspxbull HAPMidwestbull httpswwwmidwesthealthplancomLoginaspxbull FidelisCentenebull wwwfidelissccommmp 32

MI Health Authorizationsbull We need to watch these authorization that the plans are giving us for the MI

Health program Some plans are assigning a diagnosis for residents in their prior authorizations They are assigning diagnosis that the residents do not even have You need to make sure these are correct diagnosis and if not you need to work with the case managers of the plans to fix the issue The authorization numbers do change

bull Make sure that any resident that is in a MI Health plan that you have a prior authorization All plans are giving different periods authorizing the residents stay in the facility You need to set up a system to make sure you always have a authorization for the period of time you are rendering the service Here is an example of time frame of authorizations

bull Meridian is authorizing 12 monthsbull Aetna is authorizing 3 monthsbull Molina is authorizing 6 monthsbull The authorization numbers need to go on your claims to the payer You need to

put the authorizations in your software and track the dates

33

MI Health Issuesbull We are seeing some issues with MI Health where the resident does not have the correct LOC or it shows

up correct on CHAMPS but ancillary providers such as Dentist and such cannot see it I think we still have some issues with the information crossing between Bridges DHS system CMS and CHAMPS It in return is creating some access of care issues If it is a true LOC issues Facilities with LOC issues need to submit the Medicaid ID numbers to the MSA-MHL-EnrollmentMichigangov box with the subject line Nursing home LOC Issue so they may work to resolve the issues

bull If it becomes an access to care issue email the information to INTEGRATEDCAREmichigangov Remember in these emails only send the Medicaid ID and explain the situation The State will work with the plans to try to fix the process or improve the process

bull We are also seeing with new admission with LOC 015 or 005 that the plans are stating they have 14 days to authorize admission These are resident in the emergency room and possibly be admitted to you for Rehab The hospital will not keep the resident in ER for 14 days and you cannot admit the resident until you have a prior authorization I would recommend when you are told this by the plan that you need to ask to speak to a manager We will have to work through this

bull Ancillary Provider You need to work with your ancillary providers such as Lab Pharmacy X-Ray Physician and such to get the to be credentialed with the plans We are hearing that some of the pharmacies are not participating with the plans this will create issues for you so I would continue to ask these groups to participate

34

LOC 02 dropping MI Health Issuesbull The passive enrollments have occurred in Macomb amp Wayne for

Medicaid dual eligible We are having the same issue we did as in the Southwest MI amp UP with the passive enrollments I am starting to hear from facilities who are checking there CHAMPS member screens that those residents that have opted out (some residents not all) have lost there 02 Make sure you are checking your CHAMPS member screen both for those that were passively enrolled and those that might have lost there 02 Medicaid that opted out

bull Facilities with LOC issues need to submit the Medicaid ID numbers to the (Only MI Health)MSA-MHL-Enrollmentmichigangov box with the subject line Nursing home LOC Issue so they may work to resolve the issues

35

PPA Offset

bull There are no co-pays deductibles or premiums in MI Health Link so there should be no need to offset the PPA with code 25 MI Health Link enrollees can continue to offset their PPA for non-program covered medical expenses (like Vision-Code 27 Dental-Code 28 and Hearing-Code 26) and use the appropriate codes to offset the PPA when billing the health plan for nursing facility services

bull Resident pay PPA when MedicareMedicaid coinsurance

36

LOCDbull Nursing Facility Level of Care Determination (NFLOCD)

bull The MI Health Link health plan will be responsible for conducting the Michigan Medicaid NFLOCD tool for enrollees seeking admission to a nursing facility For existing residents at the time of enrollment the existing NFLOCD will be adopted for capitation payment purposes The health plan will complete a new NFLCOD tool within the first 90 days of enrollment If a nursing facility resident is disenrolled from MI Health Link the nursing facility will be responsible for conducting a new NFLOCD tool in accordance with published Medicaid policy

37

MI Health Issues-New

bull INTEGRATEDCAREmichigangov

bull Email with Insurance Plan issues Case Manager Issues

38

ACOWhat are they

39

Families Receiving Letters for ACO

40

ACO What is It

bull Whats an ACObull Accountable Care Organizations (ACOs) are groups of doctors hospitals

and other health care providers who come together voluntarily to give coordinated high quality care to their Medicare patients

bull The goal of coordinated care is to ensure that patients especially the chronically ill get the right care at the right time while avoiding

unnecessary duplication of services and preventing medical errorsbull When an ACO succeeds both in delivering high-quality care and

spending health care dollars more wisely it will share in the savings it achieves for the Medicare program

41

Payroll Based JournalMandatory on July 1 2016Internet Explorer Version

Internet Explorer v 10 and v 11 will need to operate in compatibility mode

42

43

If you submit data manually should you also submit it through the XML

bull Now you have three options

bull Submit Manually only

bull Submit through the XML only

bull You are able to submit manually and using the XML

44

45

Staffing Submission Frequently Asked Questions

bull ldquoWho are direct care staffrdquo (Who do we submit data for)bull Submission of data for contract staffbull Medical directors and consultantsbull Staff switching roles or tasks throughout the daybull Hours paid vs hours worked ndash Must be verifiablebull Public postingQuality MeasuresFive Starbull Enforcementbull Voluntary submission risks (noneSo register now)

CMS defines

bull 37 job title codes that are required to match employees to the number of hours each direct care function was performed It is important to work with your teams to define the workers that contribute to each job type and how those daily worked hours are recorded and converted to a PBJ submission

bull The PBJ does include some more specific job descriptions than the 671 For example the PBJ system includes job descriptions for RNs with administrative duties and LPNs with administrative duties versus the 671rsquos more general ldquoNurses with Administrative Duties

Page 46

47

PBJ Medical Director Rolebull Physician Leadership

bull Help the facility ensure that patients have appropriate physician coverage and ensure the provision of physician and health care practitioner services and

bull Help the facility develop a process for reviewing physician and health care practitioner credentials

bull Provide specific guidance for physician performance expectations

bull Help the facility ensure that a system is in place for monitoring the performance of health care practitioners and

bull Facilitate feedback to physicians and other health care practitioners on performance and practices

bull Patient Care - Clinical Leadership

bull Participate in administrative decision-making and the development of policies and procedures related to patient care

bull Help develop approve and implement specific clinical practices for the facility to incorporate into its care-related policies and procedures including areas required by laws and regulations

bull Develop procedures and guidance for facility staff regarding contacting practitioners including information gathering and presentation change in condition assessment and when to contact the medical director

bull Review consider andor act upon consultant recommendations as appropriate that affect the facilitys resident care policies and procedures or the care of an individual resident

bull Review respond to and participate in federal state local and other external surveys and inspections and

bull Help review policies and procedures regarding the adequate protection of patients rights advance care planning and other ethical issues48

PBJ Medical Director Rolebull Quality of Care

bull Help the facility establish systems and methods for reviewing the quality and appropriateness of clinical care and other health-related services and provide appropriate feedback and

bull Participate in the facilitys quality improvement process

bull Advise on infection control issues and approve specific infection control policies to be incorporated into facility policies and procedures

bull Help the facility provide a safe and caring environment

bull Help promote employee health and safety and

bull Assist in the development and implementation of employee health policies and programs

bull Education Information and Communication

bull Promote a learning culture within the facility by educating informing and communicating

bull Provide information to help the facility provide care consistent with current standards of practice (defined as approaches to care procedures techniques and treatments that are based on research and or expert consensus and that are contained in current manuals textbooks and or publications or that are accepted adopted or promulgated by recognized organizations or national bodies)

bull Help the facility develop medical information and communication systems with staff patients and families and others

bull Represent the facility to the professional and lay community on medical and patient care issues

bull Maintain knowledge of the changing social regulatory political and economic factors that affect medical and health services of long term care patients and

bull Help establish appropriate relationships with other health care organizations

49

Dietician

bull When the dietary or food services supervisor is other than a registered dietitian the supervisor shall receive routine consultation and technical assistance from a registered dietitian (RD) Consultation time shall not be less than 4 hours every 60 days Additional consultation time may be needed based on the total number of patients incidence of nutrition-related health problems and food service management needs of the facility

50

Pharmacy Consultant

bull At least once per month a licensed pharmacist must perform a drug regimen review (DRR) for each resident The pharmacist must report any irregularities to the attending physician or director of nursing Furthermore these reports must be acted upon

51

What are the names for the Medicare Numberbull OSCAR -Online Survey Certification and Reporting

bull PTAN-PTAN number is assigned by Medicare to authenticate the provider when using the local Medicare Administrative Contractorrsquos (MAC) self-help tools like the IVR internet portal on-line application status etc Provider Transactions Access Number

bull CCN- CMS Certification Number

bull Medicare Number- example 23-

bull All of the above mean the same thing

52

QTSO

bull Once you are logged in the QTSO site bull You will have a state login to the site to access the various site specific

to your facilitybull Installing you will need administrator rights to your network

53

Medicare UpdateWhat are we seeing

54

CMS Final Rule On Returning Credits

httpswwwfederalregistergovarticles201602122016-02789medicare-program-reporting-and-returning-of-overpayments

55

Over Payment Rule

bull Medicare payments for non covered services

bull Medicare payments in excess of the allowable amount for an identified covered service

bull Errors and non reimbursable expenditures in cost reportsbull Duplicate payment

bull Receipt of Medicare payments when another payor had the primary responsibility for payment

56

Questions to MAC

bull Does the Medicare credit balance report change with this overpayment rule

bull No Medicare Credit Balances are still required at the end of each quarter

bull Will that still be the communication to let CMS or the MAC know that we have received an overpayment

bull Submission of Medicare Credit Balance is one form of communicating overpayments to CMS Other methods include submitting a voluntary refund with required claim information or the submission of a standard overpayment form

57

Questions to MAC

bull Will the MAC still deduct from a future RAbull If the recovery of the overpayment includes adjusting a claim then

the overpayment would be netted against future claims payments and reflected on the RA

bull Or will that process change with this new rulebull Process will remain the samebull Will NGS send communication out on thisbull Yes NGS will communicate this once the final rule is communicated

to the MACs by CMS However this could change depending on final CMS instructions

58

Final Rule on Returning Credits

bull Providers will want to immediately update their current policies governing overpayments in order to comply with this new rule which will take effect on March 14 2016

bull Providers and suppliers are required to use reasonable diligence to investigate credible information regarding overpayments through both proactive compliance efforts and reactive investigations

bull If an overpayment is identified then it must be repaid within 60 days An overpayment is identified when a person has or should have through the exercise of reasonable diligence determined that the person received an overpayment and quantified the amount

bull Providers and suppliers have a maximum of 8 months to report and return overpayments ndash up to 6 months to investigate and quantify the overpayment (ie to identify it) and up to 60 days to report and return the overpayment

59

Final Rule on Returning Credits

bull Providers and suppliers are required to report and return all overpayments within a 6-year lookback period

bull The cause and amount of the overpayment is irrelevant for the determination eg it was due to a mistake it was someone elsersquos fault it is a minor amount An overpayment is an overpayment and must be returned

bull Providers and suppliers must make their own determination to which entity to report and return the overpayment ie to the Medicare contractor or using the OIG Self Disclosure Protocol or the CMS Self Referral Disclosure Protocol

60

Final Rule on Returning Credits

bull Providers and suppliers may use the claims adjustment credit balance self-reported refund process or another appropriate process to report and return overpayments At this time there is no standard refund form to use

bull Failure to report and return an overpayment could subject the provider or supplier to False Claims Act liability Civil Monetary Penalties Law liability and exclusion from federal health care programs

61

P S amp R-Accountants will be asking for this information

The location you login into has changed it is now on EIDM EIDM is the acronym for CMS Enterprise Identity Management system which includes Identity Verification Access Management Authorization Assistance Workflow Tools and Identity Lifecycle Management functions

httpswwwcmsgovResearch-Statistics-Data-and-SystemsCMS-Information-TechnologyIACSCMS-Applications-Loginhtml

Go down the page and click on the PSampRSTARThis will take you to the login pagewill look the same as the old P S amp R didChanges Affecting PSampR System Access (Please Read) (posted 01292015)(Updated 5262015)is changingThe system which controls your PSampR user ID (currently IACS)The new system is referred to as EIDMThis will result in a different way to create new accounts or change passwords to existing accountsIf you already have an account in EIDM you may have to use that account for accessing PSampR after the transitionWhen is the change effectiveJune 13 2015What is staying the sameThe internet address for accessing PSampR remains the sameThe PSampR systemfunctionality is NOT changing 62

Medicare Advantage Payorsbull Medicare Advantage payors are pullingdenying payments on admissions if the patient was readmitted within 30 days after discharge The

client believes that the payors systematically denying payments for all readmissions within 30 days They believe this practice denies them due process to address whether the readmissions were justified and not due to a premature discharge of patient The payors seem to want to act like a QIO without having the same accountabilities of the QIO related to determinations of non-payment

bull Heres the QIO process under section 4240 of the QIO Manualbull 4240 - Readmission Review - (Rev 2 07-11-03)bull Readmission review involves admissions to an acute general short-term hospital occurring less than 31 calendar days from the date of

discharge from the same or another acute general short-term hospital (see sect1154(a)(13) and 42 CFR 47671(a)(8)(ii)) Neither the day of discharge nor the day of admission is counted when determining whether a readmission has occurred

bull A Medical Review Proceduresbull Obtain the appropriate medical records for the initial admission and readmission Perform case review on both stays Analyze the cases

specifically to determine whether the patient was prematurely discharged from the first confinement thus causing readmission Perform an analysis of the stay at the first hospital to determine the cause(s) and extent of any problem(s) (eg incomplete or substandard treatment) Consider the information available to the attending physician who discharged the patient from the first confinement Do not base a determination of a premature discharge on information that the physician or provider could not have known or events that could not have been anticipated at the time of discharge

bull Review both the initial admission and the readmission at the same time unless one of them has previously been reviewed In these cases use at a minimum the PRAF case summary of the other admission in addition to the medical record of the case under review

bull C Denialsbull Deny readmissions under the following circumstancesbull If the readmission was medically unnecessarybull If the readmission resulted from a premature discharge from the same hospital orbull If the readmission was a result of circumvention of PPS by the same hospital (see sect4255)bull With the QIO process there is an appeal within the QIO here the hospital is getting no opportunity to challenge the denials

63

Medicare Provider Enrollment Feebull Provider Enrollment Application Fee Amount for CY 2016bull On December 3 CMS issued a notice Provider Enrollment Application

Fee Amount for CY 2016 [CMSndash6066ndashN] Effective January 1 2016 the CY 2016 application fee is $554 for institutional providers that are

bull Initially enrolling in the Medicare or Medicaid program or the Childrens Health Insurance Program (CHIP)

bull Revalidating their Medicare Medicaid or CHIP enrollmentbull Adding a new Medicare practice locationbull This fee is required with any enrollment application submitted from

January 1 through December 31 2016

64

Medicare MAC-Higlas

bull Effective 142016 CMS has implemented a change to begin netting (offsetting) provider money across workloads within a single organization What this means is that any related providers conducting business in two different workloads (example New York and Maine) will have their money applied to any account receivables (AR) with a remaining balance owed to Medicare within both workloads For example Provider ABC is located in New York and is scheduled to receive a payment of $1000 on todays remittance advice Provider XYZ is related to provider ABC but is located in Maine and has ARs with a balance owed of $200 Provider ABCs $1000 payment will have the $200 applied against provider XYZs ARs resulting in a net payment of $800 This will be reflected on the remittance advice by the same PLB code as seen today for offsets for the $200

65

Two Midnight RuleChange January 1 2016 httpswwwcmsgovMedicareMedicare-Fee-for-Service-PaymentHospitalOutpatientPPSHospital-Outpatient-Regulations-and-Notices-ItemsCMS-1633-FChtml

66

Two Midnight Rulebull However effective January 1 2016 CMS will allow exceptions to the

Two-Midnight Benchmark to be determined on a case-by-case basis by the physician responsible for the care of the beneficiary subject to medical review Said differently Part A payment may be appropriate in some circumstances even though there is no expectation by the physician (or qualified ordering practitioner) of a two-midnight stay and one of the two pre-existing categorical exceptions (CMS ldquoinpatient onlyrdquo list and newly initiated mechanical ventilation) does not apply CMS has indicated that this change to the Two Midnight Rule is in response to stakeholder concern and CMSrsquos continued efforts to develop the most appropriate standard for determining Medicare Part A payment

67

Two Midnight Rulebull A new 42 CFR sect4123(a) provides that a patient is considered an

inpatient of a hospitalhellipif formally admitted as an inpatient pursuant to an order for inpatient admission by a physician or other qualified practitionerhellip The physician orders inpatient status when he or she expects the patient to require a stay that crosses at least 2 midnights[10] Stays expected to be shorter than at least two midnights are generally inappropriate for inpatient admission and inpatient payment under Medicare Part A unless the surgical procedure is specified by Medicare as inpatient only under sect41922(n)[11] The physicians expectationhellipshould be based on such complex medical factors as patient history and comorbidities the severity of signs and symptoms current medical needs and the risk of an adverse event[12] The physician order is part of physician certification of the medical necessity of hospital inpatient serviceshellip[13]

68

InPatient Vs Observation Conthellip

bull Physician certification which begins with an order for inpatient admission requires the physician to certify the reasons for the hospitalization the estimated time the patient will remain in the hospital and plans for post-hospital care if appropriate[14] The certification must be completed signed and documented in the medical record prior to discharge[15]

bull A physicians admission order has no presumptive weight and both the admission order and the physician certification will be evaluated in the context of the evidence in the medical record[16] CMS intends to provide additional information about what evidence in the medical record means in future instructions and manual revisions[17]

69

Two Midnight Rulebull Although the new case-by-case exception appears to be inherently

subjective to a certain extent CMS states that the following factors (among others) would be relevant to determining whether a patient requires inpatient admission under the expanded policy

bull The severity of the signs and symptoms exhibited by the patient bull The medical predictability of something adverse happening to the patient

and bull The need for diagnostic studies that appropriately are outpatient services

(that is their performance does not ordinarily require the patient to remain at the hospital for 24 hours or more)

bull CMS also notes that an inpatient admission (and Part A payment) should be ldquorare and unusualrdquo for minor surgical procedures or other treatment that is expected to keep the patient in the hospital ldquofor only a few hoursrdquo or for a period of time that ldquodoes not span at least overnightrdquo (thus a subset of stays not meeting the Two Midnight Benchmark) CMS indicates that such cases will be prioritized for medical review

70

Health Data Insights amp Medicare Plus Blue

RAC (Retrospective Audits)

71

HDI Health Data amp Med Plus Blue

bull httpwwwhealthdatainsightscombull Blue Cross Medicare Advantage Auditsbull Facilities seeing 10 to 15 requests for Medical Recordsbull In January amp Feburarybull Selected Health Data Insights because they were a premier Audit

Vendor for CMS Recovery Audit Contractor (RAC) demonstration Project They are a audit vendor for Humana

bull Providers not sending Medical Record will get technical denial and lose payments

72

Health Data InSight

bull In 2010 they began the Hospital Reviewbull Medicare Advantage encounter datandashCMS oversight of data integrity OIG

2016bull We will review CMSs oversight of MA encounter data validation and assess

the extent to which CMSrsquos Integrated Data Repository contains timely valid and complete MA encounter data In 2012 CMS began collecting from MA organizations a more comprehensive set of encounter data reflecting the items and services provided to MA plan enrollees Prior CMS and OIG audits have indicated vulnerabilities in the accuracy of data reporting by MA organizations Realizing the potential benefits of the MA encounter data for payment and program integrity oversight is contingent upon the datarsquos completeness validity and timeliness (OEI 03-15-00060 expected issue date FY 2017)

73

Pepper Reports

bull httpswwwpepperresourcesorg

bull Program for Evaluating Payment Patterns Electronic Report ( PEPPER)

bull Annually on or about April 18 2016 will be released

bull Pepper Portal httpssecurefiletmforg

74

CGI Technologies and Solutions Inc httpracbcgicomContactInfoaspxst=1

bull Indiana bull Michiganbull Minnesotabull Illinoisbull Kentuckybull Ohiobull Wisconsin CGI Technologies and Solutions Incbull For general and administrative questions regarding client service outreach

quality assurance or project-specific issues contactbull 1877316RACB (7222)bull Email racbcgicom Tamara Tate Tamaratatecmshhsgovbull 4107861288

75

CGI Federal RAC

bull CGI Federal RAC Region Bbull Email racbcgicombull Phone 1-877-316-RACB (7222)bull Mailing Addressbull Send medical records as followsbull Medical records for Indiana Illinois Kentucky Michigan Ohio Wisconsin

Minnesota DME and Home Health CGI Federal Inc Attn RACB Imaging Dept 1001 Lakeside Ave Suite 800 Cleveland OH 44114

bull If submitting paper records please send medical records as follows For Therapy Reviews CGI Federal Inc Attn RACB Imaging 1001 Lakeside Avenue Suite 800 Cleveland OH 44114

76

How to survive RAC Audit

bull National health expenditures totaled $1679 Billion in 2003 bull National health expenditures were 153 of GROSS Domestic Product

(GDP) in 2003 bull Health care cost increasing at +9 per year bull Doomsday predictions of Medicare running out bull Congressional Action

77

RAC Audits

bull Medicare Modernization Act (MMA) of 2003Mandated a three year audit demonstration project 2005-2008

bull Appoint audit contractors to review Medicare billings for proper coding DRG assignment and medical necessity

bull Audits will apply to all health care providers (hospitals physicians homecare dme etc)

bull Audit contractors to be paid on a contingency basis a percentage of overpayments recovered

78

How Did we get here

bull Overpayments collected due to errors in Medically Unnecessary Services ndash 40

bull Incorrectly Coded ndash 35

bull Other ndash 17

bull NoInsufficient Documentation ndash 8

79

Where are we now

bull All RACrsquos completed required provider outreachAccess to Medicare billing data base given to all RAC RAC review methodology

bull Automated Review-Black amp White Issues (current) bull DRG Validation-complex review (current) bull Complex Review for coding errors (current) bull DME Medical Necessity Reviews ndashcomplex review (calendar year

2010) bull Medical Necessity Reviews-complex review (calendar year 2010)

80

RAC Reviews

bull Responsibilities of the Team Leader bull Must learn each insurance provider participating in a RAC or RAC type

program bull What are their operating rulesbull What is their appeal process Time limits

May be different process for each insurance provider bull Develop a response team

Identify who does what when why and alternate bull individual

Build and develop a manual process Review of computerized system

81

Priority Health SCIO Health Analytics

bull httpswwwsciohealthanalyticscomcore-capabilitiespayment-integrityfacility-auditsskilled-nursing-facility-audits

bull Claims for Medicare members treated at Skilled Nursing Facilities are reimbursed based on the patientsrsquo RUG (Resource Utilization Group) score which is determined using the Minimum Data Set (MDS) Using SCIOs robust analytics claims andor providers that merit review are selected for audit SCIOs auditors conduct a detailed review of the complete medical record and associated MDS to determine if the billed RUG score is valid In the event the review determines that an incorrect RUG score was billed SCIOreg provides the valid score reports the reason the change was necessary and calculates the resulting overpayment

82

+ Cheer

Onward and Upward she shall prevail We are here to care for the residents and provide a wonderful

service

13 83

84

References

bull Priority Healthbull Blue Crossbull Medicaidbull Medicare

85

  • Medicare Mange Care amp Medicaid Changes in the New World We Live In
  • Medicaid
  • NEW Medicaid Change MIlogin
  • Blueprint for Health Innovation MI
  • Provider Enrollment Electronic Signature Form Submission Process MSA 15-54
  • Provider Enrollment Electronic Signature Form Submission Process
  • Provider Enrollment Domain Administrator
  • Medicaid Coinsurance Medicare Advantage
  • Slide Number 9
  • Lawsuit DHS Changes on Caregivers
  • TPL Medicaid Change
  • CHAMPS Member Screen
  • LOC dropping off Not Due to MI Health
  • Issues
  • Secure Email Information
  • Medicaid amp Hospice
  • Medicaid
  • Medicaid Medicare Buy In
  • Manage Medicaid
  • Healthy Michigan Residents
  • Healthy Michigan Medicaid Days
  • McLaren Health Plan
  • Manage Medicaid Plans January 1
  • Slide Number 24
  • MI Health Link
  • MI Health Link 2565
  • What are the Names
  • MI Health Dual Eligible
  • MI Health LOC
  • LOC Medicaid
  • Medicaid Redetermination and MHL Enrollment
  • MI Health Link Portals
  • MI Health Authorizations
  • MI Health Issues
  • LOC 02 dropping MI Health Issues
  • PPA Offset
  • LOCD
  • MI Health Issues-New
  • ACO
  • Families Receiving Letters for ACO
  • ACO What is It
  • Payroll Based Journal
  • Slide Number 43
  • If you submit data manually should you also submit it through the XML
  • Staffing Submission Frequently Asked Questions
  • CMS defines
  • Slide Number 47
  • PBJ Medical Director Role
  • PBJ Medical Director Role
  • Dietician
  • Pharmacy Consultant
  • What are the names for the Medicare Number
  • QTSO
  • Medicare Update
  • CMS Final Rule On Returning Credits
  • Over Payment Rule
  • Questions to MAC
  • Questions to MAC
  • Final Rule on Returning Credits
  • Final Rule on Returning Credits
  • Final Rule on Returning Credits
  • Slide Number 62
  • Medicare Advantage Payors
  • Medicare Provider Enrollment Fee
  • Medicare MAC-Higlas
  • Two Midnight Rule
  • Two Midnight Rule
  • Two Midnight Rule
  • InPatient Vs Observation Conthellip
  • Two Midnight Rule
  • Health Data Insights amp Medicare Plus Blue
  • HDI Health Data amp Med Plus Blue
  • Health Data InSight
  • Pepper Reports
  • CGI Technologies and Solutions Inc httpracbcgicomContactInfoaspxst=1
  • CGI Federal RAC
  • How to survive RAC Audit
  • RAC Audits
  • How Did we get here
  • Where are we now
  • RAC Reviews
  • Priority Health SCIO Health Analytics
  • Cheer
  • References
Page 2: Medicare, Mange Care & Medicaid Changes in the New World we live in

Medicaid What are we seeing

2

NEW Medicaid Change MIloginbull File Transfer to send information to the State On May 20th 2016 users will access File Transfer

through MILogin rather than Single Sign-On

bull httpsmilogintpmichigangovuisecuretpselfserviceanonymouslogout

bull What is MILogin MILogin is the State of Michiganrsquos new Single Sign-On or SSO Very soon you will begin using MILogin to access some of the State of Michigan systems or applications MILoginwill improve overall functionality security and compliance with Federal and State regulations such as HIPAA

bull When will I use MILogin bull MILogin will be rolled out in phases MDHHS DCH Legacy systems and applications that are

currently on Single Sign-On will be accessed through MILogin by October 2016 For a listing of the systems and applications currently on MILogin please visit httpwwwmichigangovMDHHS-MILogin-Info

bull If I currently use SSO and am a Provider or Advocate do I need to set up a MILogin account bull Current Providers or Advocates who access Single Sign-on (SSO) will not need to create a MILogin

account You will use the same log in information that you currently use to access SSO MILoginwill eventually provide access to all applications needed to conduct business with the State

3

Blueprint for Health Innovation MIbull Michigan announces pilot regions for the Blueprint for Health Innovationbull LANSING Mich ndash In moving forward to better coordinate care lower costs and improve the

health of Michigan residents the Michigan Department of Health and Human Services has selected the five pilot locations for the Blueprint for Health Innovation

bull The identified regions are Jackson County Muskegon County Genesee County Northern Region and the Washtenaw and Livingston counties area Final boundaries will be determined after working with partners to target investments and impact Additional development will begin this summer across the five regions over the three-year project period

bull Launching the pilot regions this summer will help us affect payment reform and lower costs for our residents said Tim Becker chief deputy director of the MDHHS Through the pilots MDHHS will work with the healthcare community to find the best ways to implement changes going forward

bull The phased approach and timelines will be included in the Operational Plan due to Centers for Medicare amp Medicaid Services at the end of May 2016 The pilot regions will play an important role in developing a stakeholder engagement process to gather feedback on the Operational Plan prior to submission

4

Provider Enrollment Electronic Signature Form Submission Process

MSA 15-54Medicaid

5

Provider Enrollment Electronic Signature Form Submission Process

bull In compliance with 42 CFR 455104 the Michigan Department of Health and Human Services (MDHHS) is establishing a new process associated with Medicaid provider screening and enrollment requirements related to program integrity for the Medicaid Fee-for-Service (FFS) program Providers were previously notified of the changes required under 42 CFR 455105 in bulletin MSA 12-55 This bulletin describes the process for assigning additional domain access rights to the Community Health Automated Medicaid Processing System (CHAMPS) Provider Enrollment (PE) subsystem on a providers behalf

bull These forms do not need to be completed if no new domain access rights are needed

bull Issued 12302015bull Effective on 02012016

6

Provider Enrollment Domain Administrator

bull Electronic Signature Agreement Form bull To obtain the required information mandated under 42 CFR 455104 any

provider wishing to appoint another person access to their CHAMPS information must submit an Electronic Signature Agreement form (DCH-1401) and the Electronic Signature Agreement form cover sheet (MDHHS-5405) The two completed forms must be submitted to the MDHHS Medicaid Provider Enrollment Unit for processing MDHHS recommends the provider retain a copy of these forms for their records

bull The Electronic Signature Agreement form is also being updated to include additional language certifying the enrolled provider understands he or she is liable and bound by all information submitted on his or her behalf

7

Medicaid Coinsurance Medicare Advantage

bull Attention Nursing Facility Medicaid Fee for Service Providers

bull As part of the December 11 2015 CHAMPS system update the final phase of the Medicare Advantage Coinsurance Pricing Logic was implemented For claim dates of service 2010 and prior please refer to the Medicaid Provider Manual under General Information for Providers Chapter Section 124 Provider Returning Overpayments

bull For claim dates of service 2011 and forward MDHHS will be initiating the claim adjustment within the next few weeks Providers with further questions can contact Provider Support by phone 1-800-292-2550 or email ProviderSupportmichigangov

8

The State has been paying the wrong coinsurance amount for Medicare Advantage since 2008 Per below they will be doing a claim adjustment in the next few weeks for dates of service 2011 going forward If you have refunded the State by a check watch and make sure they do not double recover the money If they do you will have to get your check and list of people you refunded and send it to providersupportmichigangov They have stated they have fixed the pricing logic to pay it correctly going forward Watch and make sure they are paying the correct amount if not you will have to again pull the information from the coinsurance payer and send it to providersupportmichigangov

For dates of service prior to 2011 you will have to return the Money per the Medicaid manual

Medicaid providers performing self audits may discover an overpayment situation and wish to return theMedicaid overpayment to MDHHS This process should only be used when the provider is unable to claimadjust or it is not practical to claim adjust Sending in a check will not correct the underlying claim(s)data Providers must

10487071048707 Document why the money is being returned (ie provider self audit) and identify provider NPIinformation address dates of service and specialty area (ie durable medical items pharmacyphysician practice hospital etc) and include a basic information letter

10487071048707 Attach an excel spreadsheet document with the Tax ID billing NPIs and associated amounts (ifmultiple IDs exist for the entity) for the MDHHS Accounting Office to apply credit to

10487071048707 Make check payable to State of Michigan and mail to the MDHHSCashierrsquos Unit - Attn Bureauof Finance-MCU (Refer to the Directory Appendix for contact information) 9

Lawsuit DHS Changes on Caregivers

bull A recent Michigan Court of Appeals decision has played havoc on the rules surrounding payments to non-family caregivers DHS rules regarding payments to caregivers state that payments are divestment in two situations 1) prospective payments made to any caregiver (family or non-related) before care is provided and 2) payments to family caregivers absent a Medicaid qualified caregiving contract The Court of Appeals decision Jensen v Department of Human Services confuses the rules and applies the family caregiving contract requirements to all caregivers even professional caregiving agencies The result of the case is that payments to non-family caregivers may be divestment unless the Medicaid applicant has a contract with the caregiver meeting the extremely specific rules found in the Medicaid manual

10

TPL Medicaid Changebull Attention Providersbull Effective October 26 2015 the MDHHS Third Party Liability (TPL)

Update Other Insurance Now Online form will be updated You will now receive a confirmation number when you submit your request If an email address is added within the Requestor Information section once TPL completes your request you will receive an email with the confirmation number and the status of your request Please allow up to 10 business days for information to be verified and updated in the system Please check your spam or junk email folders if you do not receive the email after 10 business days

bull Providers with further questions can contact Provider Support by phone 1-800-292-2550 or email ProviderSupportmichigangov

bull httpsminotifytplstatemiustedpubliccoveragerequestsindex11

CHAMPS Member Screen

bull Attention Providersbull Effective September 25 2015 a change was made to the CHAMPS

system This change modified the provider view for the Member Eligibility Inquiry screen If a member no longer has active Medicaid the hyperlink to view ldquoCommercialOtherrdquo Third Party Liability (TPL) information is disabled Because TPL does not always maintain TPLOther Insurance information for members that do not have active Medicaid coverage this information was disabled to prevent inaccurate information from being reported

12

LOC dropping off Not Due to MI Health

bull If after 30 days the county hasnrsquot processed the 2565 that you have send via the central scan (517-346-9888) AND other methods you choose to use you can email the 2565 to ArdeneMartin

bull At the following mailbox I ask that you put the beneficiaries name in the subject line

bull MSA2565michigangov

13

Issues

bull PPA going all over the place

bull LOC 02 dropping off not related to MI Health

bull LOCD tons of money written off

bull Must check CHAMPS member screen all the time and you must check pending

14

Secure Email Information

bull The State of Michigan asked me to remind you when you are communicating with them regarding residents to not send Resident names Birthdates or Social security numbers in those emails What you send is the Medicaid ID and they can look it up Or if it is a billing issue send them the TCN and the Medicaid ID We have been in the practice of emailing DHS Ardene Martin Integrated Health and Provider Support with all the resident name and such

15

Medicaid amp Hospicebull LOC 07 Manage Medicaid Hospice included so plan would pay

provider and not switch to a LOC 16

bull LOC 02 Medicaid (Regular Medicaid) Hospice not included so switch to 16 Hospice and Hospice pays provider

bull LOC 11 Healthy Michigan is included in plan so plan would pay provider and not switch to LOC 16

bull LOC 005 amp 015 MI Health is up in the air waiting for CMS Currently Hospice is now included

bull LOC 16 is Hospice when they switch from Regular Medicaid only and Hospice pays provider

16

Medicaidbull Going forward please make sure that your Champs ID amp NPI on your member screen matches your facility CHAMPS ID

amp NPI for each resident and matches for all new admissions or new approved Medicaid going forward

bull The edit will be turned on soon to stop the payment of these claims if the CHAMPS ID and NPI do not Match your facility on the Medicaid member screen

bull Make sure you are putting the information correct on the 2565 you send in to DHS

bull 1 I attached a 2565 When you fill this out for new people make sure in box 12 a you put your NPI and 12 b you put your CHAMPS ID This will help the DHS case workers assign the person to your facility

bull 2 I would check all your residents CHAMPS member screens and make sure the NPI and CHAMPS ID are your facilities If not you will have to work with the DHS worker to fix this The DHS worker is the only one that can fix this

bull 3 We are having some issues where the DHS case workers will not change this NPI and CHAMPS ID to your facilities You have to get them to change it or you just will not get paid

bull 4 We situations where the resident is in a facility in Kent County (as an example) but the family lives in Livingston County and completes the applications in Livingston County You will have to get the DHS worker in Livingston to fix it not the local DHS worker in Kent County where your facility is

17

Medicaid Medicare Buy Inbull Based on the information from the Office of Personnel Management Federal

Employeersquos employed as of January 1 1983 are eligible for Medicare Part A(see page 5 of attached document) This was also confirmed with our Social Security liaison If the beneficiary did not retire before 1983 he can enroll in Medicare Part B and pay the premium and then he can enroll in Medicare Part A and pay that premium as well or may qualify for Medicare Buy in of Part A

bull If a beneficiary has an SSA document stating they are not eligible for Medicare as they do not have enough work credits the beneficiarybeneficiary representative needs to go to SSA and let them know that while they know they are not eligible for Medicare Part A free or reduced however they are eligible for Medicare Part B and would like to enroll Once the beneficiary enrolls in Medicare Part B (enrollment period January 1st ndash March 31 each year) and pays the premium then the beneficiary is eligible to either pay for Medicare Part A or that beneficiary may qualify for Medicare Part A buy in through Medicaid Once the beneficiary is enrolled in Medicare Part A and Medicare Part B Medicaid will begin to make payments on claims

18

Manage Medicaid Where are we

19

Healthy Michigan Residents

20

Healthy Michigan Medicaid Days

21

McLaren Health Plan

22

Manage Medicaid Plans January 1bull Region 1 ndash Upper Peninsula Health Planbull Region 2 ndash McLaren Health Plan Meridian Health Plan of Michigan Molina Healthcare of Michigan

UnitedHealthcare Community Planbull Region 3 ndash McLaren Health Plan Meridian Health Plan of Michigan Molina Healthcare of Michigan

UnitedHealthcare Community Planbull Region 4 ndash Blue Cross Complete of Michigan McLaren Health Plan Meridian Health Plan of Michigan Molina

Healthcare of Michigan Priority Health Choice UnitedHealthcare Community Planbull Region 5 ndash McLaren Health Plan Meridian Health Plan of Michigan Molina Healthcare of Michigan

UnitedHealthcare Community Planbull Region 6 ndash Blue Cross Complete of Michigan HAP Midwest Health Plan McLaren Health Plan Meridian Health

Plan of Michigan Molina Healthcare of Michigan UnitedHealthcare Community Planbull Region 7 ndash Blue Cross Complete of Michigan McLaren Health Plan Meridian Health Plan UnitedHealthcare

Community Planbull Region 8 ndash Aetna Better Health of Michigan McLaren Health Plan Meridian Health Plan of Michigan Molina

Healthcare of Michigan Priority Health Choice UnitedHealthcare Community Planbull Region 9 ndash Aetna Better Health of Michigan Blue Cross Complete of Michigan McLaren Health Plan Meridian

Health Plan of Michigan Molina Healthcare of Michigan UnitedHealthcare Community Planbull Region 10 ndash Aetna Better Health of Michigan Blue Cross Complete of Michigan Harbor Health Plan McLaren

Health Plan Meridian Health Plan of Michigan Molina Healthcare of Michigan Total Health Care UnitedHealthcare Community Plan 23

24

MI Health LinkWhere are we

25

MI Health Link 2565

bull This notification is being sent to providers of long term care services including nursing facilities county medical care facilities and hospital long term care units to provide clarification on the process involved with the submission of the Facility Admission Form (MSA-2565-C) for an individual enrolled in the MI Health Link program

bull The MI Health Link program covers the custodiallong term nursing facility service benefit When an individual who is enrolled in the MI Health Link program is admitted to a nursing facility for custodiallong term nursing services a disenrollment from the Integrated Care Organization (MI Health Link health plan) is NOT REQUIRED The Facility Admission Form (MSA-2565-C) should NOT be sent to the Michigan Department of Health and Human Services (MDHHS) Enrollment Services Section for a disenrollment to be processed

26

What are the Names

bull Started as Integrated Health

bull Then called MMP (Medicare Medicaid Program)

bull Duals (Also Known as Duals as in Dual Eligible)

bull Now called MI Health Link

bull Total confusion

27

MI Health Dual Eligible28

MI Health LOC

29

LOC Medicaidbull We have the new pilot program which started on March

1 2015 in Southwest Michigan Region 4 Counties Macomb Wayne and the UP You could see these patients they are dual eligible in the Pilot program in counties surrounding the pilot

bull MHL-LOC 005 (All other Facilities) or LOC 015 (County Care) These residents have to call Michigan Enrolls to dis-enroll toll-free at 1-800-975-7630 (TTY 1-888-263-5897) Monday-Friday from 8 AM to 7 PM Once they dis-enroll they will go to a LOC 02 you have to do a new LOCD

30

Medicaid Redetermination and MHL Enrollmentbull At the time of re-determination for Medicaid financial eligibility the MI

Health Link (MHL) program will not be sending beneficiaries information about this program Beneficiaries who previously opted out will not be passively enrolled according to an email from the MHL staff The MHL staff wrote

bull ldquoThere is currently no MI Health Link enrollment letter sent to beneficiaries when eligibility is re-determined A person who becomes eligible for MI Health Link enrollment may opt-in at any time

bull When Medicaid re-determination takes place the beneficiary remains in the same ICO unless that beneficiary lost Medicaid coverage If the enrollee loses Medicaid coverage and later regains it they are not passively enrolled into MI Health Link The beneficiary may choose to opt back in to the program at that time if desiredrdquo

bull MHL staff did state that about 1500 beneficiaries will be passively enrolled effective January 1 2016 These specific individuals were given normal notice of 60 and 30 days in which to opt-in or opt-out if they so chose No other large scale passive enrollment is scheduled according to the MHL staff 31

MI Health Link Portals

bull Meridian Health Planbull httpwwwmhplancommibull Amerihealthbull httpwwwamerihealthcaritasvipcarepluscomproviderself-service-

toolsindexaspxbull AetnaCoventrybull httpwwwaetnabetterhealthcomMichiganprovidersportalbull Molinabull httpwwwmolinahealthcarecommembersmien-usmemPageshomeaspxbull HAPMidwestbull httpswwwmidwesthealthplancomLoginaspxbull FidelisCentenebull wwwfidelissccommmp 32

MI Health Authorizationsbull We need to watch these authorization that the plans are giving us for the MI

Health program Some plans are assigning a diagnosis for residents in their prior authorizations They are assigning diagnosis that the residents do not even have You need to make sure these are correct diagnosis and if not you need to work with the case managers of the plans to fix the issue The authorization numbers do change

bull Make sure that any resident that is in a MI Health plan that you have a prior authorization All plans are giving different periods authorizing the residents stay in the facility You need to set up a system to make sure you always have a authorization for the period of time you are rendering the service Here is an example of time frame of authorizations

bull Meridian is authorizing 12 monthsbull Aetna is authorizing 3 monthsbull Molina is authorizing 6 monthsbull The authorization numbers need to go on your claims to the payer You need to

put the authorizations in your software and track the dates

33

MI Health Issuesbull We are seeing some issues with MI Health where the resident does not have the correct LOC or it shows

up correct on CHAMPS but ancillary providers such as Dentist and such cannot see it I think we still have some issues with the information crossing between Bridges DHS system CMS and CHAMPS It in return is creating some access of care issues If it is a true LOC issues Facilities with LOC issues need to submit the Medicaid ID numbers to the MSA-MHL-EnrollmentMichigangov box with the subject line Nursing home LOC Issue so they may work to resolve the issues

bull If it becomes an access to care issue email the information to INTEGRATEDCAREmichigangov Remember in these emails only send the Medicaid ID and explain the situation The State will work with the plans to try to fix the process or improve the process

bull We are also seeing with new admission with LOC 015 or 005 that the plans are stating they have 14 days to authorize admission These are resident in the emergency room and possibly be admitted to you for Rehab The hospital will not keep the resident in ER for 14 days and you cannot admit the resident until you have a prior authorization I would recommend when you are told this by the plan that you need to ask to speak to a manager We will have to work through this

bull Ancillary Provider You need to work with your ancillary providers such as Lab Pharmacy X-Ray Physician and such to get the to be credentialed with the plans We are hearing that some of the pharmacies are not participating with the plans this will create issues for you so I would continue to ask these groups to participate

34

LOC 02 dropping MI Health Issuesbull The passive enrollments have occurred in Macomb amp Wayne for

Medicaid dual eligible We are having the same issue we did as in the Southwest MI amp UP with the passive enrollments I am starting to hear from facilities who are checking there CHAMPS member screens that those residents that have opted out (some residents not all) have lost there 02 Make sure you are checking your CHAMPS member screen both for those that were passively enrolled and those that might have lost there 02 Medicaid that opted out

bull Facilities with LOC issues need to submit the Medicaid ID numbers to the (Only MI Health)MSA-MHL-Enrollmentmichigangov box with the subject line Nursing home LOC Issue so they may work to resolve the issues

35

PPA Offset

bull There are no co-pays deductibles or premiums in MI Health Link so there should be no need to offset the PPA with code 25 MI Health Link enrollees can continue to offset their PPA for non-program covered medical expenses (like Vision-Code 27 Dental-Code 28 and Hearing-Code 26) and use the appropriate codes to offset the PPA when billing the health plan for nursing facility services

bull Resident pay PPA when MedicareMedicaid coinsurance

36

LOCDbull Nursing Facility Level of Care Determination (NFLOCD)

bull The MI Health Link health plan will be responsible for conducting the Michigan Medicaid NFLOCD tool for enrollees seeking admission to a nursing facility For existing residents at the time of enrollment the existing NFLOCD will be adopted for capitation payment purposes The health plan will complete a new NFLCOD tool within the first 90 days of enrollment If a nursing facility resident is disenrolled from MI Health Link the nursing facility will be responsible for conducting a new NFLOCD tool in accordance with published Medicaid policy

37

MI Health Issues-New

bull INTEGRATEDCAREmichigangov

bull Email with Insurance Plan issues Case Manager Issues

38

ACOWhat are they

39

Families Receiving Letters for ACO

40

ACO What is It

bull Whats an ACObull Accountable Care Organizations (ACOs) are groups of doctors hospitals

and other health care providers who come together voluntarily to give coordinated high quality care to their Medicare patients

bull The goal of coordinated care is to ensure that patients especially the chronically ill get the right care at the right time while avoiding

unnecessary duplication of services and preventing medical errorsbull When an ACO succeeds both in delivering high-quality care and

spending health care dollars more wisely it will share in the savings it achieves for the Medicare program

41

Payroll Based JournalMandatory on July 1 2016Internet Explorer Version

Internet Explorer v 10 and v 11 will need to operate in compatibility mode

42

43

If you submit data manually should you also submit it through the XML

bull Now you have three options

bull Submit Manually only

bull Submit through the XML only

bull You are able to submit manually and using the XML

44

45

Staffing Submission Frequently Asked Questions

bull ldquoWho are direct care staffrdquo (Who do we submit data for)bull Submission of data for contract staffbull Medical directors and consultantsbull Staff switching roles or tasks throughout the daybull Hours paid vs hours worked ndash Must be verifiablebull Public postingQuality MeasuresFive Starbull Enforcementbull Voluntary submission risks (noneSo register now)

CMS defines

bull 37 job title codes that are required to match employees to the number of hours each direct care function was performed It is important to work with your teams to define the workers that contribute to each job type and how those daily worked hours are recorded and converted to a PBJ submission

bull The PBJ does include some more specific job descriptions than the 671 For example the PBJ system includes job descriptions for RNs with administrative duties and LPNs with administrative duties versus the 671rsquos more general ldquoNurses with Administrative Duties

Page 46

47

PBJ Medical Director Rolebull Physician Leadership

bull Help the facility ensure that patients have appropriate physician coverage and ensure the provision of physician and health care practitioner services and

bull Help the facility develop a process for reviewing physician and health care practitioner credentials

bull Provide specific guidance for physician performance expectations

bull Help the facility ensure that a system is in place for monitoring the performance of health care practitioners and

bull Facilitate feedback to physicians and other health care practitioners on performance and practices

bull Patient Care - Clinical Leadership

bull Participate in administrative decision-making and the development of policies and procedures related to patient care

bull Help develop approve and implement specific clinical practices for the facility to incorporate into its care-related policies and procedures including areas required by laws and regulations

bull Develop procedures and guidance for facility staff regarding contacting practitioners including information gathering and presentation change in condition assessment and when to contact the medical director

bull Review consider andor act upon consultant recommendations as appropriate that affect the facilitys resident care policies and procedures or the care of an individual resident

bull Review respond to and participate in federal state local and other external surveys and inspections and

bull Help review policies and procedures regarding the adequate protection of patients rights advance care planning and other ethical issues48

PBJ Medical Director Rolebull Quality of Care

bull Help the facility establish systems and methods for reviewing the quality and appropriateness of clinical care and other health-related services and provide appropriate feedback and

bull Participate in the facilitys quality improvement process

bull Advise on infection control issues and approve specific infection control policies to be incorporated into facility policies and procedures

bull Help the facility provide a safe and caring environment

bull Help promote employee health and safety and

bull Assist in the development and implementation of employee health policies and programs

bull Education Information and Communication

bull Promote a learning culture within the facility by educating informing and communicating

bull Provide information to help the facility provide care consistent with current standards of practice (defined as approaches to care procedures techniques and treatments that are based on research and or expert consensus and that are contained in current manuals textbooks and or publications or that are accepted adopted or promulgated by recognized organizations or national bodies)

bull Help the facility develop medical information and communication systems with staff patients and families and others

bull Represent the facility to the professional and lay community on medical and patient care issues

bull Maintain knowledge of the changing social regulatory political and economic factors that affect medical and health services of long term care patients and

bull Help establish appropriate relationships with other health care organizations

49

Dietician

bull When the dietary or food services supervisor is other than a registered dietitian the supervisor shall receive routine consultation and technical assistance from a registered dietitian (RD) Consultation time shall not be less than 4 hours every 60 days Additional consultation time may be needed based on the total number of patients incidence of nutrition-related health problems and food service management needs of the facility

50

Pharmacy Consultant

bull At least once per month a licensed pharmacist must perform a drug regimen review (DRR) for each resident The pharmacist must report any irregularities to the attending physician or director of nursing Furthermore these reports must be acted upon

51

What are the names for the Medicare Numberbull OSCAR -Online Survey Certification and Reporting

bull PTAN-PTAN number is assigned by Medicare to authenticate the provider when using the local Medicare Administrative Contractorrsquos (MAC) self-help tools like the IVR internet portal on-line application status etc Provider Transactions Access Number

bull CCN- CMS Certification Number

bull Medicare Number- example 23-

bull All of the above mean the same thing

52

QTSO

bull Once you are logged in the QTSO site bull You will have a state login to the site to access the various site specific

to your facilitybull Installing you will need administrator rights to your network

53

Medicare UpdateWhat are we seeing

54

CMS Final Rule On Returning Credits

httpswwwfederalregistergovarticles201602122016-02789medicare-program-reporting-and-returning-of-overpayments

55

Over Payment Rule

bull Medicare payments for non covered services

bull Medicare payments in excess of the allowable amount for an identified covered service

bull Errors and non reimbursable expenditures in cost reportsbull Duplicate payment

bull Receipt of Medicare payments when another payor had the primary responsibility for payment

56

Questions to MAC

bull Does the Medicare credit balance report change with this overpayment rule

bull No Medicare Credit Balances are still required at the end of each quarter

bull Will that still be the communication to let CMS or the MAC know that we have received an overpayment

bull Submission of Medicare Credit Balance is one form of communicating overpayments to CMS Other methods include submitting a voluntary refund with required claim information or the submission of a standard overpayment form

57

Questions to MAC

bull Will the MAC still deduct from a future RAbull If the recovery of the overpayment includes adjusting a claim then

the overpayment would be netted against future claims payments and reflected on the RA

bull Or will that process change with this new rulebull Process will remain the samebull Will NGS send communication out on thisbull Yes NGS will communicate this once the final rule is communicated

to the MACs by CMS However this could change depending on final CMS instructions

58

Final Rule on Returning Credits

bull Providers will want to immediately update their current policies governing overpayments in order to comply with this new rule which will take effect on March 14 2016

bull Providers and suppliers are required to use reasonable diligence to investigate credible information regarding overpayments through both proactive compliance efforts and reactive investigations

bull If an overpayment is identified then it must be repaid within 60 days An overpayment is identified when a person has or should have through the exercise of reasonable diligence determined that the person received an overpayment and quantified the amount

bull Providers and suppliers have a maximum of 8 months to report and return overpayments ndash up to 6 months to investigate and quantify the overpayment (ie to identify it) and up to 60 days to report and return the overpayment

59

Final Rule on Returning Credits

bull Providers and suppliers are required to report and return all overpayments within a 6-year lookback period

bull The cause and amount of the overpayment is irrelevant for the determination eg it was due to a mistake it was someone elsersquos fault it is a minor amount An overpayment is an overpayment and must be returned

bull Providers and suppliers must make their own determination to which entity to report and return the overpayment ie to the Medicare contractor or using the OIG Self Disclosure Protocol or the CMS Self Referral Disclosure Protocol

60

Final Rule on Returning Credits

bull Providers and suppliers may use the claims adjustment credit balance self-reported refund process or another appropriate process to report and return overpayments At this time there is no standard refund form to use

bull Failure to report and return an overpayment could subject the provider or supplier to False Claims Act liability Civil Monetary Penalties Law liability and exclusion from federal health care programs

61

P S amp R-Accountants will be asking for this information

The location you login into has changed it is now on EIDM EIDM is the acronym for CMS Enterprise Identity Management system which includes Identity Verification Access Management Authorization Assistance Workflow Tools and Identity Lifecycle Management functions

httpswwwcmsgovResearch-Statistics-Data-and-SystemsCMS-Information-TechnologyIACSCMS-Applications-Loginhtml

Go down the page and click on the PSampRSTARThis will take you to the login pagewill look the same as the old P S amp R didChanges Affecting PSampR System Access (Please Read) (posted 01292015)(Updated 5262015)is changingThe system which controls your PSampR user ID (currently IACS)The new system is referred to as EIDMThis will result in a different way to create new accounts or change passwords to existing accountsIf you already have an account in EIDM you may have to use that account for accessing PSampR after the transitionWhen is the change effectiveJune 13 2015What is staying the sameThe internet address for accessing PSampR remains the sameThe PSampR systemfunctionality is NOT changing 62

Medicare Advantage Payorsbull Medicare Advantage payors are pullingdenying payments on admissions if the patient was readmitted within 30 days after discharge The

client believes that the payors systematically denying payments for all readmissions within 30 days They believe this practice denies them due process to address whether the readmissions were justified and not due to a premature discharge of patient The payors seem to want to act like a QIO without having the same accountabilities of the QIO related to determinations of non-payment

bull Heres the QIO process under section 4240 of the QIO Manualbull 4240 - Readmission Review - (Rev 2 07-11-03)bull Readmission review involves admissions to an acute general short-term hospital occurring less than 31 calendar days from the date of

discharge from the same or another acute general short-term hospital (see sect1154(a)(13) and 42 CFR 47671(a)(8)(ii)) Neither the day of discharge nor the day of admission is counted when determining whether a readmission has occurred

bull A Medical Review Proceduresbull Obtain the appropriate medical records for the initial admission and readmission Perform case review on both stays Analyze the cases

specifically to determine whether the patient was prematurely discharged from the first confinement thus causing readmission Perform an analysis of the stay at the first hospital to determine the cause(s) and extent of any problem(s) (eg incomplete or substandard treatment) Consider the information available to the attending physician who discharged the patient from the first confinement Do not base a determination of a premature discharge on information that the physician or provider could not have known or events that could not have been anticipated at the time of discharge

bull Review both the initial admission and the readmission at the same time unless one of them has previously been reviewed In these cases use at a minimum the PRAF case summary of the other admission in addition to the medical record of the case under review

bull C Denialsbull Deny readmissions under the following circumstancesbull If the readmission was medically unnecessarybull If the readmission resulted from a premature discharge from the same hospital orbull If the readmission was a result of circumvention of PPS by the same hospital (see sect4255)bull With the QIO process there is an appeal within the QIO here the hospital is getting no opportunity to challenge the denials

63

Medicare Provider Enrollment Feebull Provider Enrollment Application Fee Amount for CY 2016bull On December 3 CMS issued a notice Provider Enrollment Application

Fee Amount for CY 2016 [CMSndash6066ndashN] Effective January 1 2016 the CY 2016 application fee is $554 for institutional providers that are

bull Initially enrolling in the Medicare or Medicaid program or the Childrens Health Insurance Program (CHIP)

bull Revalidating their Medicare Medicaid or CHIP enrollmentbull Adding a new Medicare practice locationbull This fee is required with any enrollment application submitted from

January 1 through December 31 2016

64

Medicare MAC-Higlas

bull Effective 142016 CMS has implemented a change to begin netting (offsetting) provider money across workloads within a single organization What this means is that any related providers conducting business in two different workloads (example New York and Maine) will have their money applied to any account receivables (AR) with a remaining balance owed to Medicare within both workloads For example Provider ABC is located in New York and is scheduled to receive a payment of $1000 on todays remittance advice Provider XYZ is related to provider ABC but is located in Maine and has ARs with a balance owed of $200 Provider ABCs $1000 payment will have the $200 applied against provider XYZs ARs resulting in a net payment of $800 This will be reflected on the remittance advice by the same PLB code as seen today for offsets for the $200

65

Two Midnight RuleChange January 1 2016 httpswwwcmsgovMedicareMedicare-Fee-for-Service-PaymentHospitalOutpatientPPSHospital-Outpatient-Regulations-and-Notices-ItemsCMS-1633-FChtml

66

Two Midnight Rulebull However effective January 1 2016 CMS will allow exceptions to the

Two-Midnight Benchmark to be determined on a case-by-case basis by the physician responsible for the care of the beneficiary subject to medical review Said differently Part A payment may be appropriate in some circumstances even though there is no expectation by the physician (or qualified ordering practitioner) of a two-midnight stay and one of the two pre-existing categorical exceptions (CMS ldquoinpatient onlyrdquo list and newly initiated mechanical ventilation) does not apply CMS has indicated that this change to the Two Midnight Rule is in response to stakeholder concern and CMSrsquos continued efforts to develop the most appropriate standard for determining Medicare Part A payment

67

Two Midnight Rulebull A new 42 CFR sect4123(a) provides that a patient is considered an

inpatient of a hospitalhellipif formally admitted as an inpatient pursuant to an order for inpatient admission by a physician or other qualified practitionerhellip The physician orders inpatient status when he or she expects the patient to require a stay that crosses at least 2 midnights[10] Stays expected to be shorter than at least two midnights are generally inappropriate for inpatient admission and inpatient payment under Medicare Part A unless the surgical procedure is specified by Medicare as inpatient only under sect41922(n)[11] The physicians expectationhellipshould be based on such complex medical factors as patient history and comorbidities the severity of signs and symptoms current medical needs and the risk of an adverse event[12] The physician order is part of physician certification of the medical necessity of hospital inpatient serviceshellip[13]

68

InPatient Vs Observation Conthellip

bull Physician certification which begins with an order for inpatient admission requires the physician to certify the reasons for the hospitalization the estimated time the patient will remain in the hospital and plans for post-hospital care if appropriate[14] The certification must be completed signed and documented in the medical record prior to discharge[15]

bull A physicians admission order has no presumptive weight and both the admission order and the physician certification will be evaluated in the context of the evidence in the medical record[16] CMS intends to provide additional information about what evidence in the medical record means in future instructions and manual revisions[17]

69

Two Midnight Rulebull Although the new case-by-case exception appears to be inherently

subjective to a certain extent CMS states that the following factors (among others) would be relevant to determining whether a patient requires inpatient admission under the expanded policy

bull The severity of the signs and symptoms exhibited by the patient bull The medical predictability of something adverse happening to the patient

and bull The need for diagnostic studies that appropriately are outpatient services

(that is their performance does not ordinarily require the patient to remain at the hospital for 24 hours or more)

bull CMS also notes that an inpatient admission (and Part A payment) should be ldquorare and unusualrdquo for minor surgical procedures or other treatment that is expected to keep the patient in the hospital ldquofor only a few hoursrdquo or for a period of time that ldquodoes not span at least overnightrdquo (thus a subset of stays not meeting the Two Midnight Benchmark) CMS indicates that such cases will be prioritized for medical review

70

Health Data Insights amp Medicare Plus Blue

RAC (Retrospective Audits)

71

HDI Health Data amp Med Plus Blue

bull httpwwwhealthdatainsightscombull Blue Cross Medicare Advantage Auditsbull Facilities seeing 10 to 15 requests for Medical Recordsbull In January amp Feburarybull Selected Health Data Insights because they were a premier Audit

Vendor for CMS Recovery Audit Contractor (RAC) demonstration Project They are a audit vendor for Humana

bull Providers not sending Medical Record will get technical denial and lose payments

72

Health Data InSight

bull In 2010 they began the Hospital Reviewbull Medicare Advantage encounter datandashCMS oversight of data integrity OIG

2016bull We will review CMSs oversight of MA encounter data validation and assess

the extent to which CMSrsquos Integrated Data Repository contains timely valid and complete MA encounter data In 2012 CMS began collecting from MA organizations a more comprehensive set of encounter data reflecting the items and services provided to MA plan enrollees Prior CMS and OIG audits have indicated vulnerabilities in the accuracy of data reporting by MA organizations Realizing the potential benefits of the MA encounter data for payment and program integrity oversight is contingent upon the datarsquos completeness validity and timeliness (OEI 03-15-00060 expected issue date FY 2017)

73

Pepper Reports

bull httpswwwpepperresourcesorg

bull Program for Evaluating Payment Patterns Electronic Report ( PEPPER)

bull Annually on or about April 18 2016 will be released

bull Pepper Portal httpssecurefiletmforg

74

CGI Technologies and Solutions Inc httpracbcgicomContactInfoaspxst=1

bull Indiana bull Michiganbull Minnesotabull Illinoisbull Kentuckybull Ohiobull Wisconsin CGI Technologies and Solutions Incbull For general and administrative questions regarding client service outreach

quality assurance or project-specific issues contactbull 1877316RACB (7222)bull Email racbcgicom Tamara Tate Tamaratatecmshhsgovbull 4107861288

75

CGI Federal RAC

bull CGI Federal RAC Region Bbull Email racbcgicombull Phone 1-877-316-RACB (7222)bull Mailing Addressbull Send medical records as followsbull Medical records for Indiana Illinois Kentucky Michigan Ohio Wisconsin

Minnesota DME and Home Health CGI Federal Inc Attn RACB Imaging Dept 1001 Lakeside Ave Suite 800 Cleveland OH 44114

bull If submitting paper records please send medical records as follows For Therapy Reviews CGI Federal Inc Attn RACB Imaging 1001 Lakeside Avenue Suite 800 Cleveland OH 44114

76

How to survive RAC Audit

bull National health expenditures totaled $1679 Billion in 2003 bull National health expenditures were 153 of GROSS Domestic Product

(GDP) in 2003 bull Health care cost increasing at +9 per year bull Doomsday predictions of Medicare running out bull Congressional Action

77

RAC Audits

bull Medicare Modernization Act (MMA) of 2003Mandated a three year audit demonstration project 2005-2008

bull Appoint audit contractors to review Medicare billings for proper coding DRG assignment and medical necessity

bull Audits will apply to all health care providers (hospitals physicians homecare dme etc)

bull Audit contractors to be paid on a contingency basis a percentage of overpayments recovered

78

How Did we get here

bull Overpayments collected due to errors in Medically Unnecessary Services ndash 40

bull Incorrectly Coded ndash 35

bull Other ndash 17

bull NoInsufficient Documentation ndash 8

79

Where are we now

bull All RACrsquos completed required provider outreachAccess to Medicare billing data base given to all RAC RAC review methodology

bull Automated Review-Black amp White Issues (current) bull DRG Validation-complex review (current) bull Complex Review for coding errors (current) bull DME Medical Necessity Reviews ndashcomplex review (calendar year

2010) bull Medical Necessity Reviews-complex review (calendar year 2010)

80

RAC Reviews

bull Responsibilities of the Team Leader bull Must learn each insurance provider participating in a RAC or RAC type

program bull What are their operating rulesbull What is their appeal process Time limits

May be different process for each insurance provider bull Develop a response team

Identify who does what when why and alternate bull individual

Build and develop a manual process Review of computerized system

81

Priority Health SCIO Health Analytics

bull httpswwwsciohealthanalyticscomcore-capabilitiespayment-integrityfacility-auditsskilled-nursing-facility-audits

bull Claims for Medicare members treated at Skilled Nursing Facilities are reimbursed based on the patientsrsquo RUG (Resource Utilization Group) score which is determined using the Minimum Data Set (MDS) Using SCIOs robust analytics claims andor providers that merit review are selected for audit SCIOs auditors conduct a detailed review of the complete medical record and associated MDS to determine if the billed RUG score is valid In the event the review determines that an incorrect RUG score was billed SCIOreg provides the valid score reports the reason the change was necessary and calculates the resulting overpayment

82

+ Cheer

Onward and Upward she shall prevail We are here to care for the residents and provide a wonderful

service

13 83

84

References

bull Priority Healthbull Blue Crossbull Medicaidbull Medicare

85

  • Medicare Mange Care amp Medicaid Changes in the New World We Live In
  • Medicaid
  • NEW Medicaid Change MIlogin
  • Blueprint for Health Innovation MI
  • Provider Enrollment Electronic Signature Form Submission Process MSA 15-54
  • Provider Enrollment Electronic Signature Form Submission Process
  • Provider Enrollment Domain Administrator
  • Medicaid Coinsurance Medicare Advantage
  • Slide Number 9
  • Lawsuit DHS Changes on Caregivers
  • TPL Medicaid Change
  • CHAMPS Member Screen
  • LOC dropping off Not Due to MI Health
  • Issues
  • Secure Email Information
  • Medicaid amp Hospice
  • Medicaid
  • Medicaid Medicare Buy In
  • Manage Medicaid
  • Healthy Michigan Residents
  • Healthy Michigan Medicaid Days
  • McLaren Health Plan
  • Manage Medicaid Plans January 1
  • Slide Number 24
  • MI Health Link
  • MI Health Link 2565
  • What are the Names
  • MI Health Dual Eligible
  • MI Health LOC
  • LOC Medicaid
  • Medicaid Redetermination and MHL Enrollment
  • MI Health Link Portals
  • MI Health Authorizations
  • MI Health Issues
  • LOC 02 dropping MI Health Issues
  • PPA Offset
  • LOCD
  • MI Health Issues-New
  • ACO
  • Families Receiving Letters for ACO
  • ACO What is It
  • Payroll Based Journal
  • Slide Number 43
  • If you submit data manually should you also submit it through the XML
  • Staffing Submission Frequently Asked Questions
  • CMS defines
  • Slide Number 47
  • PBJ Medical Director Role
  • PBJ Medical Director Role
  • Dietician
  • Pharmacy Consultant
  • What are the names for the Medicare Number
  • QTSO
  • Medicare Update
  • CMS Final Rule On Returning Credits
  • Over Payment Rule
  • Questions to MAC
  • Questions to MAC
  • Final Rule on Returning Credits
  • Final Rule on Returning Credits
  • Final Rule on Returning Credits
  • Slide Number 62
  • Medicare Advantage Payors
  • Medicare Provider Enrollment Fee
  • Medicare MAC-Higlas
  • Two Midnight Rule
  • Two Midnight Rule
  • Two Midnight Rule
  • InPatient Vs Observation Conthellip
  • Two Midnight Rule
  • Health Data Insights amp Medicare Plus Blue
  • HDI Health Data amp Med Plus Blue
  • Health Data InSight
  • Pepper Reports
  • CGI Technologies and Solutions Inc httpracbcgicomContactInfoaspxst=1
  • CGI Federal RAC
  • How to survive RAC Audit
  • RAC Audits
  • How Did we get here
  • Where are we now
  • RAC Reviews
  • Priority Health SCIO Health Analytics
  • Cheer
  • References
Page 3: Medicare, Mange Care & Medicaid Changes in the New World we live in

NEW Medicaid Change MIloginbull File Transfer to send information to the State On May 20th 2016 users will access File Transfer

through MILogin rather than Single Sign-On

bull httpsmilogintpmichigangovuisecuretpselfserviceanonymouslogout

bull What is MILogin MILogin is the State of Michiganrsquos new Single Sign-On or SSO Very soon you will begin using MILogin to access some of the State of Michigan systems or applications MILoginwill improve overall functionality security and compliance with Federal and State regulations such as HIPAA

bull When will I use MILogin bull MILogin will be rolled out in phases MDHHS DCH Legacy systems and applications that are

currently on Single Sign-On will be accessed through MILogin by October 2016 For a listing of the systems and applications currently on MILogin please visit httpwwwmichigangovMDHHS-MILogin-Info

bull If I currently use SSO and am a Provider or Advocate do I need to set up a MILogin account bull Current Providers or Advocates who access Single Sign-on (SSO) will not need to create a MILogin

account You will use the same log in information that you currently use to access SSO MILoginwill eventually provide access to all applications needed to conduct business with the State

3

Blueprint for Health Innovation MIbull Michigan announces pilot regions for the Blueprint for Health Innovationbull LANSING Mich ndash In moving forward to better coordinate care lower costs and improve the

health of Michigan residents the Michigan Department of Health and Human Services has selected the five pilot locations for the Blueprint for Health Innovation

bull The identified regions are Jackson County Muskegon County Genesee County Northern Region and the Washtenaw and Livingston counties area Final boundaries will be determined after working with partners to target investments and impact Additional development will begin this summer across the five regions over the three-year project period

bull Launching the pilot regions this summer will help us affect payment reform and lower costs for our residents said Tim Becker chief deputy director of the MDHHS Through the pilots MDHHS will work with the healthcare community to find the best ways to implement changes going forward

bull The phased approach and timelines will be included in the Operational Plan due to Centers for Medicare amp Medicaid Services at the end of May 2016 The pilot regions will play an important role in developing a stakeholder engagement process to gather feedback on the Operational Plan prior to submission

4

Provider Enrollment Electronic Signature Form Submission Process

MSA 15-54Medicaid

5

Provider Enrollment Electronic Signature Form Submission Process

bull In compliance with 42 CFR 455104 the Michigan Department of Health and Human Services (MDHHS) is establishing a new process associated with Medicaid provider screening and enrollment requirements related to program integrity for the Medicaid Fee-for-Service (FFS) program Providers were previously notified of the changes required under 42 CFR 455105 in bulletin MSA 12-55 This bulletin describes the process for assigning additional domain access rights to the Community Health Automated Medicaid Processing System (CHAMPS) Provider Enrollment (PE) subsystem on a providers behalf

bull These forms do not need to be completed if no new domain access rights are needed

bull Issued 12302015bull Effective on 02012016

6

Provider Enrollment Domain Administrator

bull Electronic Signature Agreement Form bull To obtain the required information mandated under 42 CFR 455104 any

provider wishing to appoint another person access to their CHAMPS information must submit an Electronic Signature Agreement form (DCH-1401) and the Electronic Signature Agreement form cover sheet (MDHHS-5405) The two completed forms must be submitted to the MDHHS Medicaid Provider Enrollment Unit for processing MDHHS recommends the provider retain a copy of these forms for their records

bull The Electronic Signature Agreement form is also being updated to include additional language certifying the enrolled provider understands he or she is liable and bound by all information submitted on his or her behalf

7

Medicaid Coinsurance Medicare Advantage

bull Attention Nursing Facility Medicaid Fee for Service Providers

bull As part of the December 11 2015 CHAMPS system update the final phase of the Medicare Advantage Coinsurance Pricing Logic was implemented For claim dates of service 2010 and prior please refer to the Medicaid Provider Manual under General Information for Providers Chapter Section 124 Provider Returning Overpayments

bull For claim dates of service 2011 and forward MDHHS will be initiating the claim adjustment within the next few weeks Providers with further questions can contact Provider Support by phone 1-800-292-2550 or email ProviderSupportmichigangov

8

The State has been paying the wrong coinsurance amount for Medicare Advantage since 2008 Per below they will be doing a claim adjustment in the next few weeks for dates of service 2011 going forward If you have refunded the State by a check watch and make sure they do not double recover the money If they do you will have to get your check and list of people you refunded and send it to providersupportmichigangov They have stated they have fixed the pricing logic to pay it correctly going forward Watch and make sure they are paying the correct amount if not you will have to again pull the information from the coinsurance payer and send it to providersupportmichigangov

For dates of service prior to 2011 you will have to return the Money per the Medicaid manual

Medicaid providers performing self audits may discover an overpayment situation and wish to return theMedicaid overpayment to MDHHS This process should only be used when the provider is unable to claimadjust or it is not practical to claim adjust Sending in a check will not correct the underlying claim(s)data Providers must

10487071048707 Document why the money is being returned (ie provider self audit) and identify provider NPIinformation address dates of service and specialty area (ie durable medical items pharmacyphysician practice hospital etc) and include a basic information letter

10487071048707 Attach an excel spreadsheet document with the Tax ID billing NPIs and associated amounts (ifmultiple IDs exist for the entity) for the MDHHS Accounting Office to apply credit to

10487071048707 Make check payable to State of Michigan and mail to the MDHHSCashierrsquos Unit - Attn Bureauof Finance-MCU (Refer to the Directory Appendix for contact information) 9

Lawsuit DHS Changes on Caregivers

bull A recent Michigan Court of Appeals decision has played havoc on the rules surrounding payments to non-family caregivers DHS rules regarding payments to caregivers state that payments are divestment in two situations 1) prospective payments made to any caregiver (family or non-related) before care is provided and 2) payments to family caregivers absent a Medicaid qualified caregiving contract The Court of Appeals decision Jensen v Department of Human Services confuses the rules and applies the family caregiving contract requirements to all caregivers even professional caregiving agencies The result of the case is that payments to non-family caregivers may be divestment unless the Medicaid applicant has a contract with the caregiver meeting the extremely specific rules found in the Medicaid manual

10

TPL Medicaid Changebull Attention Providersbull Effective October 26 2015 the MDHHS Third Party Liability (TPL)

Update Other Insurance Now Online form will be updated You will now receive a confirmation number when you submit your request If an email address is added within the Requestor Information section once TPL completes your request you will receive an email with the confirmation number and the status of your request Please allow up to 10 business days for information to be verified and updated in the system Please check your spam or junk email folders if you do not receive the email after 10 business days

bull Providers with further questions can contact Provider Support by phone 1-800-292-2550 or email ProviderSupportmichigangov

bull httpsminotifytplstatemiustedpubliccoveragerequestsindex11

CHAMPS Member Screen

bull Attention Providersbull Effective September 25 2015 a change was made to the CHAMPS

system This change modified the provider view for the Member Eligibility Inquiry screen If a member no longer has active Medicaid the hyperlink to view ldquoCommercialOtherrdquo Third Party Liability (TPL) information is disabled Because TPL does not always maintain TPLOther Insurance information for members that do not have active Medicaid coverage this information was disabled to prevent inaccurate information from being reported

12

LOC dropping off Not Due to MI Health

bull If after 30 days the county hasnrsquot processed the 2565 that you have send via the central scan (517-346-9888) AND other methods you choose to use you can email the 2565 to ArdeneMartin

bull At the following mailbox I ask that you put the beneficiaries name in the subject line

bull MSA2565michigangov

13

Issues

bull PPA going all over the place

bull LOC 02 dropping off not related to MI Health

bull LOCD tons of money written off

bull Must check CHAMPS member screen all the time and you must check pending

14

Secure Email Information

bull The State of Michigan asked me to remind you when you are communicating with them regarding residents to not send Resident names Birthdates or Social security numbers in those emails What you send is the Medicaid ID and they can look it up Or if it is a billing issue send them the TCN and the Medicaid ID We have been in the practice of emailing DHS Ardene Martin Integrated Health and Provider Support with all the resident name and such

15

Medicaid amp Hospicebull LOC 07 Manage Medicaid Hospice included so plan would pay

provider and not switch to a LOC 16

bull LOC 02 Medicaid (Regular Medicaid) Hospice not included so switch to 16 Hospice and Hospice pays provider

bull LOC 11 Healthy Michigan is included in plan so plan would pay provider and not switch to LOC 16

bull LOC 005 amp 015 MI Health is up in the air waiting for CMS Currently Hospice is now included

bull LOC 16 is Hospice when they switch from Regular Medicaid only and Hospice pays provider

16

Medicaidbull Going forward please make sure that your Champs ID amp NPI on your member screen matches your facility CHAMPS ID

amp NPI for each resident and matches for all new admissions or new approved Medicaid going forward

bull The edit will be turned on soon to stop the payment of these claims if the CHAMPS ID and NPI do not Match your facility on the Medicaid member screen

bull Make sure you are putting the information correct on the 2565 you send in to DHS

bull 1 I attached a 2565 When you fill this out for new people make sure in box 12 a you put your NPI and 12 b you put your CHAMPS ID This will help the DHS case workers assign the person to your facility

bull 2 I would check all your residents CHAMPS member screens and make sure the NPI and CHAMPS ID are your facilities If not you will have to work with the DHS worker to fix this The DHS worker is the only one that can fix this

bull 3 We are having some issues where the DHS case workers will not change this NPI and CHAMPS ID to your facilities You have to get them to change it or you just will not get paid

bull 4 We situations where the resident is in a facility in Kent County (as an example) but the family lives in Livingston County and completes the applications in Livingston County You will have to get the DHS worker in Livingston to fix it not the local DHS worker in Kent County where your facility is

17

Medicaid Medicare Buy Inbull Based on the information from the Office of Personnel Management Federal

Employeersquos employed as of January 1 1983 are eligible for Medicare Part A(see page 5 of attached document) This was also confirmed with our Social Security liaison If the beneficiary did not retire before 1983 he can enroll in Medicare Part B and pay the premium and then he can enroll in Medicare Part A and pay that premium as well or may qualify for Medicare Buy in of Part A

bull If a beneficiary has an SSA document stating they are not eligible for Medicare as they do not have enough work credits the beneficiarybeneficiary representative needs to go to SSA and let them know that while they know they are not eligible for Medicare Part A free or reduced however they are eligible for Medicare Part B and would like to enroll Once the beneficiary enrolls in Medicare Part B (enrollment period January 1st ndash March 31 each year) and pays the premium then the beneficiary is eligible to either pay for Medicare Part A or that beneficiary may qualify for Medicare Part A buy in through Medicaid Once the beneficiary is enrolled in Medicare Part A and Medicare Part B Medicaid will begin to make payments on claims

18

Manage Medicaid Where are we

19

Healthy Michigan Residents

20

Healthy Michigan Medicaid Days

21

McLaren Health Plan

22

Manage Medicaid Plans January 1bull Region 1 ndash Upper Peninsula Health Planbull Region 2 ndash McLaren Health Plan Meridian Health Plan of Michigan Molina Healthcare of Michigan

UnitedHealthcare Community Planbull Region 3 ndash McLaren Health Plan Meridian Health Plan of Michigan Molina Healthcare of Michigan

UnitedHealthcare Community Planbull Region 4 ndash Blue Cross Complete of Michigan McLaren Health Plan Meridian Health Plan of Michigan Molina

Healthcare of Michigan Priority Health Choice UnitedHealthcare Community Planbull Region 5 ndash McLaren Health Plan Meridian Health Plan of Michigan Molina Healthcare of Michigan

UnitedHealthcare Community Planbull Region 6 ndash Blue Cross Complete of Michigan HAP Midwest Health Plan McLaren Health Plan Meridian Health

Plan of Michigan Molina Healthcare of Michigan UnitedHealthcare Community Planbull Region 7 ndash Blue Cross Complete of Michigan McLaren Health Plan Meridian Health Plan UnitedHealthcare

Community Planbull Region 8 ndash Aetna Better Health of Michigan McLaren Health Plan Meridian Health Plan of Michigan Molina

Healthcare of Michigan Priority Health Choice UnitedHealthcare Community Planbull Region 9 ndash Aetna Better Health of Michigan Blue Cross Complete of Michigan McLaren Health Plan Meridian

Health Plan of Michigan Molina Healthcare of Michigan UnitedHealthcare Community Planbull Region 10 ndash Aetna Better Health of Michigan Blue Cross Complete of Michigan Harbor Health Plan McLaren

Health Plan Meridian Health Plan of Michigan Molina Healthcare of Michigan Total Health Care UnitedHealthcare Community Plan 23

24

MI Health LinkWhere are we

25

MI Health Link 2565

bull This notification is being sent to providers of long term care services including nursing facilities county medical care facilities and hospital long term care units to provide clarification on the process involved with the submission of the Facility Admission Form (MSA-2565-C) for an individual enrolled in the MI Health Link program

bull The MI Health Link program covers the custodiallong term nursing facility service benefit When an individual who is enrolled in the MI Health Link program is admitted to a nursing facility for custodiallong term nursing services a disenrollment from the Integrated Care Organization (MI Health Link health plan) is NOT REQUIRED The Facility Admission Form (MSA-2565-C) should NOT be sent to the Michigan Department of Health and Human Services (MDHHS) Enrollment Services Section for a disenrollment to be processed

26

What are the Names

bull Started as Integrated Health

bull Then called MMP (Medicare Medicaid Program)

bull Duals (Also Known as Duals as in Dual Eligible)

bull Now called MI Health Link

bull Total confusion

27

MI Health Dual Eligible28

MI Health LOC

29

LOC Medicaidbull We have the new pilot program which started on March

1 2015 in Southwest Michigan Region 4 Counties Macomb Wayne and the UP You could see these patients they are dual eligible in the Pilot program in counties surrounding the pilot

bull MHL-LOC 005 (All other Facilities) or LOC 015 (County Care) These residents have to call Michigan Enrolls to dis-enroll toll-free at 1-800-975-7630 (TTY 1-888-263-5897) Monday-Friday from 8 AM to 7 PM Once they dis-enroll they will go to a LOC 02 you have to do a new LOCD

30

Medicaid Redetermination and MHL Enrollmentbull At the time of re-determination for Medicaid financial eligibility the MI

Health Link (MHL) program will not be sending beneficiaries information about this program Beneficiaries who previously opted out will not be passively enrolled according to an email from the MHL staff The MHL staff wrote

bull ldquoThere is currently no MI Health Link enrollment letter sent to beneficiaries when eligibility is re-determined A person who becomes eligible for MI Health Link enrollment may opt-in at any time

bull When Medicaid re-determination takes place the beneficiary remains in the same ICO unless that beneficiary lost Medicaid coverage If the enrollee loses Medicaid coverage and later regains it they are not passively enrolled into MI Health Link The beneficiary may choose to opt back in to the program at that time if desiredrdquo

bull MHL staff did state that about 1500 beneficiaries will be passively enrolled effective January 1 2016 These specific individuals were given normal notice of 60 and 30 days in which to opt-in or opt-out if they so chose No other large scale passive enrollment is scheduled according to the MHL staff 31

MI Health Link Portals

bull Meridian Health Planbull httpwwwmhplancommibull Amerihealthbull httpwwwamerihealthcaritasvipcarepluscomproviderself-service-

toolsindexaspxbull AetnaCoventrybull httpwwwaetnabetterhealthcomMichiganprovidersportalbull Molinabull httpwwwmolinahealthcarecommembersmien-usmemPageshomeaspxbull HAPMidwestbull httpswwwmidwesthealthplancomLoginaspxbull FidelisCentenebull wwwfidelissccommmp 32

MI Health Authorizationsbull We need to watch these authorization that the plans are giving us for the MI

Health program Some plans are assigning a diagnosis for residents in their prior authorizations They are assigning diagnosis that the residents do not even have You need to make sure these are correct diagnosis and if not you need to work with the case managers of the plans to fix the issue The authorization numbers do change

bull Make sure that any resident that is in a MI Health plan that you have a prior authorization All plans are giving different periods authorizing the residents stay in the facility You need to set up a system to make sure you always have a authorization for the period of time you are rendering the service Here is an example of time frame of authorizations

bull Meridian is authorizing 12 monthsbull Aetna is authorizing 3 monthsbull Molina is authorizing 6 monthsbull The authorization numbers need to go on your claims to the payer You need to

put the authorizations in your software and track the dates

33

MI Health Issuesbull We are seeing some issues with MI Health where the resident does not have the correct LOC or it shows

up correct on CHAMPS but ancillary providers such as Dentist and such cannot see it I think we still have some issues with the information crossing between Bridges DHS system CMS and CHAMPS It in return is creating some access of care issues If it is a true LOC issues Facilities with LOC issues need to submit the Medicaid ID numbers to the MSA-MHL-EnrollmentMichigangov box with the subject line Nursing home LOC Issue so they may work to resolve the issues

bull If it becomes an access to care issue email the information to INTEGRATEDCAREmichigangov Remember in these emails only send the Medicaid ID and explain the situation The State will work with the plans to try to fix the process or improve the process

bull We are also seeing with new admission with LOC 015 or 005 that the plans are stating they have 14 days to authorize admission These are resident in the emergency room and possibly be admitted to you for Rehab The hospital will not keep the resident in ER for 14 days and you cannot admit the resident until you have a prior authorization I would recommend when you are told this by the plan that you need to ask to speak to a manager We will have to work through this

bull Ancillary Provider You need to work with your ancillary providers such as Lab Pharmacy X-Ray Physician and such to get the to be credentialed with the plans We are hearing that some of the pharmacies are not participating with the plans this will create issues for you so I would continue to ask these groups to participate

34

LOC 02 dropping MI Health Issuesbull The passive enrollments have occurred in Macomb amp Wayne for

Medicaid dual eligible We are having the same issue we did as in the Southwest MI amp UP with the passive enrollments I am starting to hear from facilities who are checking there CHAMPS member screens that those residents that have opted out (some residents not all) have lost there 02 Make sure you are checking your CHAMPS member screen both for those that were passively enrolled and those that might have lost there 02 Medicaid that opted out

bull Facilities with LOC issues need to submit the Medicaid ID numbers to the (Only MI Health)MSA-MHL-Enrollmentmichigangov box with the subject line Nursing home LOC Issue so they may work to resolve the issues

35

PPA Offset

bull There are no co-pays deductibles or premiums in MI Health Link so there should be no need to offset the PPA with code 25 MI Health Link enrollees can continue to offset their PPA for non-program covered medical expenses (like Vision-Code 27 Dental-Code 28 and Hearing-Code 26) and use the appropriate codes to offset the PPA when billing the health plan for nursing facility services

bull Resident pay PPA when MedicareMedicaid coinsurance

36

LOCDbull Nursing Facility Level of Care Determination (NFLOCD)

bull The MI Health Link health plan will be responsible for conducting the Michigan Medicaid NFLOCD tool for enrollees seeking admission to a nursing facility For existing residents at the time of enrollment the existing NFLOCD will be adopted for capitation payment purposes The health plan will complete a new NFLCOD tool within the first 90 days of enrollment If a nursing facility resident is disenrolled from MI Health Link the nursing facility will be responsible for conducting a new NFLOCD tool in accordance with published Medicaid policy

37

MI Health Issues-New

bull INTEGRATEDCAREmichigangov

bull Email with Insurance Plan issues Case Manager Issues

38

ACOWhat are they

39

Families Receiving Letters for ACO

40

ACO What is It

bull Whats an ACObull Accountable Care Organizations (ACOs) are groups of doctors hospitals

and other health care providers who come together voluntarily to give coordinated high quality care to their Medicare patients

bull The goal of coordinated care is to ensure that patients especially the chronically ill get the right care at the right time while avoiding

unnecessary duplication of services and preventing medical errorsbull When an ACO succeeds both in delivering high-quality care and

spending health care dollars more wisely it will share in the savings it achieves for the Medicare program

41

Payroll Based JournalMandatory on July 1 2016Internet Explorer Version

Internet Explorer v 10 and v 11 will need to operate in compatibility mode

42

43

If you submit data manually should you also submit it through the XML

bull Now you have three options

bull Submit Manually only

bull Submit through the XML only

bull You are able to submit manually and using the XML

44

45

Staffing Submission Frequently Asked Questions

bull ldquoWho are direct care staffrdquo (Who do we submit data for)bull Submission of data for contract staffbull Medical directors and consultantsbull Staff switching roles or tasks throughout the daybull Hours paid vs hours worked ndash Must be verifiablebull Public postingQuality MeasuresFive Starbull Enforcementbull Voluntary submission risks (noneSo register now)

CMS defines

bull 37 job title codes that are required to match employees to the number of hours each direct care function was performed It is important to work with your teams to define the workers that contribute to each job type and how those daily worked hours are recorded and converted to a PBJ submission

bull The PBJ does include some more specific job descriptions than the 671 For example the PBJ system includes job descriptions for RNs with administrative duties and LPNs with administrative duties versus the 671rsquos more general ldquoNurses with Administrative Duties

Page 46

47

PBJ Medical Director Rolebull Physician Leadership

bull Help the facility ensure that patients have appropriate physician coverage and ensure the provision of physician and health care practitioner services and

bull Help the facility develop a process for reviewing physician and health care practitioner credentials

bull Provide specific guidance for physician performance expectations

bull Help the facility ensure that a system is in place for monitoring the performance of health care practitioners and

bull Facilitate feedback to physicians and other health care practitioners on performance and practices

bull Patient Care - Clinical Leadership

bull Participate in administrative decision-making and the development of policies and procedures related to patient care

bull Help develop approve and implement specific clinical practices for the facility to incorporate into its care-related policies and procedures including areas required by laws and regulations

bull Develop procedures and guidance for facility staff regarding contacting practitioners including information gathering and presentation change in condition assessment and when to contact the medical director

bull Review consider andor act upon consultant recommendations as appropriate that affect the facilitys resident care policies and procedures or the care of an individual resident

bull Review respond to and participate in federal state local and other external surveys and inspections and

bull Help review policies and procedures regarding the adequate protection of patients rights advance care planning and other ethical issues48

PBJ Medical Director Rolebull Quality of Care

bull Help the facility establish systems and methods for reviewing the quality and appropriateness of clinical care and other health-related services and provide appropriate feedback and

bull Participate in the facilitys quality improvement process

bull Advise on infection control issues and approve specific infection control policies to be incorporated into facility policies and procedures

bull Help the facility provide a safe and caring environment

bull Help promote employee health and safety and

bull Assist in the development and implementation of employee health policies and programs

bull Education Information and Communication

bull Promote a learning culture within the facility by educating informing and communicating

bull Provide information to help the facility provide care consistent with current standards of practice (defined as approaches to care procedures techniques and treatments that are based on research and or expert consensus and that are contained in current manuals textbooks and or publications or that are accepted adopted or promulgated by recognized organizations or national bodies)

bull Help the facility develop medical information and communication systems with staff patients and families and others

bull Represent the facility to the professional and lay community on medical and patient care issues

bull Maintain knowledge of the changing social regulatory political and economic factors that affect medical and health services of long term care patients and

bull Help establish appropriate relationships with other health care organizations

49

Dietician

bull When the dietary or food services supervisor is other than a registered dietitian the supervisor shall receive routine consultation and technical assistance from a registered dietitian (RD) Consultation time shall not be less than 4 hours every 60 days Additional consultation time may be needed based on the total number of patients incidence of nutrition-related health problems and food service management needs of the facility

50

Pharmacy Consultant

bull At least once per month a licensed pharmacist must perform a drug regimen review (DRR) for each resident The pharmacist must report any irregularities to the attending physician or director of nursing Furthermore these reports must be acted upon

51

What are the names for the Medicare Numberbull OSCAR -Online Survey Certification and Reporting

bull PTAN-PTAN number is assigned by Medicare to authenticate the provider when using the local Medicare Administrative Contractorrsquos (MAC) self-help tools like the IVR internet portal on-line application status etc Provider Transactions Access Number

bull CCN- CMS Certification Number

bull Medicare Number- example 23-

bull All of the above mean the same thing

52

QTSO

bull Once you are logged in the QTSO site bull You will have a state login to the site to access the various site specific

to your facilitybull Installing you will need administrator rights to your network

53

Medicare UpdateWhat are we seeing

54

CMS Final Rule On Returning Credits

httpswwwfederalregistergovarticles201602122016-02789medicare-program-reporting-and-returning-of-overpayments

55

Over Payment Rule

bull Medicare payments for non covered services

bull Medicare payments in excess of the allowable amount for an identified covered service

bull Errors and non reimbursable expenditures in cost reportsbull Duplicate payment

bull Receipt of Medicare payments when another payor had the primary responsibility for payment

56

Questions to MAC

bull Does the Medicare credit balance report change with this overpayment rule

bull No Medicare Credit Balances are still required at the end of each quarter

bull Will that still be the communication to let CMS or the MAC know that we have received an overpayment

bull Submission of Medicare Credit Balance is one form of communicating overpayments to CMS Other methods include submitting a voluntary refund with required claim information or the submission of a standard overpayment form

57

Questions to MAC

bull Will the MAC still deduct from a future RAbull If the recovery of the overpayment includes adjusting a claim then

the overpayment would be netted against future claims payments and reflected on the RA

bull Or will that process change with this new rulebull Process will remain the samebull Will NGS send communication out on thisbull Yes NGS will communicate this once the final rule is communicated

to the MACs by CMS However this could change depending on final CMS instructions

58

Final Rule on Returning Credits

bull Providers will want to immediately update their current policies governing overpayments in order to comply with this new rule which will take effect on March 14 2016

bull Providers and suppliers are required to use reasonable diligence to investigate credible information regarding overpayments through both proactive compliance efforts and reactive investigations

bull If an overpayment is identified then it must be repaid within 60 days An overpayment is identified when a person has or should have through the exercise of reasonable diligence determined that the person received an overpayment and quantified the amount

bull Providers and suppliers have a maximum of 8 months to report and return overpayments ndash up to 6 months to investigate and quantify the overpayment (ie to identify it) and up to 60 days to report and return the overpayment

59

Final Rule on Returning Credits

bull Providers and suppliers are required to report and return all overpayments within a 6-year lookback period

bull The cause and amount of the overpayment is irrelevant for the determination eg it was due to a mistake it was someone elsersquos fault it is a minor amount An overpayment is an overpayment and must be returned

bull Providers and suppliers must make their own determination to which entity to report and return the overpayment ie to the Medicare contractor or using the OIG Self Disclosure Protocol or the CMS Self Referral Disclosure Protocol

60

Final Rule on Returning Credits

bull Providers and suppliers may use the claims adjustment credit balance self-reported refund process or another appropriate process to report and return overpayments At this time there is no standard refund form to use

bull Failure to report and return an overpayment could subject the provider or supplier to False Claims Act liability Civil Monetary Penalties Law liability and exclusion from federal health care programs

61

P S amp R-Accountants will be asking for this information

The location you login into has changed it is now on EIDM EIDM is the acronym for CMS Enterprise Identity Management system which includes Identity Verification Access Management Authorization Assistance Workflow Tools and Identity Lifecycle Management functions

httpswwwcmsgovResearch-Statistics-Data-and-SystemsCMS-Information-TechnologyIACSCMS-Applications-Loginhtml

Go down the page and click on the PSampRSTARThis will take you to the login pagewill look the same as the old P S amp R didChanges Affecting PSampR System Access (Please Read) (posted 01292015)(Updated 5262015)is changingThe system which controls your PSampR user ID (currently IACS)The new system is referred to as EIDMThis will result in a different way to create new accounts or change passwords to existing accountsIf you already have an account in EIDM you may have to use that account for accessing PSampR after the transitionWhen is the change effectiveJune 13 2015What is staying the sameThe internet address for accessing PSampR remains the sameThe PSampR systemfunctionality is NOT changing 62

Medicare Advantage Payorsbull Medicare Advantage payors are pullingdenying payments on admissions if the patient was readmitted within 30 days after discharge The

client believes that the payors systematically denying payments for all readmissions within 30 days They believe this practice denies them due process to address whether the readmissions were justified and not due to a premature discharge of patient The payors seem to want to act like a QIO without having the same accountabilities of the QIO related to determinations of non-payment

bull Heres the QIO process under section 4240 of the QIO Manualbull 4240 - Readmission Review - (Rev 2 07-11-03)bull Readmission review involves admissions to an acute general short-term hospital occurring less than 31 calendar days from the date of

discharge from the same or another acute general short-term hospital (see sect1154(a)(13) and 42 CFR 47671(a)(8)(ii)) Neither the day of discharge nor the day of admission is counted when determining whether a readmission has occurred

bull A Medical Review Proceduresbull Obtain the appropriate medical records for the initial admission and readmission Perform case review on both stays Analyze the cases

specifically to determine whether the patient was prematurely discharged from the first confinement thus causing readmission Perform an analysis of the stay at the first hospital to determine the cause(s) and extent of any problem(s) (eg incomplete or substandard treatment) Consider the information available to the attending physician who discharged the patient from the first confinement Do not base a determination of a premature discharge on information that the physician or provider could not have known or events that could not have been anticipated at the time of discharge

bull Review both the initial admission and the readmission at the same time unless one of them has previously been reviewed In these cases use at a minimum the PRAF case summary of the other admission in addition to the medical record of the case under review

bull C Denialsbull Deny readmissions under the following circumstancesbull If the readmission was medically unnecessarybull If the readmission resulted from a premature discharge from the same hospital orbull If the readmission was a result of circumvention of PPS by the same hospital (see sect4255)bull With the QIO process there is an appeal within the QIO here the hospital is getting no opportunity to challenge the denials

63

Medicare Provider Enrollment Feebull Provider Enrollment Application Fee Amount for CY 2016bull On December 3 CMS issued a notice Provider Enrollment Application

Fee Amount for CY 2016 [CMSndash6066ndashN] Effective January 1 2016 the CY 2016 application fee is $554 for institutional providers that are

bull Initially enrolling in the Medicare or Medicaid program or the Childrens Health Insurance Program (CHIP)

bull Revalidating their Medicare Medicaid or CHIP enrollmentbull Adding a new Medicare practice locationbull This fee is required with any enrollment application submitted from

January 1 through December 31 2016

64

Medicare MAC-Higlas

bull Effective 142016 CMS has implemented a change to begin netting (offsetting) provider money across workloads within a single organization What this means is that any related providers conducting business in two different workloads (example New York and Maine) will have their money applied to any account receivables (AR) with a remaining balance owed to Medicare within both workloads For example Provider ABC is located in New York and is scheduled to receive a payment of $1000 on todays remittance advice Provider XYZ is related to provider ABC but is located in Maine and has ARs with a balance owed of $200 Provider ABCs $1000 payment will have the $200 applied against provider XYZs ARs resulting in a net payment of $800 This will be reflected on the remittance advice by the same PLB code as seen today for offsets for the $200

65

Two Midnight RuleChange January 1 2016 httpswwwcmsgovMedicareMedicare-Fee-for-Service-PaymentHospitalOutpatientPPSHospital-Outpatient-Regulations-and-Notices-ItemsCMS-1633-FChtml

66

Two Midnight Rulebull However effective January 1 2016 CMS will allow exceptions to the

Two-Midnight Benchmark to be determined on a case-by-case basis by the physician responsible for the care of the beneficiary subject to medical review Said differently Part A payment may be appropriate in some circumstances even though there is no expectation by the physician (or qualified ordering practitioner) of a two-midnight stay and one of the two pre-existing categorical exceptions (CMS ldquoinpatient onlyrdquo list and newly initiated mechanical ventilation) does not apply CMS has indicated that this change to the Two Midnight Rule is in response to stakeholder concern and CMSrsquos continued efforts to develop the most appropriate standard for determining Medicare Part A payment

67

Two Midnight Rulebull A new 42 CFR sect4123(a) provides that a patient is considered an

inpatient of a hospitalhellipif formally admitted as an inpatient pursuant to an order for inpatient admission by a physician or other qualified practitionerhellip The physician orders inpatient status when he or she expects the patient to require a stay that crosses at least 2 midnights[10] Stays expected to be shorter than at least two midnights are generally inappropriate for inpatient admission and inpatient payment under Medicare Part A unless the surgical procedure is specified by Medicare as inpatient only under sect41922(n)[11] The physicians expectationhellipshould be based on such complex medical factors as patient history and comorbidities the severity of signs and symptoms current medical needs and the risk of an adverse event[12] The physician order is part of physician certification of the medical necessity of hospital inpatient serviceshellip[13]

68

InPatient Vs Observation Conthellip

bull Physician certification which begins with an order for inpatient admission requires the physician to certify the reasons for the hospitalization the estimated time the patient will remain in the hospital and plans for post-hospital care if appropriate[14] The certification must be completed signed and documented in the medical record prior to discharge[15]

bull A physicians admission order has no presumptive weight and both the admission order and the physician certification will be evaluated in the context of the evidence in the medical record[16] CMS intends to provide additional information about what evidence in the medical record means in future instructions and manual revisions[17]

69

Two Midnight Rulebull Although the new case-by-case exception appears to be inherently

subjective to a certain extent CMS states that the following factors (among others) would be relevant to determining whether a patient requires inpatient admission under the expanded policy

bull The severity of the signs and symptoms exhibited by the patient bull The medical predictability of something adverse happening to the patient

and bull The need for diagnostic studies that appropriately are outpatient services

(that is their performance does not ordinarily require the patient to remain at the hospital for 24 hours or more)

bull CMS also notes that an inpatient admission (and Part A payment) should be ldquorare and unusualrdquo for minor surgical procedures or other treatment that is expected to keep the patient in the hospital ldquofor only a few hoursrdquo or for a period of time that ldquodoes not span at least overnightrdquo (thus a subset of stays not meeting the Two Midnight Benchmark) CMS indicates that such cases will be prioritized for medical review

70

Health Data Insights amp Medicare Plus Blue

RAC (Retrospective Audits)

71

HDI Health Data amp Med Plus Blue

bull httpwwwhealthdatainsightscombull Blue Cross Medicare Advantage Auditsbull Facilities seeing 10 to 15 requests for Medical Recordsbull In January amp Feburarybull Selected Health Data Insights because they were a premier Audit

Vendor for CMS Recovery Audit Contractor (RAC) demonstration Project They are a audit vendor for Humana

bull Providers not sending Medical Record will get technical denial and lose payments

72

Health Data InSight

bull In 2010 they began the Hospital Reviewbull Medicare Advantage encounter datandashCMS oversight of data integrity OIG

2016bull We will review CMSs oversight of MA encounter data validation and assess

the extent to which CMSrsquos Integrated Data Repository contains timely valid and complete MA encounter data In 2012 CMS began collecting from MA organizations a more comprehensive set of encounter data reflecting the items and services provided to MA plan enrollees Prior CMS and OIG audits have indicated vulnerabilities in the accuracy of data reporting by MA organizations Realizing the potential benefits of the MA encounter data for payment and program integrity oversight is contingent upon the datarsquos completeness validity and timeliness (OEI 03-15-00060 expected issue date FY 2017)

73

Pepper Reports

bull httpswwwpepperresourcesorg

bull Program for Evaluating Payment Patterns Electronic Report ( PEPPER)

bull Annually on or about April 18 2016 will be released

bull Pepper Portal httpssecurefiletmforg

74

CGI Technologies and Solutions Inc httpracbcgicomContactInfoaspxst=1

bull Indiana bull Michiganbull Minnesotabull Illinoisbull Kentuckybull Ohiobull Wisconsin CGI Technologies and Solutions Incbull For general and administrative questions regarding client service outreach

quality assurance or project-specific issues contactbull 1877316RACB (7222)bull Email racbcgicom Tamara Tate Tamaratatecmshhsgovbull 4107861288

75

CGI Federal RAC

bull CGI Federal RAC Region Bbull Email racbcgicombull Phone 1-877-316-RACB (7222)bull Mailing Addressbull Send medical records as followsbull Medical records for Indiana Illinois Kentucky Michigan Ohio Wisconsin

Minnesota DME and Home Health CGI Federal Inc Attn RACB Imaging Dept 1001 Lakeside Ave Suite 800 Cleveland OH 44114

bull If submitting paper records please send medical records as follows For Therapy Reviews CGI Federal Inc Attn RACB Imaging 1001 Lakeside Avenue Suite 800 Cleveland OH 44114

76

How to survive RAC Audit

bull National health expenditures totaled $1679 Billion in 2003 bull National health expenditures were 153 of GROSS Domestic Product

(GDP) in 2003 bull Health care cost increasing at +9 per year bull Doomsday predictions of Medicare running out bull Congressional Action

77

RAC Audits

bull Medicare Modernization Act (MMA) of 2003Mandated a three year audit demonstration project 2005-2008

bull Appoint audit contractors to review Medicare billings for proper coding DRG assignment and medical necessity

bull Audits will apply to all health care providers (hospitals physicians homecare dme etc)

bull Audit contractors to be paid on a contingency basis a percentage of overpayments recovered

78

How Did we get here

bull Overpayments collected due to errors in Medically Unnecessary Services ndash 40

bull Incorrectly Coded ndash 35

bull Other ndash 17

bull NoInsufficient Documentation ndash 8

79

Where are we now

bull All RACrsquos completed required provider outreachAccess to Medicare billing data base given to all RAC RAC review methodology

bull Automated Review-Black amp White Issues (current) bull DRG Validation-complex review (current) bull Complex Review for coding errors (current) bull DME Medical Necessity Reviews ndashcomplex review (calendar year

2010) bull Medical Necessity Reviews-complex review (calendar year 2010)

80

RAC Reviews

bull Responsibilities of the Team Leader bull Must learn each insurance provider participating in a RAC or RAC type

program bull What are their operating rulesbull What is their appeal process Time limits

May be different process for each insurance provider bull Develop a response team

Identify who does what when why and alternate bull individual

Build and develop a manual process Review of computerized system

81

Priority Health SCIO Health Analytics

bull httpswwwsciohealthanalyticscomcore-capabilitiespayment-integrityfacility-auditsskilled-nursing-facility-audits

bull Claims for Medicare members treated at Skilled Nursing Facilities are reimbursed based on the patientsrsquo RUG (Resource Utilization Group) score which is determined using the Minimum Data Set (MDS) Using SCIOs robust analytics claims andor providers that merit review are selected for audit SCIOs auditors conduct a detailed review of the complete medical record and associated MDS to determine if the billed RUG score is valid In the event the review determines that an incorrect RUG score was billed SCIOreg provides the valid score reports the reason the change was necessary and calculates the resulting overpayment

82

+ Cheer

Onward and Upward she shall prevail We are here to care for the residents and provide a wonderful

service

13 83

84

References

bull Priority Healthbull Blue Crossbull Medicaidbull Medicare

85

  • Medicare Mange Care amp Medicaid Changes in the New World We Live In
  • Medicaid
  • NEW Medicaid Change MIlogin
  • Blueprint for Health Innovation MI
  • Provider Enrollment Electronic Signature Form Submission Process MSA 15-54
  • Provider Enrollment Electronic Signature Form Submission Process
  • Provider Enrollment Domain Administrator
  • Medicaid Coinsurance Medicare Advantage
  • Slide Number 9
  • Lawsuit DHS Changes on Caregivers
  • TPL Medicaid Change
  • CHAMPS Member Screen
  • LOC dropping off Not Due to MI Health
  • Issues
  • Secure Email Information
  • Medicaid amp Hospice
  • Medicaid
  • Medicaid Medicare Buy In
  • Manage Medicaid
  • Healthy Michigan Residents
  • Healthy Michigan Medicaid Days
  • McLaren Health Plan
  • Manage Medicaid Plans January 1
  • Slide Number 24
  • MI Health Link
  • MI Health Link 2565
  • What are the Names
  • MI Health Dual Eligible
  • MI Health LOC
  • LOC Medicaid
  • Medicaid Redetermination and MHL Enrollment
  • MI Health Link Portals
  • MI Health Authorizations
  • MI Health Issues
  • LOC 02 dropping MI Health Issues
  • PPA Offset
  • LOCD
  • MI Health Issues-New
  • ACO
  • Families Receiving Letters for ACO
  • ACO What is It
  • Payroll Based Journal
  • Slide Number 43
  • If you submit data manually should you also submit it through the XML
  • Staffing Submission Frequently Asked Questions
  • CMS defines
  • Slide Number 47
  • PBJ Medical Director Role
  • PBJ Medical Director Role
  • Dietician
  • Pharmacy Consultant
  • What are the names for the Medicare Number
  • QTSO
  • Medicare Update
  • CMS Final Rule On Returning Credits
  • Over Payment Rule
  • Questions to MAC
  • Questions to MAC
  • Final Rule on Returning Credits
  • Final Rule on Returning Credits
  • Final Rule on Returning Credits
  • Slide Number 62
  • Medicare Advantage Payors
  • Medicare Provider Enrollment Fee
  • Medicare MAC-Higlas
  • Two Midnight Rule
  • Two Midnight Rule
  • Two Midnight Rule
  • InPatient Vs Observation Conthellip
  • Two Midnight Rule
  • Health Data Insights amp Medicare Plus Blue
  • HDI Health Data amp Med Plus Blue
  • Health Data InSight
  • Pepper Reports
  • CGI Technologies and Solutions Inc httpracbcgicomContactInfoaspxst=1
  • CGI Federal RAC
  • How to survive RAC Audit
  • RAC Audits
  • How Did we get here
  • Where are we now
  • RAC Reviews
  • Priority Health SCIO Health Analytics
  • Cheer
  • References
Page 4: Medicare, Mange Care & Medicaid Changes in the New World we live in

Blueprint for Health Innovation MIbull Michigan announces pilot regions for the Blueprint for Health Innovationbull LANSING Mich ndash In moving forward to better coordinate care lower costs and improve the

health of Michigan residents the Michigan Department of Health and Human Services has selected the five pilot locations for the Blueprint for Health Innovation

bull The identified regions are Jackson County Muskegon County Genesee County Northern Region and the Washtenaw and Livingston counties area Final boundaries will be determined after working with partners to target investments and impact Additional development will begin this summer across the five regions over the three-year project period

bull Launching the pilot regions this summer will help us affect payment reform and lower costs for our residents said Tim Becker chief deputy director of the MDHHS Through the pilots MDHHS will work with the healthcare community to find the best ways to implement changes going forward

bull The phased approach and timelines will be included in the Operational Plan due to Centers for Medicare amp Medicaid Services at the end of May 2016 The pilot regions will play an important role in developing a stakeholder engagement process to gather feedback on the Operational Plan prior to submission

4

Provider Enrollment Electronic Signature Form Submission Process

MSA 15-54Medicaid

5

Provider Enrollment Electronic Signature Form Submission Process

bull In compliance with 42 CFR 455104 the Michigan Department of Health and Human Services (MDHHS) is establishing a new process associated with Medicaid provider screening and enrollment requirements related to program integrity for the Medicaid Fee-for-Service (FFS) program Providers were previously notified of the changes required under 42 CFR 455105 in bulletin MSA 12-55 This bulletin describes the process for assigning additional domain access rights to the Community Health Automated Medicaid Processing System (CHAMPS) Provider Enrollment (PE) subsystem on a providers behalf

bull These forms do not need to be completed if no new domain access rights are needed

bull Issued 12302015bull Effective on 02012016

6

Provider Enrollment Domain Administrator

bull Electronic Signature Agreement Form bull To obtain the required information mandated under 42 CFR 455104 any

provider wishing to appoint another person access to their CHAMPS information must submit an Electronic Signature Agreement form (DCH-1401) and the Electronic Signature Agreement form cover sheet (MDHHS-5405) The two completed forms must be submitted to the MDHHS Medicaid Provider Enrollment Unit for processing MDHHS recommends the provider retain a copy of these forms for their records

bull The Electronic Signature Agreement form is also being updated to include additional language certifying the enrolled provider understands he or she is liable and bound by all information submitted on his or her behalf

7

Medicaid Coinsurance Medicare Advantage

bull Attention Nursing Facility Medicaid Fee for Service Providers

bull As part of the December 11 2015 CHAMPS system update the final phase of the Medicare Advantage Coinsurance Pricing Logic was implemented For claim dates of service 2010 and prior please refer to the Medicaid Provider Manual under General Information for Providers Chapter Section 124 Provider Returning Overpayments

bull For claim dates of service 2011 and forward MDHHS will be initiating the claim adjustment within the next few weeks Providers with further questions can contact Provider Support by phone 1-800-292-2550 or email ProviderSupportmichigangov

8

The State has been paying the wrong coinsurance amount for Medicare Advantage since 2008 Per below they will be doing a claim adjustment in the next few weeks for dates of service 2011 going forward If you have refunded the State by a check watch and make sure they do not double recover the money If they do you will have to get your check and list of people you refunded and send it to providersupportmichigangov They have stated they have fixed the pricing logic to pay it correctly going forward Watch and make sure they are paying the correct amount if not you will have to again pull the information from the coinsurance payer and send it to providersupportmichigangov

For dates of service prior to 2011 you will have to return the Money per the Medicaid manual

Medicaid providers performing self audits may discover an overpayment situation and wish to return theMedicaid overpayment to MDHHS This process should only be used when the provider is unable to claimadjust or it is not practical to claim adjust Sending in a check will not correct the underlying claim(s)data Providers must

10487071048707 Document why the money is being returned (ie provider self audit) and identify provider NPIinformation address dates of service and specialty area (ie durable medical items pharmacyphysician practice hospital etc) and include a basic information letter

10487071048707 Attach an excel spreadsheet document with the Tax ID billing NPIs and associated amounts (ifmultiple IDs exist for the entity) for the MDHHS Accounting Office to apply credit to

10487071048707 Make check payable to State of Michigan and mail to the MDHHSCashierrsquos Unit - Attn Bureauof Finance-MCU (Refer to the Directory Appendix for contact information) 9

Lawsuit DHS Changes on Caregivers

bull A recent Michigan Court of Appeals decision has played havoc on the rules surrounding payments to non-family caregivers DHS rules regarding payments to caregivers state that payments are divestment in two situations 1) prospective payments made to any caregiver (family or non-related) before care is provided and 2) payments to family caregivers absent a Medicaid qualified caregiving contract The Court of Appeals decision Jensen v Department of Human Services confuses the rules and applies the family caregiving contract requirements to all caregivers even professional caregiving agencies The result of the case is that payments to non-family caregivers may be divestment unless the Medicaid applicant has a contract with the caregiver meeting the extremely specific rules found in the Medicaid manual

10

TPL Medicaid Changebull Attention Providersbull Effective October 26 2015 the MDHHS Third Party Liability (TPL)

Update Other Insurance Now Online form will be updated You will now receive a confirmation number when you submit your request If an email address is added within the Requestor Information section once TPL completes your request you will receive an email with the confirmation number and the status of your request Please allow up to 10 business days for information to be verified and updated in the system Please check your spam or junk email folders if you do not receive the email after 10 business days

bull Providers with further questions can contact Provider Support by phone 1-800-292-2550 or email ProviderSupportmichigangov

bull httpsminotifytplstatemiustedpubliccoveragerequestsindex11

CHAMPS Member Screen

bull Attention Providersbull Effective September 25 2015 a change was made to the CHAMPS

system This change modified the provider view for the Member Eligibility Inquiry screen If a member no longer has active Medicaid the hyperlink to view ldquoCommercialOtherrdquo Third Party Liability (TPL) information is disabled Because TPL does not always maintain TPLOther Insurance information for members that do not have active Medicaid coverage this information was disabled to prevent inaccurate information from being reported

12

LOC dropping off Not Due to MI Health

bull If after 30 days the county hasnrsquot processed the 2565 that you have send via the central scan (517-346-9888) AND other methods you choose to use you can email the 2565 to ArdeneMartin

bull At the following mailbox I ask that you put the beneficiaries name in the subject line

bull MSA2565michigangov

13

Issues

bull PPA going all over the place

bull LOC 02 dropping off not related to MI Health

bull LOCD tons of money written off

bull Must check CHAMPS member screen all the time and you must check pending

14

Secure Email Information

bull The State of Michigan asked me to remind you when you are communicating with them regarding residents to not send Resident names Birthdates or Social security numbers in those emails What you send is the Medicaid ID and they can look it up Or if it is a billing issue send them the TCN and the Medicaid ID We have been in the practice of emailing DHS Ardene Martin Integrated Health and Provider Support with all the resident name and such

15

Medicaid amp Hospicebull LOC 07 Manage Medicaid Hospice included so plan would pay

provider and not switch to a LOC 16

bull LOC 02 Medicaid (Regular Medicaid) Hospice not included so switch to 16 Hospice and Hospice pays provider

bull LOC 11 Healthy Michigan is included in plan so plan would pay provider and not switch to LOC 16

bull LOC 005 amp 015 MI Health is up in the air waiting for CMS Currently Hospice is now included

bull LOC 16 is Hospice when they switch from Regular Medicaid only and Hospice pays provider

16

Medicaidbull Going forward please make sure that your Champs ID amp NPI on your member screen matches your facility CHAMPS ID

amp NPI for each resident and matches for all new admissions or new approved Medicaid going forward

bull The edit will be turned on soon to stop the payment of these claims if the CHAMPS ID and NPI do not Match your facility on the Medicaid member screen

bull Make sure you are putting the information correct on the 2565 you send in to DHS

bull 1 I attached a 2565 When you fill this out for new people make sure in box 12 a you put your NPI and 12 b you put your CHAMPS ID This will help the DHS case workers assign the person to your facility

bull 2 I would check all your residents CHAMPS member screens and make sure the NPI and CHAMPS ID are your facilities If not you will have to work with the DHS worker to fix this The DHS worker is the only one that can fix this

bull 3 We are having some issues where the DHS case workers will not change this NPI and CHAMPS ID to your facilities You have to get them to change it or you just will not get paid

bull 4 We situations where the resident is in a facility in Kent County (as an example) but the family lives in Livingston County and completes the applications in Livingston County You will have to get the DHS worker in Livingston to fix it not the local DHS worker in Kent County where your facility is

17

Medicaid Medicare Buy Inbull Based on the information from the Office of Personnel Management Federal

Employeersquos employed as of January 1 1983 are eligible for Medicare Part A(see page 5 of attached document) This was also confirmed with our Social Security liaison If the beneficiary did not retire before 1983 he can enroll in Medicare Part B and pay the premium and then he can enroll in Medicare Part A and pay that premium as well or may qualify for Medicare Buy in of Part A

bull If a beneficiary has an SSA document stating they are not eligible for Medicare as they do not have enough work credits the beneficiarybeneficiary representative needs to go to SSA and let them know that while they know they are not eligible for Medicare Part A free or reduced however they are eligible for Medicare Part B and would like to enroll Once the beneficiary enrolls in Medicare Part B (enrollment period January 1st ndash March 31 each year) and pays the premium then the beneficiary is eligible to either pay for Medicare Part A or that beneficiary may qualify for Medicare Part A buy in through Medicaid Once the beneficiary is enrolled in Medicare Part A and Medicare Part B Medicaid will begin to make payments on claims

18

Manage Medicaid Where are we

19

Healthy Michigan Residents

20

Healthy Michigan Medicaid Days

21

McLaren Health Plan

22

Manage Medicaid Plans January 1bull Region 1 ndash Upper Peninsula Health Planbull Region 2 ndash McLaren Health Plan Meridian Health Plan of Michigan Molina Healthcare of Michigan

UnitedHealthcare Community Planbull Region 3 ndash McLaren Health Plan Meridian Health Plan of Michigan Molina Healthcare of Michigan

UnitedHealthcare Community Planbull Region 4 ndash Blue Cross Complete of Michigan McLaren Health Plan Meridian Health Plan of Michigan Molina

Healthcare of Michigan Priority Health Choice UnitedHealthcare Community Planbull Region 5 ndash McLaren Health Plan Meridian Health Plan of Michigan Molina Healthcare of Michigan

UnitedHealthcare Community Planbull Region 6 ndash Blue Cross Complete of Michigan HAP Midwest Health Plan McLaren Health Plan Meridian Health

Plan of Michigan Molina Healthcare of Michigan UnitedHealthcare Community Planbull Region 7 ndash Blue Cross Complete of Michigan McLaren Health Plan Meridian Health Plan UnitedHealthcare

Community Planbull Region 8 ndash Aetna Better Health of Michigan McLaren Health Plan Meridian Health Plan of Michigan Molina

Healthcare of Michigan Priority Health Choice UnitedHealthcare Community Planbull Region 9 ndash Aetna Better Health of Michigan Blue Cross Complete of Michigan McLaren Health Plan Meridian

Health Plan of Michigan Molina Healthcare of Michigan UnitedHealthcare Community Planbull Region 10 ndash Aetna Better Health of Michigan Blue Cross Complete of Michigan Harbor Health Plan McLaren

Health Plan Meridian Health Plan of Michigan Molina Healthcare of Michigan Total Health Care UnitedHealthcare Community Plan 23

24

MI Health LinkWhere are we

25

MI Health Link 2565

bull This notification is being sent to providers of long term care services including nursing facilities county medical care facilities and hospital long term care units to provide clarification on the process involved with the submission of the Facility Admission Form (MSA-2565-C) for an individual enrolled in the MI Health Link program

bull The MI Health Link program covers the custodiallong term nursing facility service benefit When an individual who is enrolled in the MI Health Link program is admitted to a nursing facility for custodiallong term nursing services a disenrollment from the Integrated Care Organization (MI Health Link health plan) is NOT REQUIRED The Facility Admission Form (MSA-2565-C) should NOT be sent to the Michigan Department of Health and Human Services (MDHHS) Enrollment Services Section for a disenrollment to be processed

26

What are the Names

bull Started as Integrated Health

bull Then called MMP (Medicare Medicaid Program)

bull Duals (Also Known as Duals as in Dual Eligible)

bull Now called MI Health Link

bull Total confusion

27

MI Health Dual Eligible28

MI Health LOC

29

LOC Medicaidbull We have the new pilot program which started on March

1 2015 in Southwest Michigan Region 4 Counties Macomb Wayne and the UP You could see these patients they are dual eligible in the Pilot program in counties surrounding the pilot

bull MHL-LOC 005 (All other Facilities) or LOC 015 (County Care) These residents have to call Michigan Enrolls to dis-enroll toll-free at 1-800-975-7630 (TTY 1-888-263-5897) Monday-Friday from 8 AM to 7 PM Once they dis-enroll they will go to a LOC 02 you have to do a new LOCD

30

Medicaid Redetermination and MHL Enrollmentbull At the time of re-determination for Medicaid financial eligibility the MI

Health Link (MHL) program will not be sending beneficiaries information about this program Beneficiaries who previously opted out will not be passively enrolled according to an email from the MHL staff The MHL staff wrote

bull ldquoThere is currently no MI Health Link enrollment letter sent to beneficiaries when eligibility is re-determined A person who becomes eligible for MI Health Link enrollment may opt-in at any time

bull When Medicaid re-determination takes place the beneficiary remains in the same ICO unless that beneficiary lost Medicaid coverage If the enrollee loses Medicaid coverage and later regains it they are not passively enrolled into MI Health Link The beneficiary may choose to opt back in to the program at that time if desiredrdquo

bull MHL staff did state that about 1500 beneficiaries will be passively enrolled effective January 1 2016 These specific individuals were given normal notice of 60 and 30 days in which to opt-in or opt-out if they so chose No other large scale passive enrollment is scheduled according to the MHL staff 31

MI Health Link Portals

bull Meridian Health Planbull httpwwwmhplancommibull Amerihealthbull httpwwwamerihealthcaritasvipcarepluscomproviderself-service-

toolsindexaspxbull AetnaCoventrybull httpwwwaetnabetterhealthcomMichiganprovidersportalbull Molinabull httpwwwmolinahealthcarecommembersmien-usmemPageshomeaspxbull HAPMidwestbull httpswwwmidwesthealthplancomLoginaspxbull FidelisCentenebull wwwfidelissccommmp 32

MI Health Authorizationsbull We need to watch these authorization that the plans are giving us for the MI

Health program Some plans are assigning a diagnosis for residents in their prior authorizations They are assigning diagnosis that the residents do not even have You need to make sure these are correct diagnosis and if not you need to work with the case managers of the plans to fix the issue The authorization numbers do change

bull Make sure that any resident that is in a MI Health plan that you have a prior authorization All plans are giving different periods authorizing the residents stay in the facility You need to set up a system to make sure you always have a authorization for the period of time you are rendering the service Here is an example of time frame of authorizations

bull Meridian is authorizing 12 monthsbull Aetna is authorizing 3 monthsbull Molina is authorizing 6 monthsbull The authorization numbers need to go on your claims to the payer You need to

put the authorizations in your software and track the dates

33

MI Health Issuesbull We are seeing some issues with MI Health where the resident does not have the correct LOC or it shows

up correct on CHAMPS but ancillary providers such as Dentist and such cannot see it I think we still have some issues with the information crossing between Bridges DHS system CMS and CHAMPS It in return is creating some access of care issues If it is a true LOC issues Facilities with LOC issues need to submit the Medicaid ID numbers to the MSA-MHL-EnrollmentMichigangov box with the subject line Nursing home LOC Issue so they may work to resolve the issues

bull If it becomes an access to care issue email the information to INTEGRATEDCAREmichigangov Remember in these emails only send the Medicaid ID and explain the situation The State will work with the plans to try to fix the process or improve the process

bull We are also seeing with new admission with LOC 015 or 005 that the plans are stating they have 14 days to authorize admission These are resident in the emergency room and possibly be admitted to you for Rehab The hospital will not keep the resident in ER for 14 days and you cannot admit the resident until you have a prior authorization I would recommend when you are told this by the plan that you need to ask to speak to a manager We will have to work through this

bull Ancillary Provider You need to work with your ancillary providers such as Lab Pharmacy X-Ray Physician and such to get the to be credentialed with the plans We are hearing that some of the pharmacies are not participating with the plans this will create issues for you so I would continue to ask these groups to participate

34

LOC 02 dropping MI Health Issuesbull The passive enrollments have occurred in Macomb amp Wayne for

Medicaid dual eligible We are having the same issue we did as in the Southwest MI amp UP with the passive enrollments I am starting to hear from facilities who are checking there CHAMPS member screens that those residents that have opted out (some residents not all) have lost there 02 Make sure you are checking your CHAMPS member screen both for those that were passively enrolled and those that might have lost there 02 Medicaid that opted out

bull Facilities with LOC issues need to submit the Medicaid ID numbers to the (Only MI Health)MSA-MHL-Enrollmentmichigangov box with the subject line Nursing home LOC Issue so they may work to resolve the issues

35

PPA Offset

bull There are no co-pays deductibles or premiums in MI Health Link so there should be no need to offset the PPA with code 25 MI Health Link enrollees can continue to offset their PPA for non-program covered medical expenses (like Vision-Code 27 Dental-Code 28 and Hearing-Code 26) and use the appropriate codes to offset the PPA when billing the health plan for nursing facility services

bull Resident pay PPA when MedicareMedicaid coinsurance

36

LOCDbull Nursing Facility Level of Care Determination (NFLOCD)

bull The MI Health Link health plan will be responsible for conducting the Michigan Medicaid NFLOCD tool for enrollees seeking admission to a nursing facility For existing residents at the time of enrollment the existing NFLOCD will be adopted for capitation payment purposes The health plan will complete a new NFLCOD tool within the first 90 days of enrollment If a nursing facility resident is disenrolled from MI Health Link the nursing facility will be responsible for conducting a new NFLOCD tool in accordance with published Medicaid policy

37

MI Health Issues-New

bull INTEGRATEDCAREmichigangov

bull Email with Insurance Plan issues Case Manager Issues

38

ACOWhat are they

39

Families Receiving Letters for ACO

40

ACO What is It

bull Whats an ACObull Accountable Care Organizations (ACOs) are groups of doctors hospitals

and other health care providers who come together voluntarily to give coordinated high quality care to their Medicare patients

bull The goal of coordinated care is to ensure that patients especially the chronically ill get the right care at the right time while avoiding

unnecessary duplication of services and preventing medical errorsbull When an ACO succeeds both in delivering high-quality care and

spending health care dollars more wisely it will share in the savings it achieves for the Medicare program

41

Payroll Based JournalMandatory on July 1 2016Internet Explorer Version

Internet Explorer v 10 and v 11 will need to operate in compatibility mode

42

43

If you submit data manually should you also submit it through the XML

bull Now you have three options

bull Submit Manually only

bull Submit through the XML only

bull You are able to submit manually and using the XML

44

45

Staffing Submission Frequently Asked Questions

bull ldquoWho are direct care staffrdquo (Who do we submit data for)bull Submission of data for contract staffbull Medical directors and consultantsbull Staff switching roles or tasks throughout the daybull Hours paid vs hours worked ndash Must be verifiablebull Public postingQuality MeasuresFive Starbull Enforcementbull Voluntary submission risks (noneSo register now)

CMS defines

bull 37 job title codes that are required to match employees to the number of hours each direct care function was performed It is important to work with your teams to define the workers that contribute to each job type and how those daily worked hours are recorded and converted to a PBJ submission

bull The PBJ does include some more specific job descriptions than the 671 For example the PBJ system includes job descriptions for RNs with administrative duties and LPNs with administrative duties versus the 671rsquos more general ldquoNurses with Administrative Duties

Page 46

47

PBJ Medical Director Rolebull Physician Leadership

bull Help the facility ensure that patients have appropriate physician coverage and ensure the provision of physician and health care practitioner services and

bull Help the facility develop a process for reviewing physician and health care practitioner credentials

bull Provide specific guidance for physician performance expectations

bull Help the facility ensure that a system is in place for monitoring the performance of health care practitioners and

bull Facilitate feedback to physicians and other health care practitioners on performance and practices

bull Patient Care - Clinical Leadership

bull Participate in administrative decision-making and the development of policies and procedures related to patient care

bull Help develop approve and implement specific clinical practices for the facility to incorporate into its care-related policies and procedures including areas required by laws and regulations

bull Develop procedures and guidance for facility staff regarding contacting practitioners including information gathering and presentation change in condition assessment and when to contact the medical director

bull Review consider andor act upon consultant recommendations as appropriate that affect the facilitys resident care policies and procedures or the care of an individual resident

bull Review respond to and participate in federal state local and other external surveys and inspections and

bull Help review policies and procedures regarding the adequate protection of patients rights advance care planning and other ethical issues48

PBJ Medical Director Rolebull Quality of Care

bull Help the facility establish systems and methods for reviewing the quality and appropriateness of clinical care and other health-related services and provide appropriate feedback and

bull Participate in the facilitys quality improvement process

bull Advise on infection control issues and approve specific infection control policies to be incorporated into facility policies and procedures

bull Help the facility provide a safe and caring environment

bull Help promote employee health and safety and

bull Assist in the development and implementation of employee health policies and programs

bull Education Information and Communication

bull Promote a learning culture within the facility by educating informing and communicating

bull Provide information to help the facility provide care consistent with current standards of practice (defined as approaches to care procedures techniques and treatments that are based on research and or expert consensus and that are contained in current manuals textbooks and or publications or that are accepted adopted or promulgated by recognized organizations or national bodies)

bull Help the facility develop medical information and communication systems with staff patients and families and others

bull Represent the facility to the professional and lay community on medical and patient care issues

bull Maintain knowledge of the changing social regulatory political and economic factors that affect medical and health services of long term care patients and

bull Help establish appropriate relationships with other health care organizations

49

Dietician

bull When the dietary or food services supervisor is other than a registered dietitian the supervisor shall receive routine consultation and technical assistance from a registered dietitian (RD) Consultation time shall not be less than 4 hours every 60 days Additional consultation time may be needed based on the total number of patients incidence of nutrition-related health problems and food service management needs of the facility

50

Pharmacy Consultant

bull At least once per month a licensed pharmacist must perform a drug regimen review (DRR) for each resident The pharmacist must report any irregularities to the attending physician or director of nursing Furthermore these reports must be acted upon

51

What are the names for the Medicare Numberbull OSCAR -Online Survey Certification and Reporting

bull PTAN-PTAN number is assigned by Medicare to authenticate the provider when using the local Medicare Administrative Contractorrsquos (MAC) self-help tools like the IVR internet portal on-line application status etc Provider Transactions Access Number

bull CCN- CMS Certification Number

bull Medicare Number- example 23-

bull All of the above mean the same thing

52

QTSO

bull Once you are logged in the QTSO site bull You will have a state login to the site to access the various site specific

to your facilitybull Installing you will need administrator rights to your network

53

Medicare UpdateWhat are we seeing

54

CMS Final Rule On Returning Credits

httpswwwfederalregistergovarticles201602122016-02789medicare-program-reporting-and-returning-of-overpayments

55

Over Payment Rule

bull Medicare payments for non covered services

bull Medicare payments in excess of the allowable amount for an identified covered service

bull Errors and non reimbursable expenditures in cost reportsbull Duplicate payment

bull Receipt of Medicare payments when another payor had the primary responsibility for payment

56

Questions to MAC

bull Does the Medicare credit balance report change with this overpayment rule

bull No Medicare Credit Balances are still required at the end of each quarter

bull Will that still be the communication to let CMS or the MAC know that we have received an overpayment

bull Submission of Medicare Credit Balance is one form of communicating overpayments to CMS Other methods include submitting a voluntary refund with required claim information or the submission of a standard overpayment form

57

Questions to MAC

bull Will the MAC still deduct from a future RAbull If the recovery of the overpayment includes adjusting a claim then

the overpayment would be netted against future claims payments and reflected on the RA

bull Or will that process change with this new rulebull Process will remain the samebull Will NGS send communication out on thisbull Yes NGS will communicate this once the final rule is communicated

to the MACs by CMS However this could change depending on final CMS instructions

58

Final Rule on Returning Credits

bull Providers will want to immediately update their current policies governing overpayments in order to comply with this new rule which will take effect on March 14 2016

bull Providers and suppliers are required to use reasonable diligence to investigate credible information regarding overpayments through both proactive compliance efforts and reactive investigations

bull If an overpayment is identified then it must be repaid within 60 days An overpayment is identified when a person has or should have through the exercise of reasonable diligence determined that the person received an overpayment and quantified the amount

bull Providers and suppliers have a maximum of 8 months to report and return overpayments ndash up to 6 months to investigate and quantify the overpayment (ie to identify it) and up to 60 days to report and return the overpayment

59

Final Rule on Returning Credits

bull Providers and suppliers are required to report and return all overpayments within a 6-year lookback period

bull The cause and amount of the overpayment is irrelevant for the determination eg it was due to a mistake it was someone elsersquos fault it is a minor amount An overpayment is an overpayment and must be returned

bull Providers and suppliers must make their own determination to which entity to report and return the overpayment ie to the Medicare contractor or using the OIG Self Disclosure Protocol or the CMS Self Referral Disclosure Protocol

60

Final Rule on Returning Credits

bull Providers and suppliers may use the claims adjustment credit balance self-reported refund process or another appropriate process to report and return overpayments At this time there is no standard refund form to use

bull Failure to report and return an overpayment could subject the provider or supplier to False Claims Act liability Civil Monetary Penalties Law liability and exclusion from federal health care programs

61

P S amp R-Accountants will be asking for this information

The location you login into has changed it is now on EIDM EIDM is the acronym for CMS Enterprise Identity Management system which includes Identity Verification Access Management Authorization Assistance Workflow Tools and Identity Lifecycle Management functions

httpswwwcmsgovResearch-Statistics-Data-and-SystemsCMS-Information-TechnologyIACSCMS-Applications-Loginhtml

Go down the page and click on the PSampRSTARThis will take you to the login pagewill look the same as the old P S amp R didChanges Affecting PSampR System Access (Please Read) (posted 01292015)(Updated 5262015)is changingThe system which controls your PSampR user ID (currently IACS)The new system is referred to as EIDMThis will result in a different way to create new accounts or change passwords to existing accountsIf you already have an account in EIDM you may have to use that account for accessing PSampR after the transitionWhen is the change effectiveJune 13 2015What is staying the sameThe internet address for accessing PSampR remains the sameThe PSampR systemfunctionality is NOT changing 62

Medicare Advantage Payorsbull Medicare Advantage payors are pullingdenying payments on admissions if the patient was readmitted within 30 days after discharge The

client believes that the payors systematically denying payments for all readmissions within 30 days They believe this practice denies them due process to address whether the readmissions were justified and not due to a premature discharge of patient The payors seem to want to act like a QIO without having the same accountabilities of the QIO related to determinations of non-payment

bull Heres the QIO process under section 4240 of the QIO Manualbull 4240 - Readmission Review - (Rev 2 07-11-03)bull Readmission review involves admissions to an acute general short-term hospital occurring less than 31 calendar days from the date of

discharge from the same or another acute general short-term hospital (see sect1154(a)(13) and 42 CFR 47671(a)(8)(ii)) Neither the day of discharge nor the day of admission is counted when determining whether a readmission has occurred

bull A Medical Review Proceduresbull Obtain the appropriate medical records for the initial admission and readmission Perform case review on both stays Analyze the cases

specifically to determine whether the patient was prematurely discharged from the first confinement thus causing readmission Perform an analysis of the stay at the first hospital to determine the cause(s) and extent of any problem(s) (eg incomplete or substandard treatment) Consider the information available to the attending physician who discharged the patient from the first confinement Do not base a determination of a premature discharge on information that the physician or provider could not have known or events that could not have been anticipated at the time of discharge

bull Review both the initial admission and the readmission at the same time unless one of them has previously been reviewed In these cases use at a minimum the PRAF case summary of the other admission in addition to the medical record of the case under review

bull C Denialsbull Deny readmissions under the following circumstancesbull If the readmission was medically unnecessarybull If the readmission resulted from a premature discharge from the same hospital orbull If the readmission was a result of circumvention of PPS by the same hospital (see sect4255)bull With the QIO process there is an appeal within the QIO here the hospital is getting no opportunity to challenge the denials

63

Medicare Provider Enrollment Feebull Provider Enrollment Application Fee Amount for CY 2016bull On December 3 CMS issued a notice Provider Enrollment Application

Fee Amount for CY 2016 [CMSndash6066ndashN] Effective January 1 2016 the CY 2016 application fee is $554 for institutional providers that are

bull Initially enrolling in the Medicare or Medicaid program or the Childrens Health Insurance Program (CHIP)

bull Revalidating their Medicare Medicaid or CHIP enrollmentbull Adding a new Medicare practice locationbull This fee is required with any enrollment application submitted from

January 1 through December 31 2016

64

Medicare MAC-Higlas

bull Effective 142016 CMS has implemented a change to begin netting (offsetting) provider money across workloads within a single organization What this means is that any related providers conducting business in two different workloads (example New York and Maine) will have their money applied to any account receivables (AR) with a remaining balance owed to Medicare within both workloads For example Provider ABC is located in New York and is scheduled to receive a payment of $1000 on todays remittance advice Provider XYZ is related to provider ABC but is located in Maine and has ARs with a balance owed of $200 Provider ABCs $1000 payment will have the $200 applied against provider XYZs ARs resulting in a net payment of $800 This will be reflected on the remittance advice by the same PLB code as seen today for offsets for the $200

65

Two Midnight RuleChange January 1 2016 httpswwwcmsgovMedicareMedicare-Fee-for-Service-PaymentHospitalOutpatientPPSHospital-Outpatient-Regulations-and-Notices-ItemsCMS-1633-FChtml

66

Two Midnight Rulebull However effective January 1 2016 CMS will allow exceptions to the

Two-Midnight Benchmark to be determined on a case-by-case basis by the physician responsible for the care of the beneficiary subject to medical review Said differently Part A payment may be appropriate in some circumstances even though there is no expectation by the physician (or qualified ordering practitioner) of a two-midnight stay and one of the two pre-existing categorical exceptions (CMS ldquoinpatient onlyrdquo list and newly initiated mechanical ventilation) does not apply CMS has indicated that this change to the Two Midnight Rule is in response to stakeholder concern and CMSrsquos continued efforts to develop the most appropriate standard for determining Medicare Part A payment

67

Two Midnight Rulebull A new 42 CFR sect4123(a) provides that a patient is considered an

inpatient of a hospitalhellipif formally admitted as an inpatient pursuant to an order for inpatient admission by a physician or other qualified practitionerhellip The physician orders inpatient status when he or she expects the patient to require a stay that crosses at least 2 midnights[10] Stays expected to be shorter than at least two midnights are generally inappropriate for inpatient admission and inpatient payment under Medicare Part A unless the surgical procedure is specified by Medicare as inpatient only under sect41922(n)[11] The physicians expectationhellipshould be based on such complex medical factors as patient history and comorbidities the severity of signs and symptoms current medical needs and the risk of an adverse event[12] The physician order is part of physician certification of the medical necessity of hospital inpatient serviceshellip[13]

68

InPatient Vs Observation Conthellip

bull Physician certification which begins with an order for inpatient admission requires the physician to certify the reasons for the hospitalization the estimated time the patient will remain in the hospital and plans for post-hospital care if appropriate[14] The certification must be completed signed and documented in the medical record prior to discharge[15]

bull A physicians admission order has no presumptive weight and both the admission order and the physician certification will be evaluated in the context of the evidence in the medical record[16] CMS intends to provide additional information about what evidence in the medical record means in future instructions and manual revisions[17]

69

Two Midnight Rulebull Although the new case-by-case exception appears to be inherently

subjective to a certain extent CMS states that the following factors (among others) would be relevant to determining whether a patient requires inpatient admission under the expanded policy

bull The severity of the signs and symptoms exhibited by the patient bull The medical predictability of something adverse happening to the patient

and bull The need for diagnostic studies that appropriately are outpatient services

(that is their performance does not ordinarily require the patient to remain at the hospital for 24 hours or more)

bull CMS also notes that an inpatient admission (and Part A payment) should be ldquorare and unusualrdquo for minor surgical procedures or other treatment that is expected to keep the patient in the hospital ldquofor only a few hoursrdquo or for a period of time that ldquodoes not span at least overnightrdquo (thus a subset of stays not meeting the Two Midnight Benchmark) CMS indicates that such cases will be prioritized for medical review

70

Health Data Insights amp Medicare Plus Blue

RAC (Retrospective Audits)

71

HDI Health Data amp Med Plus Blue

bull httpwwwhealthdatainsightscombull Blue Cross Medicare Advantage Auditsbull Facilities seeing 10 to 15 requests for Medical Recordsbull In January amp Feburarybull Selected Health Data Insights because they were a premier Audit

Vendor for CMS Recovery Audit Contractor (RAC) demonstration Project They are a audit vendor for Humana

bull Providers not sending Medical Record will get technical denial and lose payments

72

Health Data InSight

bull In 2010 they began the Hospital Reviewbull Medicare Advantage encounter datandashCMS oversight of data integrity OIG

2016bull We will review CMSs oversight of MA encounter data validation and assess

the extent to which CMSrsquos Integrated Data Repository contains timely valid and complete MA encounter data In 2012 CMS began collecting from MA organizations a more comprehensive set of encounter data reflecting the items and services provided to MA plan enrollees Prior CMS and OIG audits have indicated vulnerabilities in the accuracy of data reporting by MA organizations Realizing the potential benefits of the MA encounter data for payment and program integrity oversight is contingent upon the datarsquos completeness validity and timeliness (OEI 03-15-00060 expected issue date FY 2017)

73

Pepper Reports

bull httpswwwpepperresourcesorg

bull Program for Evaluating Payment Patterns Electronic Report ( PEPPER)

bull Annually on or about April 18 2016 will be released

bull Pepper Portal httpssecurefiletmforg

74

CGI Technologies and Solutions Inc httpracbcgicomContactInfoaspxst=1

bull Indiana bull Michiganbull Minnesotabull Illinoisbull Kentuckybull Ohiobull Wisconsin CGI Technologies and Solutions Incbull For general and administrative questions regarding client service outreach

quality assurance or project-specific issues contactbull 1877316RACB (7222)bull Email racbcgicom Tamara Tate Tamaratatecmshhsgovbull 4107861288

75

CGI Federal RAC

bull CGI Federal RAC Region Bbull Email racbcgicombull Phone 1-877-316-RACB (7222)bull Mailing Addressbull Send medical records as followsbull Medical records for Indiana Illinois Kentucky Michigan Ohio Wisconsin

Minnesota DME and Home Health CGI Federal Inc Attn RACB Imaging Dept 1001 Lakeside Ave Suite 800 Cleveland OH 44114

bull If submitting paper records please send medical records as follows For Therapy Reviews CGI Federal Inc Attn RACB Imaging 1001 Lakeside Avenue Suite 800 Cleveland OH 44114

76

How to survive RAC Audit

bull National health expenditures totaled $1679 Billion in 2003 bull National health expenditures were 153 of GROSS Domestic Product

(GDP) in 2003 bull Health care cost increasing at +9 per year bull Doomsday predictions of Medicare running out bull Congressional Action

77

RAC Audits

bull Medicare Modernization Act (MMA) of 2003Mandated a three year audit demonstration project 2005-2008

bull Appoint audit contractors to review Medicare billings for proper coding DRG assignment and medical necessity

bull Audits will apply to all health care providers (hospitals physicians homecare dme etc)

bull Audit contractors to be paid on a contingency basis a percentage of overpayments recovered

78

How Did we get here

bull Overpayments collected due to errors in Medically Unnecessary Services ndash 40

bull Incorrectly Coded ndash 35

bull Other ndash 17

bull NoInsufficient Documentation ndash 8

79

Where are we now

bull All RACrsquos completed required provider outreachAccess to Medicare billing data base given to all RAC RAC review methodology

bull Automated Review-Black amp White Issues (current) bull DRG Validation-complex review (current) bull Complex Review for coding errors (current) bull DME Medical Necessity Reviews ndashcomplex review (calendar year

2010) bull Medical Necessity Reviews-complex review (calendar year 2010)

80

RAC Reviews

bull Responsibilities of the Team Leader bull Must learn each insurance provider participating in a RAC or RAC type

program bull What are their operating rulesbull What is their appeal process Time limits

May be different process for each insurance provider bull Develop a response team

Identify who does what when why and alternate bull individual

Build and develop a manual process Review of computerized system

81

Priority Health SCIO Health Analytics

bull httpswwwsciohealthanalyticscomcore-capabilitiespayment-integrityfacility-auditsskilled-nursing-facility-audits

bull Claims for Medicare members treated at Skilled Nursing Facilities are reimbursed based on the patientsrsquo RUG (Resource Utilization Group) score which is determined using the Minimum Data Set (MDS) Using SCIOs robust analytics claims andor providers that merit review are selected for audit SCIOs auditors conduct a detailed review of the complete medical record and associated MDS to determine if the billed RUG score is valid In the event the review determines that an incorrect RUG score was billed SCIOreg provides the valid score reports the reason the change was necessary and calculates the resulting overpayment

82

+ Cheer

Onward and Upward she shall prevail We are here to care for the residents and provide a wonderful

service

13 83

84

References

bull Priority Healthbull Blue Crossbull Medicaidbull Medicare

85

  • Medicare Mange Care amp Medicaid Changes in the New World We Live In
  • Medicaid
  • NEW Medicaid Change MIlogin
  • Blueprint for Health Innovation MI
  • Provider Enrollment Electronic Signature Form Submission Process MSA 15-54
  • Provider Enrollment Electronic Signature Form Submission Process
  • Provider Enrollment Domain Administrator
  • Medicaid Coinsurance Medicare Advantage
  • Slide Number 9
  • Lawsuit DHS Changes on Caregivers
  • TPL Medicaid Change
  • CHAMPS Member Screen
  • LOC dropping off Not Due to MI Health
  • Issues
  • Secure Email Information
  • Medicaid amp Hospice
  • Medicaid
  • Medicaid Medicare Buy In
  • Manage Medicaid
  • Healthy Michigan Residents
  • Healthy Michigan Medicaid Days
  • McLaren Health Plan
  • Manage Medicaid Plans January 1
  • Slide Number 24
  • MI Health Link
  • MI Health Link 2565
  • What are the Names
  • MI Health Dual Eligible
  • MI Health LOC
  • LOC Medicaid
  • Medicaid Redetermination and MHL Enrollment
  • MI Health Link Portals
  • MI Health Authorizations
  • MI Health Issues
  • LOC 02 dropping MI Health Issues
  • PPA Offset
  • LOCD
  • MI Health Issues-New
  • ACO
  • Families Receiving Letters for ACO
  • ACO What is It
  • Payroll Based Journal
  • Slide Number 43
  • If you submit data manually should you also submit it through the XML
  • Staffing Submission Frequently Asked Questions
  • CMS defines
  • Slide Number 47
  • PBJ Medical Director Role
  • PBJ Medical Director Role
  • Dietician
  • Pharmacy Consultant
  • What are the names for the Medicare Number
  • QTSO
  • Medicare Update
  • CMS Final Rule On Returning Credits
  • Over Payment Rule
  • Questions to MAC
  • Questions to MAC
  • Final Rule on Returning Credits
  • Final Rule on Returning Credits
  • Final Rule on Returning Credits
  • Slide Number 62
  • Medicare Advantage Payors
  • Medicare Provider Enrollment Fee
  • Medicare MAC-Higlas
  • Two Midnight Rule
  • Two Midnight Rule
  • Two Midnight Rule
  • InPatient Vs Observation Conthellip
  • Two Midnight Rule
  • Health Data Insights amp Medicare Plus Blue
  • HDI Health Data amp Med Plus Blue
  • Health Data InSight
  • Pepper Reports
  • CGI Technologies and Solutions Inc httpracbcgicomContactInfoaspxst=1
  • CGI Federal RAC
  • How to survive RAC Audit
  • RAC Audits
  • How Did we get here
  • Where are we now
  • RAC Reviews
  • Priority Health SCIO Health Analytics
  • Cheer
  • References
Page 5: Medicare, Mange Care & Medicaid Changes in the New World we live in

Provider Enrollment Electronic Signature Form Submission Process

MSA 15-54Medicaid

5

Provider Enrollment Electronic Signature Form Submission Process

bull In compliance with 42 CFR 455104 the Michigan Department of Health and Human Services (MDHHS) is establishing a new process associated with Medicaid provider screening and enrollment requirements related to program integrity for the Medicaid Fee-for-Service (FFS) program Providers were previously notified of the changes required under 42 CFR 455105 in bulletin MSA 12-55 This bulletin describes the process for assigning additional domain access rights to the Community Health Automated Medicaid Processing System (CHAMPS) Provider Enrollment (PE) subsystem on a providers behalf

bull These forms do not need to be completed if no new domain access rights are needed

bull Issued 12302015bull Effective on 02012016

6

Provider Enrollment Domain Administrator

bull Electronic Signature Agreement Form bull To obtain the required information mandated under 42 CFR 455104 any

provider wishing to appoint another person access to their CHAMPS information must submit an Electronic Signature Agreement form (DCH-1401) and the Electronic Signature Agreement form cover sheet (MDHHS-5405) The two completed forms must be submitted to the MDHHS Medicaid Provider Enrollment Unit for processing MDHHS recommends the provider retain a copy of these forms for their records

bull The Electronic Signature Agreement form is also being updated to include additional language certifying the enrolled provider understands he or she is liable and bound by all information submitted on his or her behalf

7

Medicaid Coinsurance Medicare Advantage

bull Attention Nursing Facility Medicaid Fee for Service Providers

bull As part of the December 11 2015 CHAMPS system update the final phase of the Medicare Advantage Coinsurance Pricing Logic was implemented For claim dates of service 2010 and prior please refer to the Medicaid Provider Manual under General Information for Providers Chapter Section 124 Provider Returning Overpayments

bull For claim dates of service 2011 and forward MDHHS will be initiating the claim adjustment within the next few weeks Providers with further questions can contact Provider Support by phone 1-800-292-2550 or email ProviderSupportmichigangov

8

The State has been paying the wrong coinsurance amount for Medicare Advantage since 2008 Per below they will be doing a claim adjustment in the next few weeks for dates of service 2011 going forward If you have refunded the State by a check watch and make sure they do not double recover the money If they do you will have to get your check and list of people you refunded and send it to providersupportmichigangov They have stated they have fixed the pricing logic to pay it correctly going forward Watch and make sure they are paying the correct amount if not you will have to again pull the information from the coinsurance payer and send it to providersupportmichigangov

For dates of service prior to 2011 you will have to return the Money per the Medicaid manual

Medicaid providers performing self audits may discover an overpayment situation and wish to return theMedicaid overpayment to MDHHS This process should only be used when the provider is unable to claimadjust or it is not practical to claim adjust Sending in a check will not correct the underlying claim(s)data Providers must

10487071048707 Document why the money is being returned (ie provider self audit) and identify provider NPIinformation address dates of service and specialty area (ie durable medical items pharmacyphysician practice hospital etc) and include a basic information letter

10487071048707 Attach an excel spreadsheet document with the Tax ID billing NPIs and associated amounts (ifmultiple IDs exist for the entity) for the MDHHS Accounting Office to apply credit to

10487071048707 Make check payable to State of Michigan and mail to the MDHHSCashierrsquos Unit - Attn Bureauof Finance-MCU (Refer to the Directory Appendix for contact information) 9

Lawsuit DHS Changes on Caregivers

bull A recent Michigan Court of Appeals decision has played havoc on the rules surrounding payments to non-family caregivers DHS rules regarding payments to caregivers state that payments are divestment in two situations 1) prospective payments made to any caregiver (family or non-related) before care is provided and 2) payments to family caregivers absent a Medicaid qualified caregiving contract The Court of Appeals decision Jensen v Department of Human Services confuses the rules and applies the family caregiving contract requirements to all caregivers even professional caregiving agencies The result of the case is that payments to non-family caregivers may be divestment unless the Medicaid applicant has a contract with the caregiver meeting the extremely specific rules found in the Medicaid manual

10

TPL Medicaid Changebull Attention Providersbull Effective October 26 2015 the MDHHS Third Party Liability (TPL)

Update Other Insurance Now Online form will be updated You will now receive a confirmation number when you submit your request If an email address is added within the Requestor Information section once TPL completes your request you will receive an email with the confirmation number and the status of your request Please allow up to 10 business days for information to be verified and updated in the system Please check your spam or junk email folders if you do not receive the email after 10 business days

bull Providers with further questions can contact Provider Support by phone 1-800-292-2550 or email ProviderSupportmichigangov

bull httpsminotifytplstatemiustedpubliccoveragerequestsindex11

CHAMPS Member Screen

bull Attention Providersbull Effective September 25 2015 a change was made to the CHAMPS

system This change modified the provider view for the Member Eligibility Inquiry screen If a member no longer has active Medicaid the hyperlink to view ldquoCommercialOtherrdquo Third Party Liability (TPL) information is disabled Because TPL does not always maintain TPLOther Insurance information for members that do not have active Medicaid coverage this information was disabled to prevent inaccurate information from being reported

12

LOC dropping off Not Due to MI Health

bull If after 30 days the county hasnrsquot processed the 2565 that you have send via the central scan (517-346-9888) AND other methods you choose to use you can email the 2565 to ArdeneMartin

bull At the following mailbox I ask that you put the beneficiaries name in the subject line

bull MSA2565michigangov

13

Issues

bull PPA going all over the place

bull LOC 02 dropping off not related to MI Health

bull LOCD tons of money written off

bull Must check CHAMPS member screen all the time and you must check pending

14

Secure Email Information

bull The State of Michigan asked me to remind you when you are communicating with them regarding residents to not send Resident names Birthdates or Social security numbers in those emails What you send is the Medicaid ID and they can look it up Or if it is a billing issue send them the TCN and the Medicaid ID We have been in the practice of emailing DHS Ardene Martin Integrated Health and Provider Support with all the resident name and such

15

Medicaid amp Hospicebull LOC 07 Manage Medicaid Hospice included so plan would pay

provider and not switch to a LOC 16

bull LOC 02 Medicaid (Regular Medicaid) Hospice not included so switch to 16 Hospice and Hospice pays provider

bull LOC 11 Healthy Michigan is included in plan so plan would pay provider and not switch to LOC 16

bull LOC 005 amp 015 MI Health is up in the air waiting for CMS Currently Hospice is now included

bull LOC 16 is Hospice when they switch from Regular Medicaid only and Hospice pays provider

16

Medicaidbull Going forward please make sure that your Champs ID amp NPI on your member screen matches your facility CHAMPS ID

amp NPI for each resident and matches for all new admissions or new approved Medicaid going forward

bull The edit will be turned on soon to stop the payment of these claims if the CHAMPS ID and NPI do not Match your facility on the Medicaid member screen

bull Make sure you are putting the information correct on the 2565 you send in to DHS

bull 1 I attached a 2565 When you fill this out for new people make sure in box 12 a you put your NPI and 12 b you put your CHAMPS ID This will help the DHS case workers assign the person to your facility

bull 2 I would check all your residents CHAMPS member screens and make sure the NPI and CHAMPS ID are your facilities If not you will have to work with the DHS worker to fix this The DHS worker is the only one that can fix this

bull 3 We are having some issues where the DHS case workers will not change this NPI and CHAMPS ID to your facilities You have to get them to change it or you just will not get paid

bull 4 We situations where the resident is in a facility in Kent County (as an example) but the family lives in Livingston County and completes the applications in Livingston County You will have to get the DHS worker in Livingston to fix it not the local DHS worker in Kent County where your facility is

17

Medicaid Medicare Buy Inbull Based on the information from the Office of Personnel Management Federal

Employeersquos employed as of January 1 1983 are eligible for Medicare Part A(see page 5 of attached document) This was also confirmed with our Social Security liaison If the beneficiary did not retire before 1983 he can enroll in Medicare Part B and pay the premium and then he can enroll in Medicare Part A and pay that premium as well or may qualify for Medicare Buy in of Part A

bull If a beneficiary has an SSA document stating they are not eligible for Medicare as they do not have enough work credits the beneficiarybeneficiary representative needs to go to SSA and let them know that while they know they are not eligible for Medicare Part A free or reduced however they are eligible for Medicare Part B and would like to enroll Once the beneficiary enrolls in Medicare Part B (enrollment period January 1st ndash March 31 each year) and pays the premium then the beneficiary is eligible to either pay for Medicare Part A or that beneficiary may qualify for Medicare Part A buy in through Medicaid Once the beneficiary is enrolled in Medicare Part A and Medicare Part B Medicaid will begin to make payments on claims

18

Manage Medicaid Where are we

19

Healthy Michigan Residents

20

Healthy Michigan Medicaid Days

21

McLaren Health Plan

22

Manage Medicaid Plans January 1bull Region 1 ndash Upper Peninsula Health Planbull Region 2 ndash McLaren Health Plan Meridian Health Plan of Michigan Molina Healthcare of Michigan

UnitedHealthcare Community Planbull Region 3 ndash McLaren Health Plan Meridian Health Plan of Michigan Molina Healthcare of Michigan

UnitedHealthcare Community Planbull Region 4 ndash Blue Cross Complete of Michigan McLaren Health Plan Meridian Health Plan of Michigan Molina

Healthcare of Michigan Priority Health Choice UnitedHealthcare Community Planbull Region 5 ndash McLaren Health Plan Meridian Health Plan of Michigan Molina Healthcare of Michigan

UnitedHealthcare Community Planbull Region 6 ndash Blue Cross Complete of Michigan HAP Midwest Health Plan McLaren Health Plan Meridian Health

Plan of Michigan Molina Healthcare of Michigan UnitedHealthcare Community Planbull Region 7 ndash Blue Cross Complete of Michigan McLaren Health Plan Meridian Health Plan UnitedHealthcare

Community Planbull Region 8 ndash Aetna Better Health of Michigan McLaren Health Plan Meridian Health Plan of Michigan Molina

Healthcare of Michigan Priority Health Choice UnitedHealthcare Community Planbull Region 9 ndash Aetna Better Health of Michigan Blue Cross Complete of Michigan McLaren Health Plan Meridian

Health Plan of Michigan Molina Healthcare of Michigan UnitedHealthcare Community Planbull Region 10 ndash Aetna Better Health of Michigan Blue Cross Complete of Michigan Harbor Health Plan McLaren

Health Plan Meridian Health Plan of Michigan Molina Healthcare of Michigan Total Health Care UnitedHealthcare Community Plan 23

24

MI Health LinkWhere are we

25

MI Health Link 2565

bull This notification is being sent to providers of long term care services including nursing facilities county medical care facilities and hospital long term care units to provide clarification on the process involved with the submission of the Facility Admission Form (MSA-2565-C) for an individual enrolled in the MI Health Link program

bull The MI Health Link program covers the custodiallong term nursing facility service benefit When an individual who is enrolled in the MI Health Link program is admitted to a nursing facility for custodiallong term nursing services a disenrollment from the Integrated Care Organization (MI Health Link health plan) is NOT REQUIRED The Facility Admission Form (MSA-2565-C) should NOT be sent to the Michigan Department of Health and Human Services (MDHHS) Enrollment Services Section for a disenrollment to be processed

26

What are the Names

bull Started as Integrated Health

bull Then called MMP (Medicare Medicaid Program)

bull Duals (Also Known as Duals as in Dual Eligible)

bull Now called MI Health Link

bull Total confusion

27

MI Health Dual Eligible28

MI Health LOC

29

LOC Medicaidbull We have the new pilot program which started on March

1 2015 in Southwest Michigan Region 4 Counties Macomb Wayne and the UP You could see these patients they are dual eligible in the Pilot program in counties surrounding the pilot

bull MHL-LOC 005 (All other Facilities) or LOC 015 (County Care) These residents have to call Michigan Enrolls to dis-enroll toll-free at 1-800-975-7630 (TTY 1-888-263-5897) Monday-Friday from 8 AM to 7 PM Once they dis-enroll they will go to a LOC 02 you have to do a new LOCD

30

Medicaid Redetermination and MHL Enrollmentbull At the time of re-determination for Medicaid financial eligibility the MI

Health Link (MHL) program will not be sending beneficiaries information about this program Beneficiaries who previously opted out will not be passively enrolled according to an email from the MHL staff The MHL staff wrote

bull ldquoThere is currently no MI Health Link enrollment letter sent to beneficiaries when eligibility is re-determined A person who becomes eligible for MI Health Link enrollment may opt-in at any time

bull When Medicaid re-determination takes place the beneficiary remains in the same ICO unless that beneficiary lost Medicaid coverage If the enrollee loses Medicaid coverage and later regains it they are not passively enrolled into MI Health Link The beneficiary may choose to opt back in to the program at that time if desiredrdquo

bull MHL staff did state that about 1500 beneficiaries will be passively enrolled effective January 1 2016 These specific individuals were given normal notice of 60 and 30 days in which to opt-in or opt-out if they so chose No other large scale passive enrollment is scheduled according to the MHL staff 31

MI Health Link Portals

bull Meridian Health Planbull httpwwwmhplancommibull Amerihealthbull httpwwwamerihealthcaritasvipcarepluscomproviderself-service-

toolsindexaspxbull AetnaCoventrybull httpwwwaetnabetterhealthcomMichiganprovidersportalbull Molinabull httpwwwmolinahealthcarecommembersmien-usmemPageshomeaspxbull HAPMidwestbull httpswwwmidwesthealthplancomLoginaspxbull FidelisCentenebull wwwfidelissccommmp 32

MI Health Authorizationsbull We need to watch these authorization that the plans are giving us for the MI

Health program Some plans are assigning a diagnosis for residents in their prior authorizations They are assigning diagnosis that the residents do not even have You need to make sure these are correct diagnosis and if not you need to work with the case managers of the plans to fix the issue The authorization numbers do change

bull Make sure that any resident that is in a MI Health plan that you have a prior authorization All plans are giving different periods authorizing the residents stay in the facility You need to set up a system to make sure you always have a authorization for the period of time you are rendering the service Here is an example of time frame of authorizations

bull Meridian is authorizing 12 monthsbull Aetna is authorizing 3 monthsbull Molina is authorizing 6 monthsbull The authorization numbers need to go on your claims to the payer You need to

put the authorizations in your software and track the dates

33

MI Health Issuesbull We are seeing some issues with MI Health where the resident does not have the correct LOC or it shows

up correct on CHAMPS but ancillary providers such as Dentist and such cannot see it I think we still have some issues with the information crossing between Bridges DHS system CMS and CHAMPS It in return is creating some access of care issues If it is a true LOC issues Facilities with LOC issues need to submit the Medicaid ID numbers to the MSA-MHL-EnrollmentMichigangov box with the subject line Nursing home LOC Issue so they may work to resolve the issues

bull If it becomes an access to care issue email the information to INTEGRATEDCAREmichigangov Remember in these emails only send the Medicaid ID and explain the situation The State will work with the plans to try to fix the process or improve the process

bull We are also seeing with new admission with LOC 015 or 005 that the plans are stating they have 14 days to authorize admission These are resident in the emergency room and possibly be admitted to you for Rehab The hospital will not keep the resident in ER for 14 days and you cannot admit the resident until you have a prior authorization I would recommend when you are told this by the plan that you need to ask to speak to a manager We will have to work through this

bull Ancillary Provider You need to work with your ancillary providers such as Lab Pharmacy X-Ray Physician and such to get the to be credentialed with the plans We are hearing that some of the pharmacies are not participating with the plans this will create issues for you so I would continue to ask these groups to participate

34

LOC 02 dropping MI Health Issuesbull The passive enrollments have occurred in Macomb amp Wayne for

Medicaid dual eligible We are having the same issue we did as in the Southwest MI amp UP with the passive enrollments I am starting to hear from facilities who are checking there CHAMPS member screens that those residents that have opted out (some residents not all) have lost there 02 Make sure you are checking your CHAMPS member screen both for those that were passively enrolled and those that might have lost there 02 Medicaid that opted out

bull Facilities with LOC issues need to submit the Medicaid ID numbers to the (Only MI Health)MSA-MHL-Enrollmentmichigangov box with the subject line Nursing home LOC Issue so they may work to resolve the issues

35

PPA Offset

bull There are no co-pays deductibles or premiums in MI Health Link so there should be no need to offset the PPA with code 25 MI Health Link enrollees can continue to offset their PPA for non-program covered medical expenses (like Vision-Code 27 Dental-Code 28 and Hearing-Code 26) and use the appropriate codes to offset the PPA when billing the health plan for nursing facility services

bull Resident pay PPA when MedicareMedicaid coinsurance

36

LOCDbull Nursing Facility Level of Care Determination (NFLOCD)

bull The MI Health Link health plan will be responsible for conducting the Michigan Medicaid NFLOCD tool for enrollees seeking admission to a nursing facility For existing residents at the time of enrollment the existing NFLOCD will be adopted for capitation payment purposes The health plan will complete a new NFLCOD tool within the first 90 days of enrollment If a nursing facility resident is disenrolled from MI Health Link the nursing facility will be responsible for conducting a new NFLOCD tool in accordance with published Medicaid policy

37

MI Health Issues-New

bull INTEGRATEDCAREmichigangov

bull Email with Insurance Plan issues Case Manager Issues

38

ACOWhat are they

39

Families Receiving Letters for ACO

40

ACO What is It

bull Whats an ACObull Accountable Care Organizations (ACOs) are groups of doctors hospitals

and other health care providers who come together voluntarily to give coordinated high quality care to their Medicare patients

bull The goal of coordinated care is to ensure that patients especially the chronically ill get the right care at the right time while avoiding

unnecessary duplication of services and preventing medical errorsbull When an ACO succeeds both in delivering high-quality care and

spending health care dollars more wisely it will share in the savings it achieves for the Medicare program

41

Payroll Based JournalMandatory on July 1 2016Internet Explorer Version

Internet Explorer v 10 and v 11 will need to operate in compatibility mode

42

43

If you submit data manually should you also submit it through the XML

bull Now you have three options

bull Submit Manually only

bull Submit through the XML only

bull You are able to submit manually and using the XML

44

45

Staffing Submission Frequently Asked Questions

bull ldquoWho are direct care staffrdquo (Who do we submit data for)bull Submission of data for contract staffbull Medical directors and consultantsbull Staff switching roles or tasks throughout the daybull Hours paid vs hours worked ndash Must be verifiablebull Public postingQuality MeasuresFive Starbull Enforcementbull Voluntary submission risks (noneSo register now)

CMS defines

bull 37 job title codes that are required to match employees to the number of hours each direct care function was performed It is important to work with your teams to define the workers that contribute to each job type and how those daily worked hours are recorded and converted to a PBJ submission

bull The PBJ does include some more specific job descriptions than the 671 For example the PBJ system includes job descriptions for RNs with administrative duties and LPNs with administrative duties versus the 671rsquos more general ldquoNurses with Administrative Duties

Page 46

47

PBJ Medical Director Rolebull Physician Leadership

bull Help the facility ensure that patients have appropriate physician coverage and ensure the provision of physician and health care practitioner services and

bull Help the facility develop a process for reviewing physician and health care practitioner credentials

bull Provide specific guidance for physician performance expectations

bull Help the facility ensure that a system is in place for monitoring the performance of health care practitioners and

bull Facilitate feedback to physicians and other health care practitioners on performance and practices

bull Patient Care - Clinical Leadership

bull Participate in administrative decision-making and the development of policies and procedures related to patient care

bull Help develop approve and implement specific clinical practices for the facility to incorporate into its care-related policies and procedures including areas required by laws and regulations

bull Develop procedures and guidance for facility staff regarding contacting practitioners including information gathering and presentation change in condition assessment and when to contact the medical director

bull Review consider andor act upon consultant recommendations as appropriate that affect the facilitys resident care policies and procedures or the care of an individual resident

bull Review respond to and participate in federal state local and other external surveys and inspections and

bull Help review policies and procedures regarding the adequate protection of patients rights advance care planning and other ethical issues48

PBJ Medical Director Rolebull Quality of Care

bull Help the facility establish systems and methods for reviewing the quality and appropriateness of clinical care and other health-related services and provide appropriate feedback and

bull Participate in the facilitys quality improvement process

bull Advise on infection control issues and approve specific infection control policies to be incorporated into facility policies and procedures

bull Help the facility provide a safe and caring environment

bull Help promote employee health and safety and

bull Assist in the development and implementation of employee health policies and programs

bull Education Information and Communication

bull Promote a learning culture within the facility by educating informing and communicating

bull Provide information to help the facility provide care consistent with current standards of practice (defined as approaches to care procedures techniques and treatments that are based on research and or expert consensus and that are contained in current manuals textbooks and or publications or that are accepted adopted or promulgated by recognized organizations or national bodies)

bull Help the facility develop medical information and communication systems with staff patients and families and others

bull Represent the facility to the professional and lay community on medical and patient care issues

bull Maintain knowledge of the changing social regulatory political and economic factors that affect medical and health services of long term care patients and

bull Help establish appropriate relationships with other health care organizations

49

Dietician

bull When the dietary or food services supervisor is other than a registered dietitian the supervisor shall receive routine consultation and technical assistance from a registered dietitian (RD) Consultation time shall not be less than 4 hours every 60 days Additional consultation time may be needed based on the total number of patients incidence of nutrition-related health problems and food service management needs of the facility

50

Pharmacy Consultant

bull At least once per month a licensed pharmacist must perform a drug regimen review (DRR) for each resident The pharmacist must report any irregularities to the attending physician or director of nursing Furthermore these reports must be acted upon

51

What are the names for the Medicare Numberbull OSCAR -Online Survey Certification and Reporting

bull PTAN-PTAN number is assigned by Medicare to authenticate the provider when using the local Medicare Administrative Contractorrsquos (MAC) self-help tools like the IVR internet portal on-line application status etc Provider Transactions Access Number

bull CCN- CMS Certification Number

bull Medicare Number- example 23-

bull All of the above mean the same thing

52

QTSO

bull Once you are logged in the QTSO site bull You will have a state login to the site to access the various site specific

to your facilitybull Installing you will need administrator rights to your network

53

Medicare UpdateWhat are we seeing

54

CMS Final Rule On Returning Credits

httpswwwfederalregistergovarticles201602122016-02789medicare-program-reporting-and-returning-of-overpayments

55

Over Payment Rule

bull Medicare payments for non covered services

bull Medicare payments in excess of the allowable amount for an identified covered service

bull Errors and non reimbursable expenditures in cost reportsbull Duplicate payment

bull Receipt of Medicare payments when another payor had the primary responsibility for payment

56

Questions to MAC

bull Does the Medicare credit balance report change with this overpayment rule

bull No Medicare Credit Balances are still required at the end of each quarter

bull Will that still be the communication to let CMS or the MAC know that we have received an overpayment

bull Submission of Medicare Credit Balance is one form of communicating overpayments to CMS Other methods include submitting a voluntary refund with required claim information or the submission of a standard overpayment form

57

Questions to MAC

bull Will the MAC still deduct from a future RAbull If the recovery of the overpayment includes adjusting a claim then

the overpayment would be netted against future claims payments and reflected on the RA

bull Or will that process change with this new rulebull Process will remain the samebull Will NGS send communication out on thisbull Yes NGS will communicate this once the final rule is communicated

to the MACs by CMS However this could change depending on final CMS instructions

58

Final Rule on Returning Credits

bull Providers will want to immediately update their current policies governing overpayments in order to comply with this new rule which will take effect on March 14 2016

bull Providers and suppliers are required to use reasonable diligence to investigate credible information regarding overpayments through both proactive compliance efforts and reactive investigations

bull If an overpayment is identified then it must be repaid within 60 days An overpayment is identified when a person has or should have through the exercise of reasonable diligence determined that the person received an overpayment and quantified the amount

bull Providers and suppliers have a maximum of 8 months to report and return overpayments ndash up to 6 months to investigate and quantify the overpayment (ie to identify it) and up to 60 days to report and return the overpayment

59

Final Rule on Returning Credits

bull Providers and suppliers are required to report and return all overpayments within a 6-year lookback period

bull The cause and amount of the overpayment is irrelevant for the determination eg it was due to a mistake it was someone elsersquos fault it is a minor amount An overpayment is an overpayment and must be returned

bull Providers and suppliers must make their own determination to which entity to report and return the overpayment ie to the Medicare contractor or using the OIG Self Disclosure Protocol or the CMS Self Referral Disclosure Protocol

60

Final Rule on Returning Credits

bull Providers and suppliers may use the claims adjustment credit balance self-reported refund process or another appropriate process to report and return overpayments At this time there is no standard refund form to use

bull Failure to report and return an overpayment could subject the provider or supplier to False Claims Act liability Civil Monetary Penalties Law liability and exclusion from federal health care programs

61

P S amp R-Accountants will be asking for this information

The location you login into has changed it is now on EIDM EIDM is the acronym for CMS Enterprise Identity Management system which includes Identity Verification Access Management Authorization Assistance Workflow Tools and Identity Lifecycle Management functions

httpswwwcmsgovResearch-Statistics-Data-and-SystemsCMS-Information-TechnologyIACSCMS-Applications-Loginhtml

Go down the page and click on the PSampRSTARThis will take you to the login pagewill look the same as the old P S amp R didChanges Affecting PSampR System Access (Please Read) (posted 01292015)(Updated 5262015)is changingThe system which controls your PSampR user ID (currently IACS)The new system is referred to as EIDMThis will result in a different way to create new accounts or change passwords to existing accountsIf you already have an account in EIDM you may have to use that account for accessing PSampR after the transitionWhen is the change effectiveJune 13 2015What is staying the sameThe internet address for accessing PSampR remains the sameThe PSampR systemfunctionality is NOT changing 62

Medicare Advantage Payorsbull Medicare Advantage payors are pullingdenying payments on admissions if the patient was readmitted within 30 days after discharge The

client believes that the payors systematically denying payments for all readmissions within 30 days They believe this practice denies them due process to address whether the readmissions were justified and not due to a premature discharge of patient The payors seem to want to act like a QIO without having the same accountabilities of the QIO related to determinations of non-payment

bull Heres the QIO process under section 4240 of the QIO Manualbull 4240 - Readmission Review - (Rev 2 07-11-03)bull Readmission review involves admissions to an acute general short-term hospital occurring less than 31 calendar days from the date of

discharge from the same or another acute general short-term hospital (see sect1154(a)(13) and 42 CFR 47671(a)(8)(ii)) Neither the day of discharge nor the day of admission is counted when determining whether a readmission has occurred

bull A Medical Review Proceduresbull Obtain the appropriate medical records for the initial admission and readmission Perform case review on both stays Analyze the cases

specifically to determine whether the patient was prematurely discharged from the first confinement thus causing readmission Perform an analysis of the stay at the first hospital to determine the cause(s) and extent of any problem(s) (eg incomplete or substandard treatment) Consider the information available to the attending physician who discharged the patient from the first confinement Do not base a determination of a premature discharge on information that the physician or provider could not have known or events that could not have been anticipated at the time of discharge

bull Review both the initial admission and the readmission at the same time unless one of them has previously been reviewed In these cases use at a minimum the PRAF case summary of the other admission in addition to the medical record of the case under review

bull C Denialsbull Deny readmissions under the following circumstancesbull If the readmission was medically unnecessarybull If the readmission resulted from a premature discharge from the same hospital orbull If the readmission was a result of circumvention of PPS by the same hospital (see sect4255)bull With the QIO process there is an appeal within the QIO here the hospital is getting no opportunity to challenge the denials

63

Medicare Provider Enrollment Feebull Provider Enrollment Application Fee Amount for CY 2016bull On December 3 CMS issued a notice Provider Enrollment Application

Fee Amount for CY 2016 [CMSndash6066ndashN] Effective January 1 2016 the CY 2016 application fee is $554 for institutional providers that are

bull Initially enrolling in the Medicare or Medicaid program or the Childrens Health Insurance Program (CHIP)

bull Revalidating their Medicare Medicaid or CHIP enrollmentbull Adding a new Medicare practice locationbull This fee is required with any enrollment application submitted from

January 1 through December 31 2016

64

Medicare MAC-Higlas

bull Effective 142016 CMS has implemented a change to begin netting (offsetting) provider money across workloads within a single organization What this means is that any related providers conducting business in two different workloads (example New York and Maine) will have their money applied to any account receivables (AR) with a remaining balance owed to Medicare within both workloads For example Provider ABC is located in New York and is scheduled to receive a payment of $1000 on todays remittance advice Provider XYZ is related to provider ABC but is located in Maine and has ARs with a balance owed of $200 Provider ABCs $1000 payment will have the $200 applied against provider XYZs ARs resulting in a net payment of $800 This will be reflected on the remittance advice by the same PLB code as seen today for offsets for the $200

65

Two Midnight RuleChange January 1 2016 httpswwwcmsgovMedicareMedicare-Fee-for-Service-PaymentHospitalOutpatientPPSHospital-Outpatient-Regulations-and-Notices-ItemsCMS-1633-FChtml

66

Two Midnight Rulebull However effective January 1 2016 CMS will allow exceptions to the

Two-Midnight Benchmark to be determined on a case-by-case basis by the physician responsible for the care of the beneficiary subject to medical review Said differently Part A payment may be appropriate in some circumstances even though there is no expectation by the physician (or qualified ordering practitioner) of a two-midnight stay and one of the two pre-existing categorical exceptions (CMS ldquoinpatient onlyrdquo list and newly initiated mechanical ventilation) does not apply CMS has indicated that this change to the Two Midnight Rule is in response to stakeholder concern and CMSrsquos continued efforts to develop the most appropriate standard for determining Medicare Part A payment

67

Two Midnight Rulebull A new 42 CFR sect4123(a) provides that a patient is considered an

inpatient of a hospitalhellipif formally admitted as an inpatient pursuant to an order for inpatient admission by a physician or other qualified practitionerhellip The physician orders inpatient status when he or she expects the patient to require a stay that crosses at least 2 midnights[10] Stays expected to be shorter than at least two midnights are generally inappropriate for inpatient admission and inpatient payment under Medicare Part A unless the surgical procedure is specified by Medicare as inpatient only under sect41922(n)[11] The physicians expectationhellipshould be based on such complex medical factors as patient history and comorbidities the severity of signs and symptoms current medical needs and the risk of an adverse event[12] The physician order is part of physician certification of the medical necessity of hospital inpatient serviceshellip[13]

68

InPatient Vs Observation Conthellip

bull Physician certification which begins with an order for inpatient admission requires the physician to certify the reasons for the hospitalization the estimated time the patient will remain in the hospital and plans for post-hospital care if appropriate[14] The certification must be completed signed and documented in the medical record prior to discharge[15]

bull A physicians admission order has no presumptive weight and both the admission order and the physician certification will be evaluated in the context of the evidence in the medical record[16] CMS intends to provide additional information about what evidence in the medical record means in future instructions and manual revisions[17]

69

Two Midnight Rulebull Although the new case-by-case exception appears to be inherently

subjective to a certain extent CMS states that the following factors (among others) would be relevant to determining whether a patient requires inpatient admission under the expanded policy

bull The severity of the signs and symptoms exhibited by the patient bull The medical predictability of something adverse happening to the patient

and bull The need for diagnostic studies that appropriately are outpatient services

(that is their performance does not ordinarily require the patient to remain at the hospital for 24 hours or more)

bull CMS also notes that an inpatient admission (and Part A payment) should be ldquorare and unusualrdquo for minor surgical procedures or other treatment that is expected to keep the patient in the hospital ldquofor only a few hoursrdquo or for a period of time that ldquodoes not span at least overnightrdquo (thus a subset of stays not meeting the Two Midnight Benchmark) CMS indicates that such cases will be prioritized for medical review

70

Health Data Insights amp Medicare Plus Blue

RAC (Retrospective Audits)

71

HDI Health Data amp Med Plus Blue

bull httpwwwhealthdatainsightscombull Blue Cross Medicare Advantage Auditsbull Facilities seeing 10 to 15 requests for Medical Recordsbull In January amp Feburarybull Selected Health Data Insights because they were a premier Audit

Vendor for CMS Recovery Audit Contractor (RAC) demonstration Project They are a audit vendor for Humana

bull Providers not sending Medical Record will get technical denial and lose payments

72

Health Data InSight

bull In 2010 they began the Hospital Reviewbull Medicare Advantage encounter datandashCMS oversight of data integrity OIG

2016bull We will review CMSs oversight of MA encounter data validation and assess

the extent to which CMSrsquos Integrated Data Repository contains timely valid and complete MA encounter data In 2012 CMS began collecting from MA organizations a more comprehensive set of encounter data reflecting the items and services provided to MA plan enrollees Prior CMS and OIG audits have indicated vulnerabilities in the accuracy of data reporting by MA organizations Realizing the potential benefits of the MA encounter data for payment and program integrity oversight is contingent upon the datarsquos completeness validity and timeliness (OEI 03-15-00060 expected issue date FY 2017)

73

Pepper Reports

bull httpswwwpepperresourcesorg

bull Program for Evaluating Payment Patterns Electronic Report ( PEPPER)

bull Annually on or about April 18 2016 will be released

bull Pepper Portal httpssecurefiletmforg

74

CGI Technologies and Solutions Inc httpracbcgicomContactInfoaspxst=1

bull Indiana bull Michiganbull Minnesotabull Illinoisbull Kentuckybull Ohiobull Wisconsin CGI Technologies and Solutions Incbull For general and administrative questions regarding client service outreach

quality assurance or project-specific issues contactbull 1877316RACB (7222)bull Email racbcgicom Tamara Tate Tamaratatecmshhsgovbull 4107861288

75

CGI Federal RAC

bull CGI Federal RAC Region Bbull Email racbcgicombull Phone 1-877-316-RACB (7222)bull Mailing Addressbull Send medical records as followsbull Medical records for Indiana Illinois Kentucky Michigan Ohio Wisconsin

Minnesota DME and Home Health CGI Federal Inc Attn RACB Imaging Dept 1001 Lakeside Ave Suite 800 Cleveland OH 44114

bull If submitting paper records please send medical records as follows For Therapy Reviews CGI Federal Inc Attn RACB Imaging 1001 Lakeside Avenue Suite 800 Cleveland OH 44114

76

How to survive RAC Audit

bull National health expenditures totaled $1679 Billion in 2003 bull National health expenditures were 153 of GROSS Domestic Product

(GDP) in 2003 bull Health care cost increasing at +9 per year bull Doomsday predictions of Medicare running out bull Congressional Action

77

RAC Audits

bull Medicare Modernization Act (MMA) of 2003Mandated a three year audit demonstration project 2005-2008

bull Appoint audit contractors to review Medicare billings for proper coding DRG assignment and medical necessity

bull Audits will apply to all health care providers (hospitals physicians homecare dme etc)

bull Audit contractors to be paid on a contingency basis a percentage of overpayments recovered

78

How Did we get here

bull Overpayments collected due to errors in Medically Unnecessary Services ndash 40

bull Incorrectly Coded ndash 35

bull Other ndash 17

bull NoInsufficient Documentation ndash 8

79

Where are we now

bull All RACrsquos completed required provider outreachAccess to Medicare billing data base given to all RAC RAC review methodology

bull Automated Review-Black amp White Issues (current) bull DRG Validation-complex review (current) bull Complex Review for coding errors (current) bull DME Medical Necessity Reviews ndashcomplex review (calendar year

2010) bull Medical Necessity Reviews-complex review (calendar year 2010)

80

RAC Reviews

bull Responsibilities of the Team Leader bull Must learn each insurance provider participating in a RAC or RAC type

program bull What are their operating rulesbull What is their appeal process Time limits

May be different process for each insurance provider bull Develop a response team

Identify who does what when why and alternate bull individual

Build and develop a manual process Review of computerized system

81

Priority Health SCIO Health Analytics

bull httpswwwsciohealthanalyticscomcore-capabilitiespayment-integrityfacility-auditsskilled-nursing-facility-audits

bull Claims for Medicare members treated at Skilled Nursing Facilities are reimbursed based on the patientsrsquo RUG (Resource Utilization Group) score which is determined using the Minimum Data Set (MDS) Using SCIOs robust analytics claims andor providers that merit review are selected for audit SCIOs auditors conduct a detailed review of the complete medical record and associated MDS to determine if the billed RUG score is valid In the event the review determines that an incorrect RUG score was billed SCIOreg provides the valid score reports the reason the change was necessary and calculates the resulting overpayment

82

+ Cheer

Onward and Upward she shall prevail We are here to care for the residents and provide a wonderful

service

13 83

84

References

bull Priority Healthbull Blue Crossbull Medicaidbull Medicare

85

  • Medicare Mange Care amp Medicaid Changes in the New World We Live In
  • Medicaid
  • NEW Medicaid Change MIlogin
  • Blueprint for Health Innovation MI
  • Provider Enrollment Electronic Signature Form Submission Process MSA 15-54
  • Provider Enrollment Electronic Signature Form Submission Process
  • Provider Enrollment Domain Administrator
  • Medicaid Coinsurance Medicare Advantage
  • Slide Number 9
  • Lawsuit DHS Changes on Caregivers
  • TPL Medicaid Change
  • CHAMPS Member Screen
  • LOC dropping off Not Due to MI Health
  • Issues
  • Secure Email Information
  • Medicaid amp Hospice
  • Medicaid
  • Medicaid Medicare Buy In
  • Manage Medicaid
  • Healthy Michigan Residents
  • Healthy Michigan Medicaid Days
  • McLaren Health Plan
  • Manage Medicaid Plans January 1
  • Slide Number 24
  • MI Health Link
  • MI Health Link 2565
  • What are the Names
  • MI Health Dual Eligible
  • MI Health LOC
  • LOC Medicaid
  • Medicaid Redetermination and MHL Enrollment
  • MI Health Link Portals
  • MI Health Authorizations
  • MI Health Issues
  • LOC 02 dropping MI Health Issues
  • PPA Offset
  • LOCD
  • MI Health Issues-New
  • ACO
  • Families Receiving Letters for ACO
  • ACO What is It
  • Payroll Based Journal
  • Slide Number 43
  • If you submit data manually should you also submit it through the XML
  • Staffing Submission Frequently Asked Questions
  • CMS defines
  • Slide Number 47
  • PBJ Medical Director Role
  • PBJ Medical Director Role
  • Dietician
  • Pharmacy Consultant
  • What are the names for the Medicare Number
  • QTSO
  • Medicare Update
  • CMS Final Rule On Returning Credits
  • Over Payment Rule
  • Questions to MAC
  • Questions to MAC
  • Final Rule on Returning Credits
  • Final Rule on Returning Credits
  • Final Rule on Returning Credits
  • Slide Number 62
  • Medicare Advantage Payors
  • Medicare Provider Enrollment Fee
  • Medicare MAC-Higlas
  • Two Midnight Rule
  • Two Midnight Rule
  • Two Midnight Rule
  • InPatient Vs Observation Conthellip
  • Two Midnight Rule
  • Health Data Insights amp Medicare Plus Blue
  • HDI Health Data amp Med Plus Blue
  • Health Data InSight
  • Pepper Reports
  • CGI Technologies and Solutions Inc httpracbcgicomContactInfoaspxst=1
  • CGI Federal RAC
  • How to survive RAC Audit
  • RAC Audits
  • How Did we get here
  • Where are we now
  • RAC Reviews
  • Priority Health SCIO Health Analytics
  • Cheer
  • References
Page 6: Medicare, Mange Care & Medicaid Changes in the New World we live in

Provider Enrollment Electronic Signature Form Submission Process

bull In compliance with 42 CFR 455104 the Michigan Department of Health and Human Services (MDHHS) is establishing a new process associated with Medicaid provider screening and enrollment requirements related to program integrity for the Medicaid Fee-for-Service (FFS) program Providers were previously notified of the changes required under 42 CFR 455105 in bulletin MSA 12-55 This bulletin describes the process for assigning additional domain access rights to the Community Health Automated Medicaid Processing System (CHAMPS) Provider Enrollment (PE) subsystem on a providers behalf

bull These forms do not need to be completed if no new domain access rights are needed

bull Issued 12302015bull Effective on 02012016

6

Provider Enrollment Domain Administrator

bull Electronic Signature Agreement Form bull To obtain the required information mandated under 42 CFR 455104 any

provider wishing to appoint another person access to their CHAMPS information must submit an Electronic Signature Agreement form (DCH-1401) and the Electronic Signature Agreement form cover sheet (MDHHS-5405) The two completed forms must be submitted to the MDHHS Medicaid Provider Enrollment Unit for processing MDHHS recommends the provider retain a copy of these forms for their records

bull The Electronic Signature Agreement form is also being updated to include additional language certifying the enrolled provider understands he or she is liable and bound by all information submitted on his or her behalf

7

Medicaid Coinsurance Medicare Advantage

bull Attention Nursing Facility Medicaid Fee for Service Providers

bull As part of the December 11 2015 CHAMPS system update the final phase of the Medicare Advantage Coinsurance Pricing Logic was implemented For claim dates of service 2010 and prior please refer to the Medicaid Provider Manual under General Information for Providers Chapter Section 124 Provider Returning Overpayments

bull For claim dates of service 2011 and forward MDHHS will be initiating the claim adjustment within the next few weeks Providers with further questions can contact Provider Support by phone 1-800-292-2550 or email ProviderSupportmichigangov

8

The State has been paying the wrong coinsurance amount for Medicare Advantage since 2008 Per below they will be doing a claim adjustment in the next few weeks for dates of service 2011 going forward If you have refunded the State by a check watch and make sure they do not double recover the money If they do you will have to get your check and list of people you refunded and send it to providersupportmichigangov They have stated they have fixed the pricing logic to pay it correctly going forward Watch and make sure they are paying the correct amount if not you will have to again pull the information from the coinsurance payer and send it to providersupportmichigangov

For dates of service prior to 2011 you will have to return the Money per the Medicaid manual

Medicaid providers performing self audits may discover an overpayment situation and wish to return theMedicaid overpayment to MDHHS This process should only be used when the provider is unable to claimadjust or it is not practical to claim adjust Sending in a check will not correct the underlying claim(s)data Providers must

10487071048707 Document why the money is being returned (ie provider self audit) and identify provider NPIinformation address dates of service and specialty area (ie durable medical items pharmacyphysician practice hospital etc) and include a basic information letter

10487071048707 Attach an excel spreadsheet document with the Tax ID billing NPIs and associated amounts (ifmultiple IDs exist for the entity) for the MDHHS Accounting Office to apply credit to

10487071048707 Make check payable to State of Michigan and mail to the MDHHSCashierrsquos Unit - Attn Bureauof Finance-MCU (Refer to the Directory Appendix for contact information) 9

Lawsuit DHS Changes on Caregivers

bull A recent Michigan Court of Appeals decision has played havoc on the rules surrounding payments to non-family caregivers DHS rules regarding payments to caregivers state that payments are divestment in two situations 1) prospective payments made to any caregiver (family or non-related) before care is provided and 2) payments to family caregivers absent a Medicaid qualified caregiving contract The Court of Appeals decision Jensen v Department of Human Services confuses the rules and applies the family caregiving contract requirements to all caregivers even professional caregiving agencies The result of the case is that payments to non-family caregivers may be divestment unless the Medicaid applicant has a contract with the caregiver meeting the extremely specific rules found in the Medicaid manual

10

TPL Medicaid Changebull Attention Providersbull Effective October 26 2015 the MDHHS Third Party Liability (TPL)

Update Other Insurance Now Online form will be updated You will now receive a confirmation number when you submit your request If an email address is added within the Requestor Information section once TPL completes your request you will receive an email with the confirmation number and the status of your request Please allow up to 10 business days for information to be verified and updated in the system Please check your spam or junk email folders if you do not receive the email after 10 business days

bull Providers with further questions can contact Provider Support by phone 1-800-292-2550 or email ProviderSupportmichigangov

bull httpsminotifytplstatemiustedpubliccoveragerequestsindex11

CHAMPS Member Screen

bull Attention Providersbull Effective September 25 2015 a change was made to the CHAMPS

system This change modified the provider view for the Member Eligibility Inquiry screen If a member no longer has active Medicaid the hyperlink to view ldquoCommercialOtherrdquo Third Party Liability (TPL) information is disabled Because TPL does not always maintain TPLOther Insurance information for members that do not have active Medicaid coverage this information was disabled to prevent inaccurate information from being reported

12

LOC dropping off Not Due to MI Health

bull If after 30 days the county hasnrsquot processed the 2565 that you have send via the central scan (517-346-9888) AND other methods you choose to use you can email the 2565 to ArdeneMartin

bull At the following mailbox I ask that you put the beneficiaries name in the subject line

bull MSA2565michigangov

13

Issues

bull PPA going all over the place

bull LOC 02 dropping off not related to MI Health

bull LOCD tons of money written off

bull Must check CHAMPS member screen all the time and you must check pending

14

Secure Email Information

bull The State of Michigan asked me to remind you when you are communicating with them regarding residents to not send Resident names Birthdates or Social security numbers in those emails What you send is the Medicaid ID and they can look it up Or if it is a billing issue send them the TCN and the Medicaid ID We have been in the practice of emailing DHS Ardene Martin Integrated Health and Provider Support with all the resident name and such

15

Medicaid amp Hospicebull LOC 07 Manage Medicaid Hospice included so plan would pay

provider and not switch to a LOC 16

bull LOC 02 Medicaid (Regular Medicaid) Hospice not included so switch to 16 Hospice and Hospice pays provider

bull LOC 11 Healthy Michigan is included in plan so plan would pay provider and not switch to LOC 16

bull LOC 005 amp 015 MI Health is up in the air waiting for CMS Currently Hospice is now included

bull LOC 16 is Hospice when they switch from Regular Medicaid only and Hospice pays provider

16

Medicaidbull Going forward please make sure that your Champs ID amp NPI on your member screen matches your facility CHAMPS ID

amp NPI for each resident and matches for all new admissions or new approved Medicaid going forward

bull The edit will be turned on soon to stop the payment of these claims if the CHAMPS ID and NPI do not Match your facility on the Medicaid member screen

bull Make sure you are putting the information correct on the 2565 you send in to DHS

bull 1 I attached a 2565 When you fill this out for new people make sure in box 12 a you put your NPI and 12 b you put your CHAMPS ID This will help the DHS case workers assign the person to your facility

bull 2 I would check all your residents CHAMPS member screens and make sure the NPI and CHAMPS ID are your facilities If not you will have to work with the DHS worker to fix this The DHS worker is the only one that can fix this

bull 3 We are having some issues where the DHS case workers will not change this NPI and CHAMPS ID to your facilities You have to get them to change it or you just will not get paid

bull 4 We situations where the resident is in a facility in Kent County (as an example) but the family lives in Livingston County and completes the applications in Livingston County You will have to get the DHS worker in Livingston to fix it not the local DHS worker in Kent County where your facility is

17

Medicaid Medicare Buy Inbull Based on the information from the Office of Personnel Management Federal

Employeersquos employed as of January 1 1983 are eligible for Medicare Part A(see page 5 of attached document) This was also confirmed with our Social Security liaison If the beneficiary did not retire before 1983 he can enroll in Medicare Part B and pay the premium and then he can enroll in Medicare Part A and pay that premium as well or may qualify for Medicare Buy in of Part A

bull If a beneficiary has an SSA document stating they are not eligible for Medicare as they do not have enough work credits the beneficiarybeneficiary representative needs to go to SSA and let them know that while they know they are not eligible for Medicare Part A free or reduced however they are eligible for Medicare Part B and would like to enroll Once the beneficiary enrolls in Medicare Part B (enrollment period January 1st ndash March 31 each year) and pays the premium then the beneficiary is eligible to either pay for Medicare Part A or that beneficiary may qualify for Medicare Part A buy in through Medicaid Once the beneficiary is enrolled in Medicare Part A and Medicare Part B Medicaid will begin to make payments on claims

18

Manage Medicaid Where are we

19

Healthy Michigan Residents

20

Healthy Michigan Medicaid Days

21

McLaren Health Plan

22

Manage Medicaid Plans January 1bull Region 1 ndash Upper Peninsula Health Planbull Region 2 ndash McLaren Health Plan Meridian Health Plan of Michigan Molina Healthcare of Michigan

UnitedHealthcare Community Planbull Region 3 ndash McLaren Health Plan Meridian Health Plan of Michigan Molina Healthcare of Michigan

UnitedHealthcare Community Planbull Region 4 ndash Blue Cross Complete of Michigan McLaren Health Plan Meridian Health Plan of Michigan Molina

Healthcare of Michigan Priority Health Choice UnitedHealthcare Community Planbull Region 5 ndash McLaren Health Plan Meridian Health Plan of Michigan Molina Healthcare of Michigan

UnitedHealthcare Community Planbull Region 6 ndash Blue Cross Complete of Michigan HAP Midwest Health Plan McLaren Health Plan Meridian Health

Plan of Michigan Molina Healthcare of Michigan UnitedHealthcare Community Planbull Region 7 ndash Blue Cross Complete of Michigan McLaren Health Plan Meridian Health Plan UnitedHealthcare

Community Planbull Region 8 ndash Aetna Better Health of Michigan McLaren Health Plan Meridian Health Plan of Michigan Molina

Healthcare of Michigan Priority Health Choice UnitedHealthcare Community Planbull Region 9 ndash Aetna Better Health of Michigan Blue Cross Complete of Michigan McLaren Health Plan Meridian

Health Plan of Michigan Molina Healthcare of Michigan UnitedHealthcare Community Planbull Region 10 ndash Aetna Better Health of Michigan Blue Cross Complete of Michigan Harbor Health Plan McLaren

Health Plan Meridian Health Plan of Michigan Molina Healthcare of Michigan Total Health Care UnitedHealthcare Community Plan 23

24

MI Health LinkWhere are we

25

MI Health Link 2565

bull This notification is being sent to providers of long term care services including nursing facilities county medical care facilities and hospital long term care units to provide clarification on the process involved with the submission of the Facility Admission Form (MSA-2565-C) for an individual enrolled in the MI Health Link program

bull The MI Health Link program covers the custodiallong term nursing facility service benefit When an individual who is enrolled in the MI Health Link program is admitted to a nursing facility for custodiallong term nursing services a disenrollment from the Integrated Care Organization (MI Health Link health plan) is NOT REQUIRED The Facility Admission Form (MSA-2565-C) should NOT be sent to the Michigan Department of Health and Human Services (MDHHS) Enrollment Services Section for a disenrollment to be processed

26

What are the Names

bull Started as Integrated Health

bull Then called MMP (Medicare Medicaid Program)

bull Duals (Also Known as Duals as in Dual Eligible)

bull Now called MI Health Link

bull Total confusion

27

MI Health Dual Eligible28

MI Health LOC

29

LOC Medicaidbull We have the new pilot program which started on March

1 2015 in Southwest Michigan Region 4 Counties Macomb Wayne and the UP You could see these patients they are dual eligible in the Pilot program in counties surrounding the pilot

bull MHL-LOC 005 (All other Facilities) or LOC 015 (County Care) These residents have to call Michigan Enrolls to dis-enroll toll-free at 1-800-975-7630 (TTY 1-888-263-5897) Monday-Friday from 8 AM to 7 PM Once they dis-enroll they will go to a LOC 02 you have to do a new LOCD

30

Medicaid Redetermination and MHL Enrollmentbull At the time of re-determination for Medicaid financial eligibility the MI

Health Link (MHL) program will not be sending beneficiaries information about this program Beneficiaries who previously opted out will not be passively enrolled according to an email from the MHL staff The MHL staff wrote

bull ldquoThere is currently no MI Health Link enrollment letter sent to beneficiaries when eligibility is re-determined A person who becomes eligible for MI Health Link enrollment may opt-in at any time

bull When Medicaid re-determination takes place the beneficiary remains in the same ICO unless that beneficiary lost Medicaid coverage If the enrollee loses Medicaid coverage and later regains it they are not passively enrolled into MI Health Link The beneficiary may choose to opt back in to the program at that time if desiredrdquo

bull MHL staff did state that about 1500 beneficiaries will be passively enrolled effective January 1 2016 These specific individuals were given normal notice of 60 and 30 days in which to opt-in or opt-out if they so chose No other large scale passive enrollment is scheduled according to the MHL staff 31

MI Health Link Portals

bull Meridian Health Planbull httpwwwmhplancommibull Amerihealthbull httpwwwamerihealthcaritasvipcarepluscomproviderself-service-

toolsindexaspxbull AetnaCoventrybull httpwwwaetnabetterhealthcomMichiganprovidersportalbull Molinabull httpwwwmolinahealthcarecommembersmien-usmemPageshomeaspxbull HAPMidwestbull httpswwwmidwesthealthplancomLoginaspxbull FidelisCentenebull wwwfidelissccommmp 32

MI Health Authorizationsbull We need to watch these authorization that the plans are giving us for the MI

Health program Some plans are assigning a diagnosis for residents in their prior authorizations They are assigning diagnosis that the residents do not even have You need to make sure these are correct diagnosis and if not you need to work with the case managers of the plans to fix the issue The authorization numbers do change

bull Make sure that any resident that is in a MI Health plan that you have a prior authorization All plans are giving different periods authorizing the residents stay in the facility You need to set up a system to make sure you always have a authorization for the period of time you are rendering the service Here is an example of time frame of authorizations

bull Meridian is authorizing 12 monthsbull Aetna is authorizing 3 monthsbull Molina is authorizing 6 monthsbull The authorization numbers need to go on your claims to the payer You need to

put the authorizations in your software and track the dates

33

MI Health Issuesbull We are seeing some issues with MI Health where the resident does not have the correct LOC or it shows

up correct on CHAMPS but ancillary providers such as Dentist and such cannot see it I think we still have some issues with the information crossing between Bridges DHS system CMS and CHAMPS It in return is creating some access of care issues If it is a true LOC issues Facilities with LOC issues need to submit the Medicaid ID numbers to the MSA-MHL-EnrollmentMichigangov box with the subject line Nursing home LOC Issue so they may work to resolve the issues

bull If it becomes an access to care issue email the information to INTEGRATEDCAREmichigangov Remember in these emails only send the Medicaid ID and explain the situation The State will work with the plans to try to fix the process or improve the process

bull We are also seeing with new admission with LOC 015 or 005 that the plans are stating they have 14 days to authorize admission These are resident in the emergency room and possibly be admitted to you for Rehab The hospital will not keep the resident in ER for 14 days and you cannot admit the resident until you have a prior authorization I would recommend when you are told this by the plan that you need to ask to speak to a manager We will have to work through this

bull Ancillary Provider You need to work with your ancillary providers such as Lab Pharmacy X-Ray Physician and such to get the to be credentialed with the plans We are hearing that some of the pharmacies are not participating with the plans this will create issues for you so I would continue to ask these groups to participate

34

LOC 02 dropping MI Health Issuesbull The passive enrollments have occurred in Macomb amp Wayne for

Medicaid dual eligible We are having the same issue we did as in the Southwest MI amp UP with the passive enrollments I am starting to hear from facilities who are checking there CHAMPS member screens that those residents that have opted out (some residents not all) have lost there 02 Make sure you are checking your CHAMPS member screen both for those that were passively enrolled and those that might have lost there 02 Medicaid that opted out

bull Facilities with LOC issues need to submit the Medicaid ID numbers to the (Only MI Health)MSA-MHL-Enrollmentmichigangov box with the subject line Nursing home LOC Issue so they may work to resolve the issues

35

PPA Offset

bull There are no co-pays deductibles or premiums in MI Health Link so there should be no need to offset the PPA with code 25 MI Health Link enrollees can continue to offset their PPA for non-program covered medical expenses (like Vision-Code 27 Dental-Code 28 and Hearing-Code 26) and use the appropriate codes to offset the PPA when billing the health plan for nursing facility services

bull Resident pay PPA when MedicareMedicaid coinsurance

36

LOCDbull Nursing Facility Level of Care Determination (NFLOCD)

bull The MI Health Link health plan will be responsible for conducting the Michigan Medicaid NFLOCD tool for enrollees seeking admission to a nursing facility For existing residents at the time of enrollment the existing NFLOCD will be adopted for capitation payment purposes The health plan will complete a new NFLCOD tool within the first 90 days of enrollment If a nursing facility resident is disenrolled from MI Health Link the nursing facility will be responsible for conducting a new NFLOCD tool in accordance with published Medicaid policy

37

MI Health Issues-New

bull INTEGRATEDCAREmichigangov

bull Email with Insurance Plan issues Case Manager Issues

38

ACOWhat are they

39

Families Receiving Letters for ACO

40

ACO What is It

bull Whats an ACObull Accountable Care Organizations (ACOs) are groups of doctors hospitals

and other health care providers who come together voluntarily to give coordinated high quality care to their Medicare patients

bull The goal of coordinated care is to ensure that patients especially the chronically ill get the right care at the right time while avoiding

unnecessary duplication of services and preventing medical errorsbull When an ACO succeeds both in delivering high-quality care and

spending health care dollars more wisely it will share in the savings it achieves for the Medicare program

41

Payroll Based JournalMandatory on July 1 2016Internet Explorer Version

Internet Explorer v 10 and v 11 will need to operate in compatibility mode

42

43

If you submit data manually should you also submit it through the XML

bull Now you have three options

bull Submit Manually only

bull Submit through the XML only

bull You are able to submit manually and using the XML

44

45

Staffing Submission Frequently Asked Questions

bull ldquoWho are direct care staffrdquo (Who do we submit data for)bull Submission of data for contract staffbull Medical directors and consultantsbull Staff switching roles or tasks throughout the daybull Hours paid vs hours worked ndash Must be verifiablebull Public postingQuality MeasuresFive Starbull Enforcementbull Voluntary submission risks (noneSo register now)

CMS defines

bull 37 job title codes that are required to match employees to the number of hours each direct care function was performed It is important to work with your teams to define the workers that contribute to each job type and how those daily worked hours are recorded and converted to a PBJ submission

bull The PBJ does include some more specific job descriptions than the 671 For example the PBJ system includes job descriptions for RNs with administrative duties and LPNs with administrative duties versus the 671rsquos more general ldquoNurses with Administrative Duties

Page 46

47

PBJ Medical Director Rolebull Physician Leadership

bull Help the facility ensure that patients have appropriate physician coverage and ensure the provision of physician and health care practitioner services and

bull Help the facility develop a process for reviewing physician and health care practitioner credentials

bull Provide specific guidance for physician performance expectations

bull Help the facility ensure that a system is in place for monitoring the performance of health care practitioners and

bull Facilitate feedback to physicians and other health care practitioners on performance and practices

bull Patient Care - Clinical Leadership

bull Participate in administrative decision-making and the development of policies and procedures related to patient care

bull Help develop approve and implement specific clinical practices for the facility to incorporate into its care-related policies and procedures including areas required by laws and regulations

bull Develop procedures and guidance for facility staff regarding contacting practitioners including information gathering and presentation change in condition assessment and when to contact the medical director

bull Review consider andor act upon consultant recommendations as appropriate that affect the facilitys resident care policies and procedures or the care of an individual resident

bull Review respond to and participate in federal state local and other external surveys and inspections and

bull Help review policies and procedures regarding the adequate protection of patients rights advance care planning and other ethical issues48

PBJ Medical Director Rolebull Quality of Care

bull Help the facility establish systems and methods for reviewing the quality and appropriateness of clinical care and other health-related services and provide appropriate feedback and

bull Participate in the facilitys quality improvement process

bull Advise on infection control issues and approve specific infection control policies to be incorporated into facility policies and procedures

bull Help the facility provide a safe and caring environment

bull Help promote employee health and safety and

bull Assist in the development and implementation of employee health policies and programs

bull Education Information and Communication

bull Promote a learning culture within the facility by educating informing and communicating

bull Provide information to help the facility provide care consistent with current standards of practice (defined as approaches to care procedures techniques and treatments that are based on research and or expert consensus and that are contained in current manuals textbooks and or publications or that are accepted adopted or promulgated by recognized organizations or national bodies)

bull Help the facility develop medical information and communication systems with staff patients and families and others

bull Represent the facility to the professional and lay community on medical and patient care issues

bull Maintain knowledge of the changing social regulatory political and economic factors that affect medical and health services of long term care patients and

bull Help establish appropriate relationships with other health care organizations

49

Dietician

bull When the dietary or food services supervisor is other than a registered dietitian the supervisor shall receive routine consultation and technical assistance from a registered dietitian (RD) Consultation time shall not be less than 4 hours every 60 days Additional consultation time may be needed based on the total number of patients incidence of nutrition-related health problems and food service management needs of the facility

50

Pharmacy Consultant

bull At least once per month a licensed pharmacist must perform a drug regimen review (DRR) for each resident The pharmacist must report any irregularities to the attending physician or director of nursing Furthermore these reports must be acted upon

51

What are the names for the Medicare Numberbull OSCAR -Online Survey Certification and Reporting

bull PTAN-PTAN number is assigned by Medicare to authenticate the provider when using the local Medicare Administrative Contractorrsquos (MAC) self-help tools like the IVR internet portal on-line application status etc Provider Transactions Access Number

bull CCN- CMS Certification Number

bull Medicare Number- example 23-

bull All of the above mean the same thing

52

QTSO

bull Once you are logged in the QTSO site bull You will have a state login to the site to access the various site specific

to your facilitybull Installing you will need administrator rights to your network

53

Medicare UpdateWhat are we seeing

54

CMS Final Rule On Returning Credits

httpswwwfederalregistergovarticles201602122016-02789medicare-program-reporting-and-returning-of-overpayments

55

Over Payment Rule

bull Medicare payments for non covered services

bull Medicare payments in excess of the allowable amount for an identified covered service

bull Errors and non reimbursable expenditures in cost reportsbull Duplicate payment

bull Receipt of Medicare payments when another payor had the primary responsibility for payment

56

Questions to MAC

bull Does the Medicare credit balance report change with this overpayment rule

bull No Medicare Credit Balances are still required at the end of each quarter

bull Will that still be the communication to let CMS or the MAC know that we have received an overpayment

bull Submission of Medicare Credit Balance is one form of communicating overpayments to CMS Other methods include submitting a voluntary refund with required claim information or the submission of a standard overpayment form

57

Questions to MAC

bull Will the MAC still deduct from a future RAbull If the recovery of the overpayment includes adjusting a claim then

the overpayment would be netted against future claims payments and reflected on the RA

bull Or will that process change with this new rulebull Process will remain the samebull Will NGS send communication out on thisbull Yes NGS will communicate this once the final rule is communicated

to the MACs by CMS However this could change depending on final CMS instructions

58

Final Rule on Returning Credits

bull Providers will want to immediately update their current policies governing overpayments in order to comply with this new rule which will take effect on March 14 2016

bull Providers and suppliers are required to use reasonable diligence to investigate credible information regarding overpayments through both proactive compliance efforts and reactive investigations

bull If an overpayment is identified then it must be repaid within 60 days An overpayment is identified when a person has or should have through the exercise of reasonable diligence determined that the person received an overpayment and quantified the amount

bull Providers and suppliers have a maximum of 8 months to report and return overpayments ndash up to 6 months to investigate and quantify the overpayment (ie to identify it) and up to 60 days to report and return the overpayment

59

Final Rule on Returning Credits

bull Providers and suppliers are required to report and return all overpayments within a 6-year lookback period

bull The cause and amount of the overpayment is irrelevant for the determination eg it was due to a mistake it was someone elsersquos fault it is a minor amount An overpayment is an overpayment and must be returned

bull Providers and suppliers must make their own determination to which entity to report and return the overpayment ie to the Medicare contractor or using the OIG Self Disclosure Protocol or the CMS Self Referral Disclosure Protocol

60

Final Rule on Returning Credits

bull Providers and suppliers may use the claims adjustment credit balance self-reported refund process or another appropriate process to report and return overpayments At this time there is no standard refund form to use

bull Failure to report and return an overpayment could subject the provider or supplier to False Claims Act liability Civil Monetary Penalties Law liability and exclusion from federal health care programs

61

P S amp R-Accountants will be asking for this information

The location you login into has changed it is now on EIDM EIDM is the acronym for CMS Enterprise Identity Management system which includes Identity Verification Access Management Authorization Assistance Workflow Tools and Identity Lifecycle Management functions

httpswwwcmsgovResearch-Statistics-Data-and-SystemsCMS-Information-TechnologyIACSCMS-Applications-Loginhtml

Go down the page and click on the PSampRSTARThis will take you to the login pagewill look the same as the old P S amp R didChanges Affecting PSampR System Access (Please Read) (posted 01292015)(Updated 5262015)is changingThe system which controls your PSampR user ID (currently IACS)The new system is referred to as EIDMThis will result in a different way to create new accounts or change passwords to existing accountsIf you already have an account in EIDM you may have to use that account for accessing PSampR after the transitionWhen is the change effectiveJune 13 2015What is staying the sameThe internet address for accessing PSampR remains the sameThe PSampR systemfunctionality is NOT changing 62

Medicare Advantage Payorsbull Medicare Advantage payors are pullingdenying payments on admissions if the patient was readmitted within 30 days after discharge The

client believes that the payors systematically denying payments for all readmissions within 30 days They believe this practice denies them due process to address whether the readmissions were justified and not due to a premature discharge of patient The payors seem to want to act like a QIO without having the same accountabilities of the QIO related to determinations of non-payment

bull Heres the QIO process under section 4240 of the QIO Manualbull 4240 - Readmission Review - (Rev 2 07-11-03)bull Readmission review involves admissions to an acute general short-term hospital occurring less than 31 calendar days from the date of

discharge from the same or another acute general short-term hospital (see sect1154(a)(13) and 42 CFR 47671(a)(8)(ii)) Neither the day of discharge nor the day of admission is counted when determining whether a readmission has occurred

bull A Medical Review Proceduresbull Obtain the appropriate medical records for the initial admission and readmission Perform case review on both stays Analyze the cases

specifically to determine whether the patient was prematurely discharged from the first confinement thus causing readmission Perform an analysis of the stay at the first hospital to determine the cause(s) and extent of any problem(s) (eg incomplete or substandard treatment) Consider the information available to the attending physician who discharged the patient from the first confinement Do not base a determination of a premature discharge on information that the physician or provider could not have known or events that could not have been anticipated at the time of discharge

bull Review both the initial admission and the readmission at the same time unless one of them has previously been reviewed In these cases use at a minimum the PRAF case summary of the other admission in addition to the medical record of the case under review

bull C Denialsbull Deny readmissions under the following circumstancesbull If the readmission was medically unnecessarybull If the readmission resulted from a premature discharge from the same hospital orbull If the readmission was a result of circumvention of PPS by the same hospital (see sect4255)bull With the QIO process there is an appeal within the QIO here the hospital is getting no opportunity to challenge the denials

63

Medicare Provider Enrollment Feebull Provider Enrollment Application Fee Amount for CY 2016bull On December 3 CMS issued a notice Provider Enrollment Application

Fee Amount for CY 2016 [CMSndash6066ndashN] Effective January 1 2016 the CY 2016 application fee is $554 for institutional providers that are

bull Initially enrolling in the Medicare or Medicaid program or the Childrens Health Insurance Program (CHIP)

bull Revalidating their Medicare Medicaid or CHIP enrollmentbull Adding a new Medicare practice locationbull This fee is required with any enrollment application submitted from

January 1 through December 31 2016

64

Medicare MAC-Higlas

bull Effective 142016 CMS has implemented a change to begin netting (offsetting) provider money across workloads within a single organization What this means is that any related providers conducting business in two different workloads (example New York and Maine) will have their money applied to any account receivables (AR) with a remaining balance owed to Medicare within both workloads For example Provider ABC is located in New York and is scheduled to receive a payment of $1000 on todays remittance advice Provider XYZ is related to provider ABC but is located in Maine and has ARs with a balance owed of $200 Provider ABCs $1000 payment will have the $200 applied against provider XYZs ARs resulting in a net payment of $800 This will be reflected on the remittance advice by the same PLB code as seen today for offsets for the $200

65

Two Midnight RuleChange January 1 2016 httpswwwcmsgovMedicareMedicare-Fee-for-Service-PaymentHospitalOutpatientPPSHospital-Outpatient-Regulations-and-Notices-ItemsCMS-1633-FChtml

66

Two Midnight Rulebull However effective January 1 2016 CMS will allow exceptions to the

Two-Midnight Benchmark to be determined on a case-by-case basis by the physician responsible for the care of the beneficiary subject to medical review Said differently Part A payment may be appropriate in some circumstances even though there is no expectation by the physician (or qualified ordering practitioner) of a two-midnight stay and one of the two pre-existing categorical exceptions (CMS ldquoinpatient onlyrdquo list and newly initiated mechanical ventilation) does not apply CMS has indicated that this change to the Two Midnight Rule is in response to stakeholder concern and CMSrsquos continued efforts to develop the most appropriate standard for determining Medicare Part A payment

67

Two Midnight Rulebull A new 42 CFR sect4123(a) provides that a patient is considered an

inpatient of a hospitalhellipif formally admitted as an inpatient pursuant to an order for inpatient admission by a physician or other qualified practitionerhellip The physician orders inpatient status when he or she expects the patient to require a stay that crosses at least 2 midnights[10] Stays expected to be shorter than at least two midnights are generally inappropriate for inpatient admission and inpatient payment under Medicare Part A unless the surgical procedure is specified by Medicare as inpatient only under sect41922(n)[11] The physicians expectationhellipshould be based on such complex medical factors as patient history and comorbidities the severity of signs and symptoms current medical needs and the risk of an adverse event[12] The physician order is part of physician certification of the medical necessity of hospital inpatient serviceshellip[13]

68

InPatient Vs Observation Conthellip

bull Physician certification which begins with an order for inpatient admission requires the physician to certify the reasons for the hospitalization the estimated time the patient will remain in the hospital and plans for post-hospital care if appropriate[14] The certification must be completed signed and documented in the medical record prior to discharge[15]

bull A physicians admission order has no presumptive weight and both the admission order and the physician certification will be evaluated in the context of the evidence in the medical record[16] CMS intends to provide additional information about what evidence in the medical record means in future instructions and manual revisions[17]

69

Two Midnight Rulebull Although the new case-by-case exception appears to be inherently

subjective to a certain extent CMS states that the following factors (among others) would be relevant to determining whether a patient requires inpatient admission under the expanded policy

bull The severity of the signs and symptoms exhibited by the patient bull The medical predictability of something adverse happening to the patient

and bull The need for diagnostic studies that appropriately are outpatient services

(that is their performance does not ordinarily require the patient to remain at the hospital for 24 hours or more)

bull CMS also notes that an inpatient admission (and Part A payment) should be ldquorare and unusualrdquo for minor surgical procedures or other treatment that is expected to keep the patient in the hospital ldquofor only a few hoursrdquo or for a period of time that ldquodoes not span at least overnightrdquo (thus a subset of stays not meeting the Two Midnight Benchmark) CMS indicates that such cases will be prioritized for medical review

70

Health Data Insights amp Medicare Plus Blue

RAC (Retrospective Audits)

71

HDI Health Data amp Med Plus Blue

bull httpwwwhealthdatainsightscombull Blue Cross Medicare Advantage Auditsbull Facilities seeing 10 to 15 requests for Medical Recordsbull In January amp Feburarybull Selected Health Data Insights because they were a premier Audit

Vendor for CMS Recovery Audit Contractor (RAC) demonstration Project They are a audit vendor for Humana

bull Providers not sending Medical Record will get technical denial and lose payments

72

Health Data InSight

bull In 2010 they began the Hospital Reviewbull Medicare Advantage encounter datandashCMS oversight of data integrity OIG

2016bull We will review CMSs oversight of MA encounter data validation and assess

the extent to which CMSrsquos Integrated Data Repository contains timely valid and complete MA encounter data In 2012 CMS began collecting from MA organizations a more comprehensive set of encounter data reflecting the items and services provided to MA plan enrollees Prior CMS and OIG audits have indicated vulnerabilities in the accuracy of data reporting by MA organizations Realizing the potential benefits of the MA encounter data for payment and program integrity oversight is contingent upon the datarsquos completeness validity and timeliness (OEI 03-15-00060 expected issue date FY 2017)

73

Pepper Reports

bull httpswwwpepperresourcesorg

bull Program for Evaluating Payment Patterns Electronic Report ( PEPPER)

bull Annually on or about April 18 2016 will be released

bull Pepper Portal httpssecurefiletmforg

74

CGI Technologies and Solutions Inc httpracbcgicomContactInfoaspxst=1

bull Indiana bull Michiganbull Minnesotabull Illinoisbull Kentuckybull Ohiobull Wisconsin CGI Technologies and Solutions Incbull For general and administrative questions regarding client service outreach

quality assurance or project-specific issues contactbull 1877316RACB (7222)bull Email racbcgicom Tamara Tate Tamaratatecmshhsgovbull 4107861288

75

CGI Federal RAC

bull CGI Federal RAC Region Bbull Email racbcgicombull Phone 1-877-316-RACB (7222)bull Mailing Addressbull Send medical records as followsbull Medical records for Indiana Illinois Kentucky Michigan Ohio Wisconsin

Minnesota DME and Home Health CGI Federal Inc Attn RACB Imaging Dept 1001 Lakeside Ave Suite 800 Cleveland OH 44114

bull If submitting paper records please send medical records as follows For Therapy Reviews CGI Federal Inc Attn RACB Imaging 1001 Lakeside Avenue Suite 800 Cleveland OH 44114

76

How to survive RAC Audit

bull National health expenditures totaled $1679 Billion in 2003 bull National health expenditures were 153 of GROSS Domestic Product

(GDP) in 2003 bull Health care cost increasing at +9 per year bull Doomsday predictions of Medicare running out bull Congressional Action

77

RAC Audits

bull Medicare Modernization Act (MMA) of 2003Mandated a three year audit demonstration project 2005-2008

bull Appoint audit contractors to review Medicare billings for proper coding DRG assignment and medical necessity

bull Audits will apply to all health care providers (hospitals physicians homecare dme etc)

bull Audit contractors to be paid on a contingency basis a percentage of overpayments recovered

78

How Did we get here

bull Overpayments collected due to errors in Medically Unnecessary Services ndash 40

bull Incorrectly Coded ndash 35

bull Other ndash 17

bull NoInsufficient Documentation ndash 8

79

Where are we now

bull All RACrsquos completed required provider outreachAccess to Medicare billing data base given to all RAC RAC review methodology

bull Automated Review-Black amp White Issues (current) bull DRG Validation-complex review (current) bull Complex Review for coding errors (current) bull DME Medical Necessity Reviews ndashcomplex review (calendar year

2010) bull Medical Necessity Reviews-complex review (calendar year 2010)

80

RAC Reviews

bull Responsibilities of the Team Leader bull Must learn each insurance provider participating in a RAC or RAC type

program bull What are their operating rulesbull What is their appeal process Time limits

May be different process for each insurance provider bull Develop a response team

Identify who does what when why and alternate bull individual

Build and develop a manual process Review of computerized system

81

Priority Health SCIO Health Analytics

bull httpswwwsciohealthanalyticscomcore-capabilitiespayment-integrityfacility-auditsskilled-nursing-facility-audits

bull Claims for Medicare members treated at Skilled Nursing Facilities are reimbursed based on the patientsrsquo RUG (Resource Utilization Group) score which is determined using the Minimum Data Set (MDS) Using SCIOs robust analytics claims andor providers that merit review are selected for audit SCIOs auditors conduct a detailed review of the complete medical record and associated MDS to determine if the billed RUG score is valid In the event the review determines that an incorrect RUG score was billed SCIOreg provides the valid score reports the reason the change was necessary and calculates the resulting overpayment

82

+ Cheer

Onward and Upward she shall prevail We are here to care for the residents and provide a wonderful

service

13 83

84

References

bull Priority Healthbull Blue Crossbull Medicaidbull Medicare

85

  • Medicare Mange Care amp Medicaid Changes in the New World We Live In
  • Medicaid
  • NEW Medicaid Change MIlogin
  • Blueprint for Health Innovation MI
  • Provider Enrollment Electronic Signature Form Submission Process MSA 15-54
  • Provider Enrollment Electronic Signature Form Submission Process
  • Provider Enrollment Domain Administrator
  • Medicaid Coinsurance Medicare Advantage
  • Slide Number 9
  • Lawsuit DHS Changes on Caregivers
  • TPL Medicaid Change
  • CHAMPS Member Screen
  • LOC dropping off Not Due to MI Health
  • Issues
  • Secure Email Information
  • Medicaid amp Hospice
  • Medicaid
  • Medicaid Medicare Buy In
  • Manage Medicaid
  • Healthy Michigan Residents
  • Healthy Michigan Medicaid Days
  • McLaren Health Plan
  • Manage Medicaid Plans January 1
  • Slide Number 24
  • MI Health Link
  • MI Health Link 2565
  • What are the Names
  • MI Health Dual Eligible
  • MI Health LOC
  • LOC Medicaid
  • Medicaid Redetermination and MHL Enrollment
  • MI Health Link Portals
  • MI Health Authorizations
  • MI Health Issues
  • LOC 02 dropping MI Health Issues
  • PPA Offset
  • LOCD
  • MI Health Issues-New
  • ACO
  • Families Receiving Letters for ACO
  • ACO What is It
  • Payroll Based Journal
  • Slide Number 43
  • If you submit data manually should you also submit it through the XML
  • Staffing Submission Frequently Asked Questions
  • CMS defines
  • Slide Number 47
  • PBJ Medical Director Role
  • PBJ Medical Director Role
  • Dietician
  • Pharmacy Consultant
  • What are the names for the Medicare Number
  • QTSO
  • Medicare Update
  • CMS Final Rule On Returning Credits
  • Over Payment Rule
  • Questions to MAC
  • Questions to MAC
  • Final Rule on Returning Credits
  • Final Rule on Returning Credits
  • Final Rule on Returning Credits
  • Slide Number 62
  • Medicare Advantage Payors
  • Medicare Provider Enrollment Fee
  • Medicare MAC-Higlas
  • Two Midnight Rule
  • Two Midnight Rule
  • Two Midnight Rule
  • InPatient Vs Observation Conthellip
  • Two Midnight Rule
  • Health Data Insights amp Medicare Plus Blue
  • HDI Health Data amp Med Plus Blue
  • Health Data InSight
  • Pepper Reports
  • CGI Technologies and Solutions Inc httpracbcgicomContactInfoaspxst=1
  • CGI Federal RAC
  • How to survive RAC Audit
  • RAC Audits
  • How Did we get here
  • Where are we now
  • RAC Reviews
  • Priority Health SCIO Health Analytics
  • Cheer
  • References
Page 7: Medicare, Mange Care & Medicaid Changes in the New World we live in

Provider Enrollment Domain Administrator

bull Electronic Signature Agreement Form bull To obtain the required information mandated under 42 CFR 455104 any

provider wishing to appoint another person access to their CHAMPS information must submit an Electronic Signature Agreement form (DCH-1401) and the Electronic Signature Agreement form cover sheet (MDHHS-5405) The two completed forms must be submitted to the MDHHS Medicaid Provider Enrollment Unit for processing MDHHS recommends the provider retain a copy of these forms for their records

bull The Electronic Signature Agreement form is also being updated to include additional language certifying the enrolled provider understands he or she is liable and bound by all information submitted on his or her behalf

7

Medicaid Coinsurance Medicare Advantage

bull Attention Nursing Facility Medicaid Fee for Service Providers

bull As part of the December 11 2015 CHAMPS system update the final phase of the Medicare Advantage Coinsurance Pricing Logic was implemented For claim dates of service 2010 and prior please refer to the Medicaid Provider Manual under General Information for Providers Chapter Section 124 Provider Returning Overpayments

bull For claim dates of service 2011 and forward MDHHS will be initiating the claim adjustment within the next few weeks Providers with further questions can contact Provider Support by phone 1-800-292-2550 or email ProviderSupportmichigangov

8

The State has been paying the wrong coinsurance amount for Medicare Advantage since 2008 Per below they will be doing a claim adjustment in the next few weeks for dates of service 2011 going forward If you have refunded the State by a check watch and make sure they do not double recover the money If they do you will have to get your check and list of people you refunded and send it to providersupportmichigangov They have stated they have fixed the pricing logic to pay it correctly going forward Watch and make sure they are paying the correct amount if not you will have to again pull the information from the coinsurance payer and send it to providersupportmichigangov

For dates of service prior to 2011 you will have to return the Money per the Medicaid manual

Medicaid providers performing self audits may discover an overpayment situation and wish to return theMedicaid overpayment to MDHHS This process should only be used when the provider is unable to claimadjust or it is not practical to claim adjust Sending in a check will not correct the underlying claim(s)data Providers must

10487071048707 Document why the money is being returned (ie provider self audit) and identify provider NPIinformation address dates of service and specialty area (ie durable medical items pharmacyphysician practice hospital etc) and include a basic information letter

10487071048707 Attach an excel spreadsheet document with the Tax ID billing NPIs and associated amounts (ifmultiple IDs exist for the entity) for the MDHHS Accounting Office to apply credit to

10487071048707 Make check payable to State of Michigan and mail to the MDHHSCashierrsquos Unit - Attn Bureauof Finance-MCU (Refer to the Directory Appendix for contact information) 9

Lawsuit DHS Changes on Caregivers

bull A recent Michigan Court of Appeals decision has played havoc on the rules surrounding payments to non-family caregivers DHS rules regarding payments to caregivers state that payments are divestment in two situations 1) prospective payments made to any caregiver (family or non-related) before care is provided and 2) payments to family caregivers absent a Medicaid qualified caregiving contract The Court of Appeals decision Jensen v Department of Human Services confuses the rules and applies the family caregiving contract requirements to all caregivers even professional caregiving agencies The result of the case is that payments to non-family caregivers may be divestment unless the Medicaid applicant has a contract with the caregiver meeting the extremely specific rules found in the Medicaid manual

10

TPL Medicaid Changebull Attention Providersbull Effective October 26 2015 the MDHHS Third Party Liability (TPL)

Update Other Insurance Now Online form will be updated You will now receive a confirmation number when you submit your request If an email address is added within the Requestor Information section once TPL completes your request you will receive an email with the confirmation number and the status of your request Please allow up to 10 business days for information to be verified and updated in the system Please check your spam or junk email folders if you do not receive the email after 10 business days

bull Providers with further questions can contact Provider Support by phone 1-800-292-2550 or email ProviderSupportmichigangov

bull httpsminotifytplstatemiustedpubliccoveragerequestsindex11

CHAMPS Member Screen

bull Attention Providersbull Effective September 25 2015 a change was made to the CHAMPS

system This change modified the provider view for the Member Eligibility Inquiry screen If a member no longer has active Medicaid the hyperlink to view ldquoCommercialOtherrdquo Third Party Liability (TPL) information is disabled Because TPL does not always maintain TPLOther Insurance information for members that do not have active Medicaid coverage this information was disabled to prevent inaccurate information from being reported

12

LOC dropping off Not Due to MI Health

bull If after 30 days the county hasnrsquot processed the 2565 that you have send via the central scan (517-346-9888) AND other methods you choose to use you can email the 2565 to ArdeneMartin

bull At the following mailbox I ask that you put the beneficiaries name in the subject line

bull MSA2565michigangov

13

Issues

bull PPA going all over the place

bull LOC 02 dropping off not related to MI Health

bull LOCD tons of money written off

bull Must check CHAMPS member screen all the time and you must check pending

14

Secure Email Information

bull The State of Michigan asked me to remind you when you are communicating with them regarding residents to not send Resident names Birthdates or Social security numbers in those emails What you send is the Medicaid ID and they can look it up Or if it is a billing issue send them the TCN and the Medicaid ID We have been in the practice of emailing DHS Ardene Martin Integrated Health and Provider Support with all the resident name and such

15

Medicaid amp Hospicebull LOC 07 Manage Medicaid Hospice included so plan would pay

provider and not switch to a LOC 16

bull LOC 02 Medicaid (Regular Medicaid) Hospice not included so switch to 16 Hospice and Hospice pays provider

bull LOC 11 Healthy Michigan is included in plan so plan would pay provider and not switch to LOC 16

bull LOC 005 amp 015 MI Health is up in the air waiting for CMS Currently Hospice is now included

bull LOC 16 is Hospice when they switch from Regular Medicaid only and Hospice pays provider

16

Medicaidbull Going forward please make sure that your Champs ID amp NPI on your member screen matches your facility CHAMPS ID

amp NPI for each resident and matches for all new admissions or new approved Medicaid going forward

bull The edit will be turned on soon to stop the payment of these claims if the CHAMPS ID and NPI do not Match your facility on the Medicaid member screen

bull Make sure you are putting the information correct on the 2565 you send in to DHS

bull 1 I attached a 2565 When you fill this out for new people make sure in box 12 a you put your NPI and 12 b you put your CHAMPS ID This will help the DHS case workers assign the person to your facility

bull 2 I would check all your residents CHAMPS member screens and make sure the NPI and CHAMPS ID are your facilities If not you will have to work with the DHS worker to fix this The DHS worker is the only one that can fix this

bull 3 We are having some issues where the DHS case workers will not change this NPI and CHAMPS ID to your facilities You have to get them to change it or you just will not get paid

bull 4 We situations where the resident is in a facility in Kent County (as an example) but the family lives in Livingston County and completes the applications in Livingston County You will have to get the DHS worker in Livingston to fix it not the local DHS worker in Kent County where your facility is

17

Medicaid Medicare Buy Inbull Based on the information from the Office of Personnel Management Federal

Employeersquos employed as of January 1 1983 are eligible for Medicare Part A(see page 5 of attached document) This was also confirmed with our Social Security liaison If the beneficiary did not retire before 1983 he can enroll in Medicare Part B and pay the premium and then he can enroll in Medicare Part A and pay that premium as well or may qualify for Medicare Buy in of Part A

bull If a beneficiary has an SSA document stating they are not eligible for Medicare as they do not have enough work credits the beneficiarybeneficiary representative needs to go to SSA and let them know that while they know they are not eligible for Medicare Part A free or reduced however they are eligible for Medicare Part B and would like to enroll Once the beneficiary enrolls in Medicare Part B (enrollment period January 1st ndash March 31 each year) and pays the premium then the beneficiary is eligible to either pay for Medicare Part A or that beneficiary may qualify for Medicare Part A buy in through Medicaid Once the beneficiary is enrolled in Medicare Part A and Medicare Part B Medicaid will begin to make payments on claims

18

Manage Medicaid Where are we

19

Healthy Michigan Residents

20

Healthy Michigan Medicaid Days

21

McLaren Health Plan

22

Manage Medicaid Plans January 1bull Region 1 ndash Upper Peninsula Health Planbull Region 2 ndash McLaren Health Plan Meridian Health Plan of Michigan Molina Healthcare of Michigan

UnitedHealthcare Community Planbull Region 3 ndash McLaren Health Plan Meridian Health Plan of Michigan Molina Healthcare of Michigan

UnitedHealthcare Community Planbull Region 4 ndash Blue Cross Complete of Michigan McLaren Health Plan Meridian Health Plan of Michigan Molina

Healthcare of Michigan Priority Health Choice UnitedHealthcare Community Planbull Region 5 ndash McLaren Health Plan Meridian Health Plan of Michigan Molina Healthcare of Michigan

UnitedHealthcare Community Planbull Region 6 ndash Blue Cross Complete of Michigan HAP Midwest Health Plan McLaren Health Plan Meridian Health

Plan of Michigan Molina Healthcare of Michigan UnitedHealthcare Community Planbull Region 7 ndash Blue Cross Complete of Michigan McLaren Health Plan Meridian Health Plan UnitedHealthcare

Community Planbull Region 8 ndash Aetna Better Health of Michigan McLaren Health Plan Meridian Health Plan of Michigan Molina

Healthcare of Michigan Priority Health Choice UnitedHealthcare Community Planbull Region 9 ndash Aetna Better Health of Michigan Blue Cross Complete of Michigan McLaren Health Plan Meridian

Health Plan of Michigan Molina Healthcare of Michigan UnitedHealthcare Community Planbull Region 10 ndash Aetna Better Health of Michigan Blue Cross Complete of Michigan Harbor Health Plan McLaren

Health Plan Meridian Health Plan of Michigan Molina Healthcare of Michigan Total Health Care UnitedHealthcare Community Plan 23

24

MI Health LinkWhere are we

25

MI Health Link 2565

bull This notification is being sent to providers of long term care services including nursing facilities county medical care facilities and hospital long term care units to provide clarification on the process involved with the submission of the Facility Admission Form (MSA-2565-C) for an individual enrolled in the MI Health Link program

bull The MI Health Link program covers the custodiallong term nursing facility service benefit When an individual who is enrolled in the MI Health Link program is admitted to a nursing facility for custodiallong term nursing services a disenrollment from the Integrated Care Organization (MI Health Link health plan) is NOT REQUIRED The Facility Admission Form (MSA-2565-C) should NOT be sent to the Michigan Department of Health and Human Services (MDHHS) Enrollment Services Section for a disenrollment to be processed

26

What are the Names

bull Started as Integrated Health

bull Then called MMP (Medicare Medicaid Program)

bull Duals (Also Known as Duals as in Dual Eligible)

bull Now called MI Health Link

bull Total confusion

27

MI Health Dual Eligible28

MI Health LOC

29

LOC Medicaidbull We have the new pilot program which started on March

1 2015 in Southwest Michigan Region 4 Counties Macomb Wayne and the UP You could see these patients they are dual eligible in the Pilot program in counties surrounding the pilot

bull MHL-LOC 005 (All other Facilities) or LOC 015 (County Care) These residents have to call Michigan Enrolls to dis-enroll toll-free at 1-800-975-7630 (TTY 1-888-263-5897) Monday-Friday from 8 AM to 7 PM Once they dis-enroll they will go to a LOC 02 you have to do a new LOCD

30

Medicaid Redetermination and MHL Enrollmentbull At the time of re-determination for Medicaid financial eligibility the MI

Health Link (MHL) program will not be sending beneficiaries information about this program Beneficiaries who previously opted out will not be passively enrolled according to an email from the MHL staff The MHL staff wrote

bull ldquoThere is currently no MI Health Link enrollment letter sent to beneficiaries when eligibility is re-determined A person who becomes eligible for MI Health Link enrollment may opt-in at any time

bull When Medicaid re-determination takes place the beneficiary remains in the same ICO unless that beneficiary lost Medicaid coverage If the enrollee loses Medicaid coverage and later regains it they are not passively enrolled into MI Health Link The beneficiary may choose to opt back in to the program at that time if desiredrdquo

bull MHL staff did state that about 1500 beneficiaries will be passively enrolled effective January 1 2016 These specific individuals were given normal notice of 60 and 30 days in which to opt-in or opt-out if they so chose No other large scale passive enrollment is scheduled according to the MHL staff 31

MI Health Link Portals

bull Meridian Health Planbull httpwwwmhplancommibull Amerihealthbull httpwwwamerihealthcaritasvipcarepluscomproviderself-service-

toolsindexaspxbull AetnaCoventrybull httpwwwaetnabetterhealthcomMichiganprovidersportalbull Molinabull httpwwwmolinahealthcarecommembersmien-usmemPageshomeaspxbull HAPMidwestbull httpswwwmidwesthealthplancomLoginaspxbull FidelisCentenebull wwwfidelissccommmp 32

MI Health Authorizationsbull We need to watch these authorization that the plans are giving us for the MI

Health program Some plans are assigning a diagnosis for residents in their prior authorizations They are assigning diagnosis that the residents do not even have You need to make sure these are correct diagnosis and if not you need to work with the case managers of the plans to fix the issue The authorization numbers do change

bull Make sure that any resident that is in a MI Health plan that you have a prior authorization All plans are giving different periods authorizing the residents stay in the facility You need to set up a system to make sure you always have a authorization for the period of time you are rendering the service Here is an example of time frame of authorizations

bull Meridian is authorizing 12 monthsbull Aetna is authorizing 3 monthsbull Molina is authorizing 6 monthsbull The authorization numbers need to go on your claims to the payer You need to

put the authorizations in your software and track the dates

33

MI Health Issuesbull We are seeing some issues with MI Health where the resident does not have the correct LOC or it shows

up correct on CHAMPS but ancillary providers such as Dentist and such cannot see it I think we still have some issues with the information crossing between Bridges DHS system CMS and CHAMPS It in return is creating some access of care issues If it is a true LOC issues Facilities with LOC issues need to submit the Medicaid ID numbers to the MSA-MHL-EnrollmentMichigangov box with the subject line Nursing home LOC Issue so they may work to resolve the issues

bull If it becomes an access to care issue email the information to INTEGRATEDCAREmichigangov Remember in these emails only send the Medicaid ID and explain the situation The State will work with the plans to try to fix the process or improve the process

bull We are also seeing with new admission with LOC 015 or 005 that the plans are stating they have 14 days to authorize admission These are resident in the emergency room and possibly be admitted to you for Rehab The hospital will not keep the resident in ER for 14 days and you cannot admit the resident until you have a prior authorization I would recommend when you are told this by the plan that you need to ask to speak to a manager We will have to work through this

bull Ancillary Provider You need to work with your ancillary providers such as Lab Pharmacy X-Ray Physician and such to get the to be credentialed with the plans We are hearing that some of the pharmacies are not participating with the plans this will create issues for you so I would continue to ask these groups to participate

34

LOC 02 dropping MI Health Issuesbull The passive enrollments have occurred in Macomb amp Wayne for

Medicaid dual eligible We are having the same issue we did as in the Southwest MI amp UP with the passive enrollments I am starting to hear from facilities who are checking there CHAMPS member screens that those residents that have opted out (some residents not all) have lost there 02 Make sure you are checking your CHAMPS member screen both for those that were passively enrolled and those that might have lost there 02 Medicaid that opted out

bull Facilities with LOC issues need to submit the Medicaid ID numbers to the (Only MI Health)MSA-MHL-Enrollmentmichigangov box with the subject line Nursing home LOC Issue so they may work to resolve the issues

35

PPA Offset

bull There are no co-pays deductibles or premiums in MI Health Link so there should be no need to offset the PPA with code 25 MI Health Link enrollees can continue to offset their PPA for non-program covered medical expenses (like Vision-Code 27 Dental-Code 28 and Hearing-Code 26) and use the appropriate codes to offset the PPA when billing the health plan for nursing facility services

bull Resident pay PPA when MedicareMedicaid coinsurance

36

LOCDbull Nursing Facility Level of Care Determination (NFLOCD)

bull The MI Health Link health plan will be responsible for conducting the Michigan Medicaid NFLOCD tool for enrollees seeking admission to a nursing facility For existing residents at the time of enrollment the existing NFLOCD will be adopted for capitation payment purposes The health plan will complete a new NFLCOD tool within the first 90 days of enrollment If a nursing facility resident is disenrolled from MI Health Link the nursing facility will be responsible for conducting a new NFLOCD tool in accordance with published Medicaid policy

37

MI Health Issues-New

bull INTEGRATEDCAREmichigangov

bull Email with Insurance Plan issues Case Manager Issues

38

ACOWhat are they

39

Families Receiving Letters for ACO

40

ACO What is It

bull Whats an ACObull Accountable Care Organizations (ACOs) are groups of doctors hospitals

and other health care providers who come together voluntarily to give coordinated high quality care to their Medicare patients

bull The goal of coordinated care is to ensure that patients especially the chronically ill get the right care at the right time while avoiding

unnecessary duplication of services and preventing medical errorsbull When an ACO succeeds both in delivering high-quality care and

spending health care dollars more wisely it will share in the savings it achieves for the Medicare program

41

Payroll Based JournalMandatory on July 1 2016Internet Explorer Version

Internet Explorer v 10 and v 11 will need to operate in compatibility mode

42

43

If you submit data manually should you also submit it through the XML

bull Now you have three options

bull Submit Manually only

bull Submit through the XML only

bull You are able to submit manually and using the XML

44

45

Staffing Submission Frequently Asked Questions

bull ldquoWho are direct care staffrdquo (Who do we submit data for)bull Submission of data for contract staffbull Medical directors and consultantsbull Staff switching roles or tasks throughout the daybull Hours paid vs hours worked ndash Must be verifiablebull Public postingQuality MeasuresFive Starbull Enforcementbull Voluntary submission risks (noneSo register now)

CMS defines

bull 37 job title codes that are required to match employees to the number of hours each direct care function was performed It is important to work with your teams to define the workers that contribute to each job type and how those daily worked hours are recorded and converted to a PBJ submission

bull The PBJ does include some more specific job descriptions than the 671 For example the PBJ system includes job descriptions for RNs with administrative duties and LPNs with administrative duties versus the 671rsquos more general ldquoNurses with Administrative Duties

Page 46

47

PBJ Medical Director Rolebull Physician Leadership

bull Help the facility ensure that patients have appropriate physician coverage and ensure the provision of physician and health care practitioner services and

bull Help the facility develop a process for reviewing physician and health care practitioner credentials

bull Provide specific guidance for physician performance expectations

bull Help the facility ensure that a system is in place for monitoring the performance of health care practitioners and

bull Facilitate feedback to physicians and other health care practitioners on performance and practices

bull Patient Care - Clinical Leadership

bull Participate in administrative decision-making and the development of policies and procedures related to patient care

bull Help develop approve and implement specific clinical practices for the facility to incorporate into its care-related policies and procedures including areas required by laws and regulations

bull Develop procedures and guidance for facility staff regarding contacting practitioners including information gathering and presentation change in condition assessment and when to contact the medical director

bull Review consider andor act upon consultant recommendations as appropriate that affect the facilitys resident care policies and procedures or the care of an individual resident

bull Review respond to and participate in federal state local and other external surveys and inspections and

bull Help review policies and procedures regarding the adequate protection of patients rights advance care planning and other ethical issues48

PBJ Medical Director Rolebull Quality of Care

bull Help the facility establish systems and methods for reviewing the quality and appropriateness of clinical care and other health-related services and provide appropriate feedback and

bull Participate in the facilitys quality improvement process

bull Advise on infection control issues and approve specific infection control policies to be incorporated into facility policies and procedures

bull Help the facility provide a safe and caring environment

bull Help promote employee health and safety and

bull Assist in the development and implementation of employee health policies and programs

bull Education Information and Communication

bull Promote a learning culture within the facility by educating informing and communicating

bull Provide information to help the facility provide care consistent with current standards of practice (defined as approaches to care procedures techniques and treatments that are based on research and or expert consensus and that are contained in current manuals textbooks and or publications or that are accepted adopted or promulgated by recognized organizations or national bodies)

bull Help the facility develop medical information and communication systems with staff patients and families and others

bull Represent the facility to the professional and lay community on medical and patient care issues

bull Maintain knowledge of the changing social regulatory political and economic factors that affect medical and health services of long term care patients and

bull Help establish appropriate relationships with other health care organizations

49

Dietician

bull When the dietary or food services supervisor is other than a registered dietitian the supervisor shall receive routine consultation and technical assistance from a registered dietitian (RD) Consultation time shall not be less than 4 hours every 60 days Additional consultation time may be needed based on the total number of patients incidence of nutrition-related health problems and food service management needs of the facility

50

Pharmacy Consultant

bull At least once per month a licensed pharmacist must perform a drug regimen review (DRR) for each resident The pharmacist must report any irregularities to the attending physician or director of nursing Furthermore these reports must be acted upon

51

What are the names for the Medicare Numberbull OSCAR -Online Survey Certification and Reporting

bull PTAN-PTAN number is assigned by Medicare to authenticate the provider when using the local Medicare Administrative Contractorrsquos (MAC) self-help tools like the IVR internet portal on-line application status etc Provider Transactions Access Number

bull CCN- CMS Certification Number

bull Medicare Number- example 23-

bull All of the above mean the same thing

52

QTSO

bull Once you are logged in the QTSO site bull You will have a state login to the site to access the various site specific

to your facilitybull Installing you will need administrator rights to your network

53

Medicare UpdateWhat are we seeing

54

CMS Final Rule On Returning Credits

httpswwwfederalregistergovarticles201602122016-02789medicare-program-reporting-and-returning-of-overpayments

55

Over Payment Rule

bull Medicare payments for non covered services

bull Medicare payments in excess of the allowable amount for an identified covered service

bull Errors and non reimbursable expenditures in cost reportsbull Duplicate payment

bull Receipt of Medicare payments when another payor had the primary responsibility for payment

56

Questions to MAC

bull Does the Medicare credit balance report change with this overpayment rule

bull No Medicare Credit Balances are still required at the end of each quarter

bull Will that still be the communication to let CMS or the MAC know that we have received an overpayment

bull Submission of Medicare Credit Balance is one form of communicating overpayments to CMS Other methods include submitting a voluntary refund with required claim information or the submission of a standard overpayment form

57

Questions to MAC

bull Will the MAC still deduct from a future RAbull If the recovery of the overpayment includes adjusting a claim then

the overpayment would be netted against future claims payments and reflected on the RA

bull Or will that process change with this new rulebull Process will remain the samebull Will NGS send communication out on thisbull Yes NGS will communicate this once the final rule is communicated

to the MACs by CMS However this could change depending on final CMS instructions

58

Final Rule on Returning Credits

bull Providers will want to immediately update their current policies governing overpayments in order to comply with this new rule which will take effect on March 14 2016

bull Providers and suppliers are required to use reasonable diligence to investigate credible information regarding overpayments through both proactive compliance efforts and reactive investigations

bull If an overpayment is identified then it must be repaid within 60 days An overpayment is identified when a person has or should have through the exercise of reasonable diligence determined that the person received an overpayment and quantified the amount

bull Providers and suppliers have a maximum of 8 months to report and return overpayments ndash up to 6 months to investigate and quantify the overpayment (ie to identify it) and up to 60 days to report and return the overpayment

59

Final Rule on Returning Credits

bull Providers and suppliers are required to report and return all overpayments within a 6-year lookback period

bull The cause and amount of the overpayment is irrelevant for the determination eg it was due to a mistake it was someone elsersquos fault it is a minor amount An overpayment is an overpayment and must be returned

bull Providers and suppliers must make their own determination to which entity to report and return the overpayment ie to the Medicare contractor or using the OIG Self Disclosure Protocol or the CMS Self Referral Disclosure Protocol

60

Final Rule on Returning Credits

bull Providers and suppliers may use the claims adjustment credit balance self-reported refund process or another appropriate process to report and return overpayments At this time there is no standard refund form to use

bull Failure to report and return an overpayment could subject the provider or supplier to False Claims Act liability Civil Monetary Penalties Law liability and exclusion from federal health care programs

61

P S amp R-Accountants will be asking for this information

The location you login into has changed it is now on EIDM EIDM is the acronym for CMS Enterprise Identity Management system which includes Identity Verification Access Management Authorization Assistance Workflow Tools and Identity Lifecycle Management functions

httpswwwcmsgovResearch-Statistics-Data-and-SystemsCMS-Information-TechnologyIACSCMS-Applications-Loginhtml

Go down the page and click on the PSampRSTARThis will take you to the login pagewill look the same as the old P S amp R didChanges Affecting PSampR System Access (Please Read) (posted 01292015)(Updated 5262015)is changingThe system which controls your PSampR user ID (currently IACS)The new system is referred to as EIDMThis will result in a different way to create new accounts or change passwords to existing accountsIf you already have an account in EIDM you may have to use that account for accessing PSampR after the transitionWhen is the change effectiveJune 13 2015What is staying the sameThe internet address for accessing PSampR remains the sameThe PSampR systemfunctionality is NOT changing 62

Medicare Advantage Payorsbull Medicare Advantage payors are pullingdenying payments on admissions if the patient was readmitted within 30 days after discharge The

client believes that the payors systematically denying payments for all readmissions within 30 days They believe this practice denies them due process to address whether the readmissions were justified and not due to a premature discharge of patient The payors seem to want to act like a QIO without having the same accountabilities of the QIO related to determinations of non-payment

bull Heres the QIO process under section 4240 of the QIO Manualbull 4240 - Readmission Review - (Rev 2 07-11-03)bull Readmission review involves admissions to an acute general short-term hospital occurring less than 31 calendar days from the date of

discharge from the same or another acute general short-term hospital (see sect1154(a)(13) and 42 CFR 47671(a)(8)(ii)) Neither the day of discharge nor the day of admission is counted when determining whether a readmission has occurred

bull A Medical Review Proceduresbull Obtain the appropriate medical records for the initial admission and readmission Perform case review on both stays Analyze the cases

specifically to determine whether the patient was prematurely discharged from the first confinement thus causing readmission Perform an analysis of the stay at the first hospital to determine the cause(s) and extent of any problem(s) (eg incomplete or substandard treatment) Consider the information available to the attending physician who discharged the patient from the first confinement Do not base a determination of a premature discharge on information that the physician or provider could not have known or events that could not have been anticipated at the time of discharge

bull Review both the initial admission and the readmission at the same time unless one of them has previously been reviewed In these cases use at a minimum the PRAF case summary of the other admission in addition to the medical record of the case under review

bull C Denialsbull Deny readmissions under the following circumstancesbull If the readmission was medically unnecessarybull If the readmission resulted from a premature discharge from the same hospital orbull If the readmission was a result of circumvention of PPS by the same hospital (see sect4255)bull With the QIO process there is an appeal within the QIO here the hospital is getting no opportunity to challenge the denials

63

Medicare Provider Enrollment Feebull Provider Enrollment Application Fee Amount for CY 2016bull On December 3 CMS issued a notice Provider Enrollment Application

Fee Amount for CY 2016 [CMSndash6066ndashN] Effective January 1 2016 the CY 2016 application fee is $554 for institutional providers that are

bull Initially enrolling in the Medicare or Medicaid program or the Childrens Health Insurance Program (CHIP)

bull Revalidating their Medicare Medicaid or CHIP enrollmentbull Adding a new Medicare practice locationbull This fee is required with any enrollment application submitted from

January 1 through December 31 2016

64

Medicare MAC-Higlas

bull Effective 142016 CMS has implemented a change to begin netting (offsetting) provider money across workloads within a single organization What this means is that any related providers conducting business in two different workloads (example New York and Maine) will have their money applied to any account receivables (AR) with a remaining balance owed to Medicare within both workloads For example Provider ABC is located in New York and is scheduled to receive a payment of $1000 on todays remittance advice Provider XYZ is related to provider ABC but is located in Maine and has ARs with a balance owed of $200 Provider ABCs $1000 payment will have the $200 applied against provider XYZs ARs resulting in a net payment of $800 This will be reflected on the remittance advice by the same PLB code as seen today for offsets for the $200

65

Two Midnight RuleChange January 1 2016 httpswwwcmsgovMedicareMedicare-Fee-for-Service-PaymentHospitalOutpatientPPSHospital-Outpatient-Regulations-and-Notices-ItemsCMS-1633-FChtml

66

Two Midnight Rulebull However effective January 1 2016 CMS will allow exceptions to the

Two-Midnight Benchmark to be determined on a case-by-case basis by the physician responsible for the care of the beneficiary subject to medical review Said differently Part A payment may be appropriate in some circumstances even though there is no expectation by the physician (or qualified ordering practitioner) of a two-midnight stay and one of the two pre-existing categorical exceptions (CMS ldquoinpatient onlyrdquo list and newly initiated mechanical ventilation) does not apply CMS has indicated that this change to the Two Midnight Rule is in response to stakeholder concern and CMSrsquos continued efforts to develop the most appropriate standard for determining Medicare Part A payment

67

Two Midnight Rulebull A new 42 CFR sect4123(a) provides that a patient is considered an

inpatient of a hospitalhellipif formally admitted as an inpatient pursuant to an order for inpatient admission by a physician or other qualified practitionerhellip The physician orders inpatient status when he or she expects the patient to require a stay that crosses at least 2 midnights[10] Stays expected to be shorter than at least two midnights are generally inappropriate for inpatient admission and inpatient payment under Medicare Part A unless the surgical procedure is specified by Medicare as inpatient only under sect41922(n)[11] The physicians expectationhellipshould be based on such complex medical factors as patient history and comorbidities the severity of signs and symptoms current medical needs and the risk of an adverse event[12] The physician order is part of physician certification of the medical necessity of hospital inpatient serviceshellip[13]

68

InPatient Vs Observation Conthellip

bull Physician certification which begins with an order for inpatient admission requires the physician to certify the reasons for the hospitalization the estimated time the patient will remain in the hospital and plans for post-hospital care if appropriate[14] The certification must be completed signed and documented in the medical record prior to discharge[15]

bull A physicians admission order has no presumptive weight and both the admission order and the physician certification will be evaluated in the context of the evidence in the medical record[16] CMS intends to provide additional information about what evidence in the medical record means in future instructions and manual revisions[17]

69

Two Midnight Rulebull Although the new case-by-case exception appears to be inherently

subjective to a certain extent CMS states that the following factors (among others) would be relevant to determining whether a patient requires inpatient admission under the expanded policy

bull The severity of the signs and symptoms exhibited by the patient bull The medical predictability of something adverse happening to the patient

and bull The need for diagnostic studies that appropriately are outpatient services

(that is their performance does not ordinarily require the patient to remain at the hospital for 24 hours or more)

bull CMS also notes that an inpatient admission (and Part A payment) should be ldquorare and unusualrdquo for minor surgical procedures or other treatment that is expected to keep the patient in the hospital ldquofor only a few hoursrdquo or for a period of time that ldquodoes not span at least overnightrdquo (thus a subset of stays not meeting the Two Midnight Benchmark) CMS indicates that such cases will be prioritized for medical review

70

Health Data Insights amp Medicare Plus Blue

RAC (Retrospective Audits)

71

HDI Health Data amp Med Plus Blue

bull httpwwwhealthdatainsightscombull Blue Cross Medicare Advantage Auditsbull Facilities seeing 10 to 15 requests for Medical Recordsbull In January amp Feburarybull Selected Health Data Insights because they were a premier Audit

Vendor for CMS Recovery Audit Contractor (RAC) demonstration Project They are a audit vendor for Humana

bull Providers not sending Medical Record will get technical denial and lose payments

72

Health Data InSight

bull In 2010 they began the Hospital Reviewbull Medicare Advantage encounter datandashCMS oversight of data integrity OIG

2016bull We will review CMSs oversight of MA encounter data validation and assess

the extent to which CMSrsquos Integrated Data Repository contains timely valid and complete MA encounter data In 2012 CMS began collecting from MA organizations a more comprehensive set of encounter data reflecting the items and services provided to MA plan enrollees Prior CMS and OIG audits have indicated vulnerabilities in the accuracy of data reporting by MA organizations Realizing the potential benefits of the MA encounter data for payment and program integrity oversight is contingent upon the datarsquos completeness validity and timeliness (OEI 03-15-00060 expected issue date FY 2017)

73

Pepper Reports

bull httpswwwpepperresourcesorg

bull Program for Evaluating Payment Patterns Electronic Report ( PEPPER)

bull Annually on or about April 18 2016 will be released

bull Pepper Portal httpssecurefiletmforg

74

CGI Technologies and Solutions Inc httpracbcgicomContactInfoaspxst=1

bull Indiana bull Michiganbull Minnesotabull Illinoisbull Kentuckybull Ohiobull Wisconsin CGI Technologies and Solutions Incbull For general and administrative questions regarding client service outreach

quality assurance or project-specific issues contactbull 1877316RACB (7222)bull Email racbcgicom Tamara Tate Tamaratatecmshhsgovbull 4107861288

75

CGI Federal RAC

bull CGI Federal RAC Region Bbull Email racbcgicombull Phone 1-877-316-RACB (7222)bull Mailing Addressbull Send medical records as followsbull Medical records for Indiana Illinois Kentucky Michigan Ohio Wisconsin

Minnesota DME and Home Health CGI Federal Inc Attn RACB Imaging Dept 1001 Lakeside Ave Suite 800 Cleveland OH 44114

bull If submitting paper records please send medical records as follows For Therapy Reviews CGI Federal Inc Attn RACB Imaging 1001 Lakeside Avenue Suite 800 Cleveland OH 44114

76

How to survive RAC Audit

bull National health expenditures totaled $1679 Billion in 2003 bull National health expenditures were 153 of GROSS Domestic Product

(GDP) in 2003 bull Health care cost increasing at +9 per year bull Doomsday predictions of Medicare running out bull Congressional Action

77

RAC Audits

bull Medicare Modernization Act (MMA) of 2003Mandated a three year audit demonstration project 2005-2008

bull Appoint audit contractors to review Medicare billings for proper coding DRG assignment and medical necessity

bull Audits will apply to all health care providers (hospitals physicians homecare dme etc)

bull Audit contractors to be paid on a contingency basis a percentage of overpayments recovered

78

How Did we get here

bull Overpayments collected due to errors in Medically Unnecessary Services ndash 40

bull Incorrectly Coded ndash 35

bull Other ndash 17

bull NoInsufficient Documentation ndash 8

79

Where are we now

bull All RACrsquos completed required provider outreachAccess to Medicare billing data base given to all RAC RAC review methodology

bull Automated Review-Black amp White Issues (current) bull DRG Validation-complex review (current) bull Complex Review for coding errors (current) bull DME Medical Necessity Reviews ndashcomplex review (calendar year

2010) bull Medical Necessity Reviews-complex review (calendar year 2010)

80

RAC Reviews

bull Responsibilities of the Team Leader bull Must learn each insurance provider participating in a RAC or RAC type

program bull What are their operating rulesbull What is their appeal process Time limits

May be different process for each insurance provider bull Develop a response team

Identify who does what when why and alternate bull individual

Build and develop a manual process Review of computerized system

81

Priority Health SCIO Health Analytics

bull httpswwwsciohealthanalyticscomcore-capabilitiespayment-integrityfacility-auditsskilled-nursing-facility-audits

bull Claims for Medicare members treated at Skilled Nursing Facilities are reimbursed based on the patientsrsquo RUG (Resource Utilization Group) score which is determined using the Minimum Data Set (MDS) Using SCIOs robust analytics claims andor providers that merit review are selected for audit SCIOs auditors conduct a detailed review of the complete medical record and associated MDS to determine if the billed RUG score is valid In the event the review determines that an incorrect RUG score was billed SCIOreg provides the valid score reports the reason the change was necessary and calculates the resulting overpayment

82

+ Cheer

Onward and Upward she shall prevail We are here to care for the residents and provide a wonderful

service

13 83

84

References

bull Priority Healthbull Blue Crossbull Medicaidbull Medicare

85

  • Medicare Mange Care amp Medicaid Changes in the New World We Live In
  • Medicaid
  • NEW Medicaid Change MIlogin
  • Blueprint for Health Innovation MI
  • Provider Enrollment Electronic Signature Form Submission Process MSA 15-54
  • Provider Enrollment Electronic Signature Form Submission Process
  • Provider Enrollment Domain Administrator
  • Medicaid Coinsurance Medicare Advantage
  • Slide Number 9
  • Lawsuit DHS Changes on Caregivers
  • TPL Medicaid Change
  • CHAMPS Member Screen
  • LOC dropping off Not Due to MI Health
  • Issues
  • Secure Email Information
  • Medicaid amp Hospice
  • Medicaid
  • Medicaid Medicare Buy In
  • Manage Medicaid
  • Healthy Michigan Residents
  • Healthy Michigan Medicaid Days
  • McLaren Health Plan
  • Manage Medicaid Plans January 1
  • Slide Number 24
  • MI Health Link
  • MI Health Link 2565
  • What are the Names
  • MI Health Dual Eligible
  • MI Health LOC
  • LOC Medicaid
  • Medicaid Redetermination and MHL Enrollment
  • MI Health Link Portals
  • MI Health Authorizations
  • MI Health Issues
  • LOC 02 dropping MI Health Issues
  • PPA Offset
  • LOCD
  • MI Health Issues-New
  • ACO
  • Families Receiving Letters for ACO
  • ACO What is It
  • Payroll Based Journal
  • Slide Number 43
  • If you submit data manually should you also submit it through the XML
  • Staffing Submission Frequently Asked Questions
  • CMS defines
  • Slide Number 47
  • PBJ Medical Director Role
  • PBJ Medical Director Role
  • Dietician
  • Pharmacy Consultant
  • What are the names for the Medicare Number
  • QTSO
  • Medicare Update
  • CMS Final Rule On Returning Credits
  • Over Payment Rule
  • Questions to MAC
  • Questions to MAC
  • Final Rule on Returning Credits
  • Final Rule on Returning Credits
  • Final Rule on Returning Credits
  • Slide Number 62
  • Medicare Advantage Payors
  • Medicare Provider Enrollment Fee
  • Medicare MAC-Higlas
  • Two Midnight Rule
  • Two Midnight Rule
  • Two Midnight Rule
  • InPatient Vs Observation Conthellip
  • Two Midnight Rule
  • Health Data Insights amp Medicare Plus Blue
  • HDI Health Data amp Med Plus Blue
  • Health Data InSight
  • Pepper Reports
  • CGI Technologies and Solutions Inc httpracbcgicomContactInfoaspxst=1
  • CGI Federal RAC
  • How to survive RAC Audit
  • RAC Audits
  • How Did we get here
  • Where are we now
  • RAC Reviews
  • Priority Health SCIO Health Analytics
  • Cheer
  • References
Page 8: Medicare, Mange Care & Medicaid Changes in the New World we live in

Medicaid Coinsurance Medicare Advantage

bull Attention Nursing Facility Medicaid Fee for Service Providers

bull As part of the December 11 2015 CHAMPS system update the final phase of the Medicare Advantage Coinsurance Pricing Logic was implemented For claim dates of service 2010 and prior please refer to the Medicaid Provider Manual under General Information for Providers Chapter Section 124 Provider Returning Overpayments

bull For claim dates of service 2011 and forward MDHHS will be initiating the claim adjustment within the next few weeks Providers with further questions can contact Provider Support by phone 1-800-292-2550 or email ProviderSupportmichigangov

8

The State has been paying the wrong coinsurance amount for Medicare Advantage since 2008 Per below they will be doing a claim adjustment in the next few weeks for dates of service 2011 going forward If you have refunded the State by a check watch and make sure they do not double recover the money If they do you will have to get your check and list of people you refunded and send it to providersupportmichigangov They have stated they have fixed the pricing logic to pay it correctly going forward Watch and make sure they are paying the correct amount if not you will have to again pull the information from the coinsurance payer and send it to providersupportmichigangov

For dates of service prior to 2011 you will have to return the Money per the Medicaid manual

Medicaid providers performing self audits may discover an overpayment situation and wish to return theMedicaid overpayment to MDHHS This process should only be used when the provider is unable to claimadjust or it is not practical to claim adjust Sending in a check will not correct the underlying claim(s)data Providers must

10487071048707 Document why the money is being returned (ie provider self audit) and identify provider NPIinformation address dates of service and specialty area (ie durable medical items pharmacyphysician practice hospital etc) and include a basic information letter

10487071048707 Attach an excel spreadsheet document with the Tax ID billing NPIs and associated amounts (ifmultiple IDs exist for the entity) for the MDHHS Accounting Office to apply credit to

10487071048707 Make check payable to State of Michigan and mail to the MDHHSCashierrsquos Unit - Attn Bureauof Finance-MCU (Refer to the Directory Appendix for contact information) 9

Lawsuit DHS Changes on Caregivers

bull A recent Michigan Court of Appeals decision has played havoc on the rules surrounding payments to non-family caregivers DHS rules regarding payments to caregivers state that payments are divestment in two situations 1) prospective payments made to any caregiver (family or non-related) before care is provided and 2) payments to family caregivers absent a Medicaid qualified caregiving contract The Court of Appeals decision Jensen v Department of Human Services confuses the rules and applies the family caregiving contract requirements to all caregivers even professional caregiving agencies The result of the case is that payments to non-family caregivers may be divestment unless the Medicaid applicant has a contract with the caregiver meeting the extremely specific rules found in the Medicaid manual

10

TPL Medicaid Changebull Attention Providersbull Effective October 26 2015 the MDHHS Third Party Liability (TPL)

Update Other Insurance Now Online form will be updated You will now receive a confirmation number when you submit your request If an email address is added within the Requestor Information section once TPL completes your request you will receive an email with the confirmation number and the status of your request Please allow up to 10 business days for information to be verified and updated in the system Please check your spam or junk email folders if you do not receive the email after 10 business days

bull Providers with further questions can contact Provider Support by phone 1-800-292-2550 or email ProviderSupportmichigangov

bull httpsminotifytplstatemiustedpubliccoveragerequestsindex11

CHAMPS Member Screen

bull Attention Providersbull Effective September 25 2015 a change was made to the CHAMPS

system This change modified the provider view for the Member Eligibility Inquiry screen If a member no longer has active Medicaid the hyperlink to view ldquoCommercialOtherrdquo Third Party Liability (TPL) information is disabled Because TPL does not always maintain TPLOther Insurance information for members that do not have active Medicaid coverage this information was disabled to prevent inaccurate information from being reported

12

LOC dropping off Not Due to MI Health

bull If after 30 days the county hasnrsquot processed the 2565 that you have send via the central scan (517-346-9888) AND other methods you choose to use you can email the 2565 to ArdeneMartin

bull At the following mailbox I ask that you put the beneficiaries name in the subject line

bull MSA2565michigangov

13

Issues

bull PPA going all over the place

bull LOC 02 dropping off not related to MI Health

bull LOCD tons of money written off

bull Must check CHAMPS member screen all the time and you must check pending

14

Secure Email Information

bull The State of Michigan asked me to remind you when you are communicating with them regarding residents to not send Resident names Birthdates or Social security numbers in those emails What you send is the Medicaid ID and they can look it up Or if it is a billing issue send them the TCN and the Medicaid ID We have been in the practice of emailing DHS Ardene Martin Integrated Health and Provider Support with all the resident name and such

15

Medicaid amp Hospicebull LOC 07 Manage Medicaid Hospice included so plan would pay

provider and not switch to a LOC 16

bull LOC 02 Medicaid (Regular Medicaid) Hospice not included so switch to 16 Hospice and Hospice pays provider

bull LOC 11 Healthy Michigan is included in plan so plan would pay provider and not switch to LOC 16

bull LOC 005 amp 015 MI Health is up in the air waiting for CMS Currently Hospice is now included

bull LOC 16 is Hospice when they switch from Regular Medicaid only and Hospice pays provider

16

Medicaidbull Going forward please make sure that your Champs ID amp NPI on your member screen matches your facility CHAMPS ID

amp NPI for each resident and matches for all new admissions or new approved Medicaid going forward

bull The edit will be turned on soon to stop the payment of these claims if the CHAMPS ID and NPI do not Match your facility on the Medicaid member screen

bull Make sure you are putting the information correct on the 2565 you send in to DHS

bull 1 I attached a 2565 When you fill this out for new people make sure in box 12 a you put your NPI and 12 b you put your CHAMPS ID This will help the DHS case workers assign the person to your facility

bull 2 I would check all your residents CHAMPS member screens and make sure the NPI and CHAMPS ID are your facilities If not you will have to work with the DHS worker to fix this The DHS worker is the only one that can fix this

bull 3 We are having some issues where the DHS case workers will not change this NPI and CHAMPS ID to your facilities You have to get them to change it or you just will not get paid

bull 4 We situations where the resident is in a facility in Kent County (as an example) but the family lives in Livingston County and completes the applications in Livingston County You will have to get the DHS worker in Livingston to fix it not the local DHS worker in Kent County where your facility is

17

Medicaid Medicare Buy Inbull Based on the information from the Office of Personnel Management Federal

Employeersquos employed as of January 1 1983 are eligible for Medicare Part A(see page 5 of attached document) This was also confirmed with our Social Security liaison If the beneficiary did not retire before 1983 he can enroll in Medicare Part B and pay the premium and then he can enroll in Medicare Part A and pay that premium as well or may qualify for Medicare Buy in of Part A

bull If a beneficiary has an SSA document stating they are not eligible for Medicare as they do not have enough work credits the beneficiarybeneficiary representative needs to go to SSA and let them know that while they know they are not eligible for Medicare Part A free or reduced however they are eligible for Medicare Part B and would like to enroll Once the beneficiary enrolls in Medicare Part B (enrollment period January 1st ndash March 31 each year) and pays the premium then the beneficiary is eligible to either pay for Medicare Part A or that beneficiary may qualify for Medicare Part A buy in through Medicaid Once the beneficiary is enrolled in Medicare Part A and Medicare Part B Medicaid will begin to make payments on claims

18

Manage Medicaid Where are we

19

Healthy Michigan Residents

20

Healthy Michigan Medicaid Days

21

McLaren Health Plan

22

Manage Medicaid Plans January 1bull Region 1 ndash Upper Peninsula Health Planbull Region 2 ndash McLaren Health Plan Meridian Health Plan of Michigan Molina Healthcare of Michigan

UnitedHealthcare Community Planbull Region 3 ndash McLaren Health Plan Meridian Health Plan of Michigan Molina Healthcare of Michigan

UnitedHealthcare Community Planbull Region 4 ndash Blue Cross Complete of Michigan McLaren Health Plan Meridian Health Plan of Michigan Molina

Healthcare of Michigan Priority Health Choice UnitedHealthcare Community Planbull Region 5 ndash McLaren Health Plan Meridian Health Plan of Michigan Molina Healthcare of Michigan

UnitedHealthcare Community Planbull Region 6 ndash Blue Cross Complete of Michigan HAP Midwest Health Plan McLaren Health Plan Meridian Health

Plan of Michigan Molina Healthcare of Michigan UnitedHealthcare Community Planbull Region 7 ndash Blue Cross Complete of Michigan McLaren Health Plan Meridian Health Plan UnitedHealthcare

Community Planbull Region 8 ndash Aetna Better Health of Michigan McLaren Health Plan Meridian Health Plan of Michigan Molina

Healthcare of Michigan Priority Health Choice UnitedHealthcare Community Planbull Region 9 ndash Aetna Better Health of Michigan Blue Cross Complete of Michigan McLaren Health Plan Meridian

Health Plan of Michigan Molina Healthcare of Michigan UnitedHealthcare Community Planbull Region 10 ndash Aetna Better Health of Michigan Blue Cross Complete of Michigan Harbor Health Plan McLaren

Health Plan Meridian Health Plan of Michigan Molina Healthcare of Michigan Total Health Care UnitedHealthcare Community Plan 23

24

MI Health LinkWhere are we

25

MI Health Link 2565

bull This notification is being sent to providers of long term care services including nursing facilities county medical care facilities and hospital long term care units to provide clarification on the process involved with the submission of the Facility Admission Form (MSA-2565-C) for an individual enrolled in the MI Health Link program

bull The MI Health Link program covers the custodiallong term nursing facility service benefit When an individual who is enrolled in the MI Health Link program is admitted to a nursing facility for custodiallong term nursing services a disenrollment from the Integrated Care Organization (MI Health Link health plan) is NOT REQUIRED The Facility Admission Form (MSA-2565-C) should NOT be sent to the Michigan Department of Health and Human Services (MDHHS) Enrollment Services Section for a disenrollment to be processed

26

What are the Names

bull Started as Integrated Health

bull Then called MMP (Medicare Medicaid Program)

bull Duals (Also Known as Duals as in Dual Eligible)

bull Now called MI Health Link

bull Total confusion

27

MI Health Dual Eligible28

MI Health LOC

29

LOC Medicaidbull We have the new pilot program which started on March

1 2015 in Southwest Michigan Region 4 Counties Macomb Wayne and the UP You could see these patients they are dual eligible in the Pilot program in counties surrounding the pilot

bull MHL-LOC 005 (All other Facilities) or LOC 015 (County Care) These residents have to call Michigan Enrolls to dis-enroll toll-free at 1-800-975-7630 (TTY 1-888-263-5897) Monday-Friday from 8 AM to 7 PM Once they dis-enroll they will go to a LOC 02 you have to do a new LOCD

30

Medicaid Redetermination and MHL Enrollmentbull At the time of re-determination for Medicaid financial eligibility the MI

Health Link (MHL) program will not be sending beneficiaries information about this program Beneficiaries who previously opted out will not be passively enrolled according to an email from the MHL staff The MHL staff wrote

bull ldquoThere is currently no MI Health Link enrollment letter sent to beneficiaries when eligibility is re-determined A person who becomes eligible for MI Health Link enrollment may opt-in at any time

bull When Medicaid re-determination takes place the beneficiary remains in the same ICO unless that beneficiary lost Medicaid coverage If the enrollee loses Medicaid coverage and later regains it they are not passively enrolled into MI Health Link The beneficiary may choose to opt back in to the program at that time if desiredrdquo

bull MHL staff did state that about 1500 beneficiaries will be passively enrolled effective January 1 2016 These specific individuals were given normal notice of 60 and 30 days in which to opt-in or opt-out if they so chose No other large scale passive enrollment is scheduled according to the MHL staff 31

MI Health Link Portals

bull Meridian Health Planbull httpwwwmhplancommibull Amerihealthbull httpwwwamerihealthcaritasvipcarepluscomproviderself-service-

toolsindexaspxbull AetnaCoventrybull httpwwwaetnabetterhealthcomMichiganprovidersportalbull Molinabull httpwwwmolinahealthcarecommembersmien-usmemPageshomeaspxbull HAPMidwestbull httpswwwmidwesthealthplancomLoginaspxbull FidelisCentenebull wwwfidelissccommmp 32

MI Health Authorizationsbull We need to watch these authorization that the plans are giving us for the MI

Health program Some plans are assigning a diagnosis for residents in their prior authorizations They are assigning diagnosis that the residents do not even have You need to make sure these are correct diagnosis and if not you need to work with the case managers of the plans to fix the issue The authorization numbers do change

bull Make sure that any resident that is in a MI Health plan that you have a prior authorization All plans are giving different periods authorizing the residents stay in the facility You need to set up a system to make sure you always have a authorization for the period of time you are rendering the service Here is an example of time frame of authorizations

bull Meridian is authorizing 12 monthsbull Aetna is authorizing 3 monthsbull Molina is authorizing 6 monthsbull The authorization numbers need to go on your claims to the payer You need to

put the authorizations in your software and track the dates

33

MI Health Issuesbull We are seeing some issues with MI Health where the resident does not have the correct LOC or it shows

up correct on CHAMPS but ancillary providers such as Dentist and such cannot see it I think we still have some issues with the information crossing between Bridges DHS system CMS and CHAMPS It in return is creating some access of care issues If it is a true LOC issues Facilities with LOC issues need to submit the Medicaid ID numbers to the MSA-MHL-EnrollmentMichigangov box with the subject line Nursing home LOC Issue so they may work to resolve the issues

bull If it becomes an access to care issue email the information to INTEGRATEDCAREmichigangov Remember in these emails only send the Medicaid ID and explain the situation The State will work with the plans to try to fix the process or improve the process

bull We are also seeing with new admission with LOC 015 or 005 that the plans are stating they have 14 days to authorize admission These are resident in the emergency room and possibly be admitted to you for Rehab The hospital will not keep the resident in ER for 14 days and you cannot admit the resident until you have a prior authorization I would recommend when you are told this by the plan that you need to ask to speak to a manager We will have to work through this

bull Ancillary Provider You need to work with your ancillary providers such as Lab Pharmacy X-Ray Physician and such to get the to be credentialed with the plans We are hearing that some of the pharmacies are not participating with the plans this will create issues for you so I would continue to ask these groups to participate

34

LOC 02 dropping MI Health Issuesbull The passive enrollments have occurred in Macomb amp Wayne for

Medicaid dual eligible We are having the same issue we did as in the Southwest MI amp UP with the passive enrollments I am starting to hear from facilities who are checking there CHAMPS member screens that those residents that have opted out (some residents not all) have lost there 02 Make sure you are checking your CHAMPS member screen both for those that were passively enrolled and those that might have lost there 02 Medicaid that opted out

bull Facilities with LOC issues need to submit the Medicaid ID numbers to the (Only MI Health)MSA-MHL-Enrollmentmichigangov box with the subject line Nursing home LOC Issue so they may work to resolve the issues

35

PPA Offset

bull There are no co-pays deductibles or premiums in MI Health Link so there should be no need to offset the PPA with code 25 MI Health Link enrollees can continue to offset their PPA for non-program covered medical expenses (like Vision-Code 27 Dental-Code 28 and Hearing-Code 26) and use the appropriate codes to offset the PPA when billing the health plan for nursing facility services

bull Resident pay PPA when MedicareMedicaid coinsurance

36

LOCDbull Nursing Facility Level of Care Determination (NFLOCD)

bull The MI Health Link health plan will be responsible for conducting the Michigan Medicaid NFLOCD tool for enrollees seeking admission to a nursing facility For existing residents at the time of enrollment the existing NFLOCD will be adopted for capitation payment purposes The health plan will complete a new NFLCOD tool within the first 90 days of enrollment If a nursing facility resident is disenrolled from MI Health Link the nursing facility will be responsible for conducting a new NFLOCD tool in accordance with published Medicaid policy

37

MI Health Issues-New

bull INTEGRATEDCAREmichigangov

bull Email with Insurance Plan issues Case Manager Issues

38

ACOWhat are they

39

Families Receiving Letters for ACO

40

ACO What is It

bull Whats an ACObull Accountable Care Organizations (ACOs) are groups of doctors hospitals

and other health care providers who come together voluntarily to give coordinated high quality care to their Medicare patients

bull The goal of coordinated care is to ensure that patients especially the chronically ill get the right care at the right time while avoiding

unnecessary duplication of services and preventing medical errorsbull When an ACO succeeds both in delivering high-quality care and

spending health care dollars more wisely it will share in the savings it achieves for the Medicare program

41

Payroll Based JournalMandatory on July 1 2016Internet Explorer Version

Internet Explorer v 10 and v 11 will need to operate in compatibility mode

42

43

If you submit data manually should you also submit it through the XML

bull Now you have three options

bull Submit Manually only

bull Submit through the XML only

bull You are able to submit manually and using the XML

44

45

Staffing Submission Frequently Asked Questions

bull ldquoWho are direct care staffrdquo (Who do we submit data for)bull Submission of data for contract staffbull Medical directors and consultantsbull Staff switching roles or tasks throughout the daybull Hours paid vs hours worked ndash Must be verifiablebull Public postingQuality MeasuresFive Starbull Enforcementbull Voluntary submission risks (noneSo register now)

CMS defines

bull 37 job title codes that are required to match employees to the number of hours each direct care function was performed It is important to work with your teams to define the workers that contribute to each job type and how those daily worked hours are recorded and converted to a PBJ submission

bull The PBJ does include some more specific job descriptions than the 671 For example the PBJ system includes job descriptions for RNs with administrative duties and LPNs with administrative duties versus the 671rsquos more general ldquoNurses with Administrative Duties

Page 46

47

PBJ Medical Director Rolebull Physician Leadership

bull Help the facility ensure that patients have appropriate physician coverage and ensure the provision of physician and health care practitioner services and

bull Help the facility develop a process for reviewing physician and health care practitioner credentials

bull Provide specific guidance for physician performance expectations

bull Help the facility ensure that a system is in place for monitoring the performance of health care practitioners and

bull Facilitate feedback to physicians and other health care practitioners on performance and practices

bull Patient Care - Clinical Leadership

bull Participate in administrative decision-making and the development of policies and procedures related to patient care

bull Help develop approve and implement specific clinical practices for the facility to incorporate into its care-related policies and procedures including areas required by laws and regulations

bull Develop procedures and guidance for facility staff regarding contacting practitioners including information gathering and presentation change in condition assessment and when to contact the medical director

bull Review consider andor act upon consultant recommendations as appropriate that affect the facilitys resident care policies and procedures or the care of an individual resident

bull Review respond to and participate in federal state local and other external surveys and inspections and

bull Help review policies and procedures regarding the adequate protection of patients rights advance care planning and other ethical issues48

PBJ Medical Director Rolebull Quality of Care

bull Help the facility establish systems and methods for reviewing the quality and appropriateness of clinical care and other health-related services and provide appropriate feedback and

bull Participate in the facilitys quality improvement process

bull Advise on infection control issues and approve specific infection control policies to be incorporated into facility policies and procedures

bull Help the facility provide a safe and caring environment

bull Help promote employee health and safety and

bull Assist in the development and implementation of employee health policies and programs

bull Education Information and Communication

bull Promote a learning culture within the facility by educating informing and communicating

bull Provide information to help the facility provide care consistent with current standards of practice (defined as approaches to care procedures techniques and treatments that are based on research and or expert consensus and that are contained in current manuals textbooks and or publications or that are accepted adopted or promulgated by recognized organizations or national bodies)

bull Help the facility develop medical information and communication systems with staff patients and families and others

bull Represent the facility to the professional and lay community on medical and patient care issues

bull Maintain knowledge of the changing social regulatory political and economic factors that affect medical and health services of long term care patients and

bull Help establish appropriate relationships with other health care organizations

49

Dietician

bull When the dietary or food services supervisor is other than a registered dietitian the supervisor shall receive routine consultation and technical assistance from a registered dietitian (RD) Consultation time shall not be less than 4 hours every 60 days Additional consultation time may be needed based on the total number of patients incidence of nutrition-related health problems and food service management needs of the facility

50

Pharmacy Consultant

bull At least once per month a licensed pharmacist must perform a drug regimen review (DRR) for each resident The pharmacist must report any irregularities to the attending physician or director of nursing Furthermore these reports must be acted upon

51

What are the names for the Medicare Numberbull OSCAR -Online Survey Certification and Reporting

bull PTAN-PTAN number is assigned by Medicare to authenticate the provider when using the local Medicare Administrative Contractorrsquos (MAC) self-help tools like the IVR internet portal on-line application status etc Provider Transactions Access Number

bull CCN- CMS Certification Number

bull Medicare Number- example 23-

bull All of the above mean the same thing

52

QTSO

bull Once you are logged in the QTSO site bull You will have a state login to the site to access the various site specific

to your facilitybull Installing you will need administrator rights to your network

53

Medicare UpdateWhat are we seeing

54

CMS Final Rule On Returning Credits

httpswwwfederalregistergovarticles201602122016-02789medicare-program-reporting-and-returning-of-overpayments

55

Over Payment Rule

bull Medicare payments for non covered services

bull Medicare payments in excess of the allowable amount for an identified covered service

bull Errors and non reimbursable expenditures in cost reportsbull Duplicate payment

bull Receipt of Medicare payments when another payor had the primary responsibility for payment

56

Questions to MAC

bull Does the Medicare credit balance report change with this overpayment rule

bull No Medicare Credit Balances are still required at the end of each quarter

bull Will that still be the communication to let CMS or the MAC know that we have received an overpayment

bull Submission of Medicare Credit Balance is one form of communicating overpayments to CMS Other methods include submitting a voluntary refund with required claim information or the submission of a standard overpayment form

57

Questions to MAC

bull Will the MAC still deduct from a future RAbull If the recovery of the overpayment includes adjusting a claim then

the overpayment would be netted against future claims payments and reflected on the RA

bull Or will that process change with this new rulebull Process will remain the samebull Will NGS send communication out on thisbull Yes NGS will communicate this once the final rule is communicated

to the MACs by CMS However this could change depending on final CMS instructions

58

Final Rule on Returning Credits

bull Providers will want to immediately update their current policies governing overpayments in order to comply with this new rule which will take effect on March 14 2016

bull Providers and suppliers are required to use reasonable diligence to investigate credible information regarding overpayments through both proactive compliance efforts and reactive investigations

bull If an overpayment is identified then it must be repaid within 60 days An overpayment is identified when a person has or should have through the exercise of reasonable diligence determined that the person received an overpayment and quantified the amount

bull Providers and suppliers have a maximum of 8 months to report and return overpayments ndash up to 6 months to investigate and quantify the overpayment (ie to identify it) and up to 60 days to report and return the overpayment

59

Final Rule on Returning Credits

bull Providers and suppliers are required to report and return all overpayments within a 6-year lookback period

bull The cause and amount of the overpayment is irrelevant for the determination eg it was due to a mistake it was someone elsersquos fault it is a minor amount An overpayment is an overpayment and must be returned

bull Providers and suppliers must make their own determination to which entity to report and return the overpayment ie to the Medicare contractor or using the OIG Self Disclosure Protocol or the CMS Self Referral Disclosure Protocol

60

Final Rule on Returning Credits

bull Providers and suppliers may use the claims adjustment credit balance self-reported refund process or another appropriate process to report and return overpayments At this time there is no standard refund form to use

bull Failure to report and return an overpayment could subject the provider or supplier to False Claims Act liability Civil Monetary Penalties Law liability and exclusion from federal health care programs

61

P S amp R-Accountants will be asking for this information

The location you login into has changed it is now on EIDM EIDM is the acronym for CMS Enterprise Identity Management system which includes Identity Verification Access Management Authorization Assistance Workflow Tools and Identity Lifecycle Management functions

httpswwwcmsgovResearch-Statistics-Data-and-SystemsCMS-Information-TechnologyIACSCMS-Applications-Loginhtml

Go down the page and click on the PSampRSTARThis will take you to the login pagewill look the same as the old P S amp R didChanges Affecting PSampR System Access (Please Read) (posted 01292015)(Updated 5262015)is changingThe system which controls your PSampR user ID (currently IACS)The new system is referred to as EIDMThis will result in a different way to create new accounts or change passwords to existing accountsIf you already have an account in EIDM you may have to use that account for accessing PSampR after the transitionWhen is the change effectiveJune 13 2015What is staying the sameThe internet address for accessing PSampR remains the sameThe PSampR systemfunctionality is NOT changing 62

Medicare Advantage Payorsbull Medicare Advantage payors are pullingdenying payments on admissions if the patient was readmitted within 30 days after discharge The

client believes that the payors systematically denying payments for all readmissions within 30 days They believe this practice denies them due process to address whether the readmissions were justified and not due to a premature discharge of patient The payors seem to want to act like a QIO without having the same accountabilities of the QIO related to determinations of non-payment

bull Heres the QIO process under section 4240 of the QIO Manualbull 4240 - Readmission Review - (Rev 2 07-11-03)bull Readmission review involves admissions to an acute general short-term hospital occurring less than 31 calendar days from the date of

discharge from the same or another acute general short-term hospital (see sect1154(a)(13) and 42 CFR 47671(a)(8)(ii)) Neither the day of discharge nor the day of admission is counted when determining whether a readmission has occurred

bull A Medical Review Proceduresbull Obtain the appropriate medical records for the initial admission and readmission Perform case review on both stays Analyze the cases

specifically to determine whether the patient was prematurely discharged from the first confinement thus causing readmission Perform an analysis of the stay at the first hospital to determine the cause(s) and extent of any problem(s) (eg incomplete or substandard treatment) Consider the information available to the attending physician who discharged the patient from the first confinement Do not base a determination of a premature discharge on information that the physician or provider could not have known or events that could not have been anticipated at the time of discharge

bull Review both the initial admission and the readmission at the same time unless one of them has previously been reviewed In these cases use at a minimum the PRAF case summary of the other admission in addition to the medical record of the case under review

bull C Denialsbull Deny readmissions under the following circumstancesbull If the readmission was medically unnecessarybull If the readmission resulted from a premature discharge from the same hospital orbull If the readmission was a result of circumvention of PPS by the same hospital (see sect4255)bull With the QIO process there is an appeal within the QIO here the hospital is getting no opportunity to challenge the denials

63

Medicare Provider Enrollment Feebull Provider Enrollment Application Fee Amount for CY 2016bull On December 3 CMS issued a notice Provider Enrollment Application

Fee Amount for CY 2016 [CMSndash6066ndashN] Effective January 1 2016 the CY 2016 application fee is $554 for institutional providers that are

bull Initially enrolling in the Medicare or Medicaid program or the Childrens Health Insurance Program (CHIP)

bull Revalidating their Medicare Medicaid or CHIP enrollmentbull Adding a new Medicare practice locationbull This fee is required with any enrollment application submitted from

January 1 through December 31 2016

64

Medicare MAC-Higlas

bull Effective 142016 CMS has implemented a change to begin netting (offsetting) provider money across workloads within a single organization What this means is that any related providers conducting business in two different workloads (example New York and Maine) will have their money applied to any account receivables (AR) with a remaining balance owed to Medicare within both workloads For example Provider ABC is located in New York and is scheduled to receive a payment of $1000 on todays remittance advice Provider XYZ is related to provider ABC but is located in Maine and has ARs with a balance owed of $200 Provider ABCs $1000 payment will have the $200 applied against provider XYZs ARs resulting in a net payment of $800 This will be reflected on the remittance advice by the same PLB code as seen today for offsets for the $200

65

Two Midnight RuleChange January 1 2016 httpswwwcmsgovMedicareMedicare-Fee-for-Service-PaymentHospitalOutpatientPPSHospital-Outpatient-Regulations-and-Notices-ItemsCMS-1633-FChtml

66

Two Midnight Rulebull However effective January 1 2016 CMS will allow exceptions to the

Two-Midnight Benchmark to be determined on a case-by-case basis by the physician responsible for the care of the beneficiary subject to medical review Said differently Part A payment may be appropriate in some circumstances even though there is no expectation by the physician (or qualified ordering practitioner) of a two-midnight stay and one of the two pre-existing categorical exceptions (CMS ldquoinpatient onlyrdquo list and newly initiated mechanical ventilation) does not apply CMS has indicated that this change to the Two Midnight Rule is in response to stakeholder concern and CMSrsquos continued efforts to develop the most appropriate standard for determining Medicare Part A payment

67

Two Midnight Rulebull A new 42 CFR sect4123(a) provides that a patient is considered an

inpatient of a hospitalhellipif formally admitted as an inpatient pursuant to an order for inpatient admission by a physician or other qualified practitionerhellip The physician orders inpatient status when he or she expects the patient to require a stay that crosses at least 2 midnights[10] Stays expected to be shorter than at least two midnights are generally inappropriate for inpatient admission and inpatient payment under Medicare Part A unless the surgical procedure is specified by Medicare as inpatient only under sect41922(n)[11] The physicians expectationhellipshould be based on such complex medical factors as patient history and comorbidities the severity of signs and symptoms current medical needs and the risk of an adverse event[12] The physician order is part of physician certification of the medical necessity of hospital inpatient serviceshellip[13]

68

InPatient Vs Observation Conthellip

bull Physician certification which begins with an order for inpatient admission requires the physician to certify the reasons for the hospitalization the estimated time the patient will remain in the hospital and plans for post-hospital care if appropriate[14] The certification must be completed signed and documented in the medical record prior to discharge[15]

bull A physicians admission order has no presumptive weight and both the admission order and the physician certification will be evaluated in the context of the evidence in the medical record[16] CMS intends to provide additional information about what evidence in the medical record means in future instructions and manual revisions[17]

69

Two Midnight Rulebull Although the new case-by-case exception appears to be inherently

subjective to a certain extent CMS states that the following factors (among others) would be relevant to determining whether a patient requires inpatient admission under the expanded policy

bull The severity of the signs and symptoms exhibited by the patient bull The medical predictability of something adverse happening to the patient

and bull The need for diagnostic studies that appropriately are outpatient services

(that is their performance does not ordinarily require the patient to remain at the hospital for 24 hours or more)

bull CMS also notes that an inpatient admission (and Part A payment) should be ldquorare and unusualrdquo for minor surgical procedures or other treatment that is expected to keep the patient in the hospital ldquofor only a few hoursrdquo or for a period of time that ldquodoes not span at least overnightrdquo (thus a subset of stays not meeting the Two Midnight Benchmark) CMS indicates that such cases will be prioritized for medical review

70

Health Data Insights amp Medicare Plus Blue

RAC (Retrospective Audits)

71

HDI Health Data amp Med Plus Blue

bull httpwwwhealthdatainsightscombull Blue Cross Medicare Advantage Auditsbull Facilities seeing 10 to 15 requests for Medical Recordsbull In January amp Feburarybull Selected Health Data Insights because they were a premier Audit

Vendor for CMS Recovery Audit Contractor (RAC) demonstration Project They are a audit vendor for Humana

bull Providers not sending Medical Record will get technical denial and lose payments

72

Health Data InSight

bull In 2010 they began the Hospital Reviewbull Medicare Advantage encounter datandashCMS oversight of data integrity OIG

2016bull We will review CMSs oversight of MA encounter data validation and assess

the extent to which CMSrsquos Integrated Data Repository contains timely valid and complete MA encounter data In 2012 CMS began collecting from MA organizations a more comprehensive set of encounter data reflecting the items and services provided to MA plan enrollees Prior CMS and OIG audits have indicated vulnerabilities in the accuracy of data reporting by MA organizations Realizing the potential benefits of the MA encounter data for payment and program integrity oversight is contingent upon the datarsquos completeness validity and timeliness (OEI 03-15-00060 expected issue date FY 2017)

73

Pepper Reports

bull httpswwwpepperresourcesorg

bull Program for Evaluating Payment Patterns Electronic Report ( PEPPER)

bull Annually on or about April 18 2016 will be released

bull Pepper Portal httpssecurefiletmforg

74

CGI Technologies and Solutions Inc httpracbcgicomContactInfoaspxst=1

bull Indiana bull Michiganbull Minnesotabull Illinoisbull Kentuckybull Ohiobull Wisconsin CGI Technologies and Solutions Incbull For general and administrative questions regarding client service outreach

quality assurance or project-specific issues contactbull 1877316RACB (7222)bull Email racbcgicom Tamara Tate Tamaratatecmshhsgovbull 4107861288

75

CGI Federal RAC

bull CGI Federal RAC Region Bbull Email racbcgicombull Phone 1-877-316-RACB (7222)bull Mailing Addressbull Send medical records as followsbull Medical records for Indiana Illinois Kentucky Michigan Ohio Wisconsin

Minnesota DME and Home Health CGI Federal Inc Attn RACB Imaging Dept 1001 Lakeside Ave Suite 800 Cleveland OH 44114

bull If submitting paper records please send medical records as follows For Therapy Reviews CGI Federal Inc Attn RACB Imaging 1001 Lakeside Avenue Suite 800 Cleveland OH 44114

76

How to survive RAC Audit

bull National health expenditures totaled $1679 Billion in 2003 bull National health expenditures were 153 of GROSS Domestic Product

(GDP) in 2003 bull Health care cost increasing at +9 per year bull Doomsday predictions of Medicare running out bull Congressional Action

77

RAC Audits

bull Medicare Modernization Act (MMA) of 2003Mandated a three year audit demonstration project 2005-2008

bull Appoint audit contractors to review Medicare billings for proper coding DRG assignment and medical necessity

bull Audits will apply to all health care providers (hospitals physicians homecare dme etc)

bull Audit contractors to be paid on a contingency basis a percentage of overpayments recovered

78

How Did we get here

bull Overpayments collected due to errors in Medically Unnecessary Services ndash 40

bull Incorrectly Coded ndash 35

bull Other ndash 17

bull NoInsufficient Documentation ndash 8

79

Where are we now

bull All RACrsquos completed required provider outreachAccess to Medicare billing data base given to all RAC RAC review methodology

bull Automated Review-Black amp White Issues (current) bull DRG Validation-complex review (current) bull Complex Review for coding errors (current) bull DME Medical Necessity Reviews ndashcomplex review (calendar year

2010) bull Medical Necessity Reviews-complex review (calendar year 2010)

80

RAC Reviews

bull Responsibilities of the Team Leader bull Must learn each insurance provider participating in a RAC or RAC type

program bull What are their operating rulesbull What is their appeal process Time limits

May be different process for each insurance provider bull Develop a response team

Identify who does what when why and alternate bull individual

Build and develop a manual process Review of computerized system

81

Priority Health SCIO Health Analytics

bull httpswwwsciohealthanalyticscomcore-capabilitiespayment-integrityfacility-auditsskilled-nursing-facility-audits

bull Claims for Medicare members treated at Skilled Nursing Facilities are reimbursed based on the patientsrsquo RUG (Resource Utilization Group) score which is determined using the Minimum Data Set (MDS) Using SCIOs robust analytics claims andor providers that merit review are selected for audit SCIOs auditors conduct a detailed review of the complete medical record and associated MDS to determine if the billed RUG score is valid In the event the review determines that an incorrect RUG score was billed SCIOreg provides the valid score reports the reason the change was necessary and calculates the resulting overpayment

82

+ Cheer

Onward and Upward she shall prevail We are here to care for the residents and provide a wonderful

service

13 83

84

References

bull Priority Healthbull Blue Crossbull Medicaidbull Medicare

85

  • Medicare Mange Care amp Medicaid Changes in the New World We Live In
  • Medicaid
  • NEW Medicaid Change MIlogin
  • Blueprint for Health Innovation MI
  • Provider Enrollment Electronic Signature Form Submission Process MSA 15-54
  • Provider Enrollment Electronic Signature Form Submission Process
  • Provider Enrollment Domain Administrator
  • Medicaid Coinsurance Medicare Advantage
  • Slide Number 9
  • Lawsuit DHS Changes on Caregivers
  • TPL Medicaid Change
  • CHAMPS Member Screen
  • LOC dropping off Not Due to MI Health
  • Issues
  • Secure Email Information
  • Medicaid amp Hospice
  • Medicaid
  • Medicaid Medicare Buy In
  • Manage Medicaid
  • Healthy Michigan Residents
  • Healthy Michigan Medicaid Days
  • McLaren Health Plan
  • Manage Medicaid Plans January 1
  • Slide Number 24
  • MI Health Link
  • MI Health Link 2565
  • What are the Names
  • MI Health Dual Eligible
  • MI Health LOC
  • LOC Medicaid
  • Medicaid Redetermination and MHL Enrollment
  • MI Health Link Portals
  • MI Health Authorizations
  • MI Health Issues
  • LOC 02 dropping MI Health Issues
  • PPA Offset
  • LOCD
  • MI Health Issues-New
  • ACO
  • Families Receiving Letters for ACO
  • ACO What is It
  • Payroll Based Journal
  • Slide Number 43
  • If you submit data manually should you also submit it through the XML
  • Staffing Submission Frequently Asked Questions
  • CMS defines
  • Slide Number 47
  • PBJ Medical Director Role
  • PBJ Medical Director Role
  • Dietician
  • Pharmacy Consultant
  • What are the names for the Medicare Number
  • QTSO
  • Medicare Update
  • CMS Final Rule On Returning Credits
  • Over Payment Rule
  • Questions to MAC
  • Questions to MAC
  • Final Rule on Returning Credits
  • Final Rule on Returning Credits
  • Final Rule on Returning Credits
  • Slide Number 62
  • Medicare Advantage Payors
  • Medicare Provider Enrollment Fee
  • Medicare MAC-Higlas
  • Two Midnight Rule
  • Two Midnight Rule
  • Two Midnight Rule
  • InPatient Vs Observation Conthellip
  • Two Midnight Rule
  • Health Data Insights amp Medicare Plus Blue
  • HDI Health Data amp Med Plus Blue
  • Health Data InSight
  • Pepper Reports
  • CGI Technologies and Solutions Inc httpracbcgicomContactInfoaspxst=1
  • CGI Federal RAC
  • How to survive RAC Audit
  • RAC Audits
  • How Did we get here
  • Where are we now
  • RAC Reviews
  • Priority Health SCIO Health Analytics
  • Cheer
  • References
Page 9: Medicare, Mange Care & Medicaid Changes in the New World we live in

The State has been paying the wrong coinsurance amount for Medicare Advantage since 2008 Per below they will be doing a claim adjustment in the next few weeks for dates of service 2011 going forward If you have refunded the State by a check watch and make sure they do not double recover the money If they do you will have to get your check and list of people you refunded and send it to providersupportmichigangov They have stated they have fixed the pricing logic to pay it correctly going forward Watch and make sure they are paying the correct amount if not you will have to again pull the information from the coinsurance payer and send it to providersupportmichigangov

For dates of service prior to 2011 you will have to return the Money per the Medicaid manual

Medicaid providers performing self audits may discover an overpayment situation and wish to return theMedicaid overpayment to MDHHS This process should only be used when the provider is unable to claimadjust or it is not practical to claim adjust Sending in a check will not correct the underlying claim(s)data Providers must

10487071048707 Document why the money is being returned (ie provider self audit) and identify provider NPIinformation address dates of service and specialty area (ie durable medical items pharmacyphysician practice hospital etc) and include a basic information letter

10487071048707 Attach an excel spreadsheet document with the Tax ID billing NPIs and associated amounts (ifmultiple IDs exist for the entity) for the MDHHS Accounting Office to apply credit to

10487071048707 Make check payable to State of Michigan and mail to the MDHHSCashierrsquos Unit - Attn Bureauof Finance-MCU (Refer to the Directory Appendix for contact information) 9

Lawsuit DHS Changes on Caregivers

bull A recent Michigan Court of Appeals decision has played havoc on the rules surrounding payments to non-family caregivers DHS rules regarding payments to caregivers state that payments are divestment in two situations 1) prospective payments made to any caregiver (family or non-related) before care is provided and 2) payments to family caregivers absent a Medicaid qualified caregiving contract The Court of Appeals decision Jensen v Department of Human Services confuses the rules and applies the family caregiving contract requirements to all caregivers even professional caregiving agencies The result of the case is that payments to non-family caregivers may be divestment unless the Medicaid applicant has a contract with the caregiver meeting the extremely specific rules found in the Medicaid manual

10

TPL Medicaid Changebull Attention Providersbull Effective October 26 2015 the MDHHS Third Party Liability (TPL)

Update Other Insurance Now Online form will be updated You will now receive a confirmation number when you submit your request If an email address is added within the Requestor Information section once TPL completes your request you will receive an email with the confirmation number and the status of your request Please allow up to 10 business days for information to be verified and updated in the system Please check your spam or junk email folders if you do not receive the email after 10 business days

bull Providers with further questions can contact Provider Support by phone 1-800-292-2550 or email ProviderSupportmichigangov

bull httpsminotifytplstatemiustedpubliccoveragerequestsindex11

CHAMPS Member Screen

bull Attention Providersbull Effective September 25 2015 a change was made to the CHAMPS

system This change modified the provider view for the Member Eligibility Inquiry screen If a member no longer has active Medicaid the hyperlink to view ldquoCommercialOtherrdquo Third Party Liability (TPL) information is disabled Because TPL does not always maintain TPLOther Insurance information for members that do not have active Medicaid coverage this information was disabled to prevent inaccurate information from being reported

12

LOC dropping off Not Due to MI Health

bull If after 30 days the county hasnrsquot processed the 2565 that you have send via the central scan (517-346-9888) AND other methods you choose to use you can email the 2565 to ArdeneMartin

bull At the following mailbox I ask that you put the beneficiaries name in the subject line

bull MSA2565michigangov

13

Issues

bull PPA going all over the place

bull LOC 02 dropping off not related to MI Health

bull LOCD tons of money written off

bull Must check CHAMPS member screen all the time and you must check pending

14

Secure Email Information

bull The State of Michigan asked me to remind you when you are communicating with them regarding residents to not send Resident names Birthdates or Social security numbers in those emails What you send is the Medicaid ID and they can look it up Or if it is a billing issue send them the TCN and the Medicaid ID We have been in the practice of emailing DHS Ardene Martin Integrated Health and Provider Support with all the resident name and such

15

Medicaid amp Hospicebull LOC 07 Manage Medicaid Hospice included so plan would pay

provider and not switch to a LOC 16

bull LOC 02 Medicaid (Regular Medicaid) Hospice not included so switch to 16 Hospice and Hospice pays provider

bull LOC 11 Healthy Michigan is included in plan so plan would pay provider and not switch to LOC 16

bull LOC 005 amp 015 MI Health is up in the air waiting for CMS Currently Hospice is now included

bull LOC 16 is Hospice when they switch from Regular Medicaid only and Hospice pays provider

16

Medicaidbull Going forward please make sure that your Champs ID amp NPI on your member screen matches your facility CHAMPS ID

amp NPI for each resident and matches for all new admissions or new approved Medicaid going forward

bull The edit will be turned on soon to stop the payment of these claims if the CHAMPS ID and NPI do not Match your facility on the Medicaid member screen

bull Make sure you are putting the information correct on the 2565 you send in to DHS

bull 1 I attached a 2565 When you fill this out for new people make sure in box 12 a you put your NPI and 12 b you put your CHAMPS ID This will help the DHS case workers assign the person to your facility

bull 2 I would check all your residents CHAMPS member screens and make sure the NPI and CHAMPS ID are your facilities If not you will have to work with the DHS worker to fix this The DHS worker is the only one that can fix this

bull 3 We are having some issues where the DHS case workers will not change this NPI and CHAMPS ID to your facilities You have to get them to change it or you just will not get paid

bull 4 We situations where the resident is in a facility in Kent County (as an example) but the family lives in Livingston County and completes the applications in Livingston County You will have to get the DHS worker in Livingston to fix it not the local DHS worker in Kent County where your facility is

17

Medicaid Medicare Buy Inbull Based on the information from the Office of Personnel Management Federal

Employeersquos employed as of January 1 1983 are eligible for Medicare Part A(see page 5 of attached document) This was also confirmed with our Social Security liaison If the beneficiary did not retire before 1983 he can enroll in Medicare Part B and pay the premium and then he can enroll in Medicare Part A and pay that premium as well or may qualify for Medicare Buy in of Part A

bull If a beneficiary has an SSA document stating they are not eligible for Medicare as they do not have enough work credits the beneficiarybeneficiary representative needs to go to SSA and let them know that while they know they are not eligible for Medicare Part A free or reduced however they are eligible for Medicare Part B and would like to enroll Once the beneficiary enrolls in Medicare Part B (enrollment period January 1st ndash March 31 each year) and pays the premium then the beneficiary is eligible to either pay for Medicare Part A or that beneficiary may qualify for Medicare Part A buy in through Medicaid Once the beneficiary is enrolled in Medicare Part A and Medicare Part B Medicaid will begin to make payments on claims

18

Manage Medicaid Where are we

19

Healthy Michigan Residents

20

Healthy Michigan Medicaid Days

21

McLaren Health Plan

22

Manage Medicaid Plans January 1bull Region 1 ndash Upper Peninsula Health Planbull Region 2 ndash McLaren Health Plan Meridian Health Plan of Michigan Molina Healthcare of Michigan

UnitedHealthcare Community Planbull Region 3 ndash McLaren Health Plan Meridian Health Plan of Michigan Molina Healthcare of Michigan

UnitedHealthcare Community Planbull Region 4 ndash Blue Cross Complete of Michigan McLaren Health Plan Meridian Health Plan of Michigan Molina

Healthcare of Michigan Priority Health Choice UnitedHealthcare Community Planbull Region 5 ndash McLaren Health Plan Meridian Health Plan of Michigan Molina Healthcare of Michigan

UnitedHealthcare Community Planbull Region 6 ndash Blue Cross Complete of Michigan HAP Midwest Health Plan McLaren Health Plan Meridian Health

Plan of Michigan Molina Healthcare of Michigan UnitedHealthcare Community Planbull Region 7 ndash Blue Cross Complete of Michigan McLaren Health Plan Meridian Health Plan UnitedHealthcare

Community Planbull Region 8 ndash Aetna Better Health of Michigan McLaren Health Plan Meridian Health Plan of Michigan Molina

Healthcare of Michigan Priority Health Choice UnitedHealthcare Community Planbull Region 9 ndash Aetna Better Health of Michigan Blue Cross Complete of Michigan McLaren Health Plan Meridian

Health Plan of Michigan Molina Healthcare of Michigan UnitedHealthcare Community Planbull Region 10 ndash Aetna Better Health of Michigan Blue Cross Complete of Michigan Harbor Health Plan McLaren

Health Plan Meridian Health Plan of Michigan Molina Healthcare of Michigan Total Health Care UnitedHealthcare Community Plan 23

24

MI Health LinkWhere are we

25

MI Health Link 2565

bull This notification is being sent to providers of long term care services including nursing facilities county medical care facilities and hospital long term care units to provide clarification on the process involved with the submission of the Facility Admission Form (MSA-2565-C) for an individual enrolled in the MI Health Link program

bull The MI Health Link program covers the custodiallong term nursing facility service benefit When an individual who is enrolled in the MI Health Link program is admitted to a nursing facility for custodiallong term nursing services a disenrollment from the Integrated Care Organization (MI Health Link health plan) is NOT REQUIRED The Facility Admission Form (MSA-2565-C) should NOT be sent to the Michigan Department of Health and Human Services (MDHHS) Enrollment Services Section for a disenrollment to be processed

26

What are the Names

bull Started as Integrated Health

bull Then called MMP (Medicare Medicaid Program)

bull Duals (Also Known as Duals as in Dual Eligible)

bull Now called MI Health Link

bull Total confusion

27

MI Health Dual Eligible28

MI Health LOC

29

LOC Medicaidbull We have the new pilot program which started on March

1 2015 in Southwest Michigan Region 4 Counties Macomb Wayne and the UP You could see these patients they are dual eligible in the Pilot program in counties surrounding the pilot

bull MHL-LOC 005 (All other Facilities) or LOC 015 (County Care) These residents have to call Michigan Enrolls to dis-enroll toll-free at 1-800-975-7630 (TTY 1-888-263-5897) Monday-Friday from 8 AM to 7 PM Once they dis-enroll they will go to a LOC 02 you have to do a new LOCD

30

Medicaid Redetermination and MHL Enrollmentbull At the time of re-determination for Medicaid financial eligibility the MI

Health Link (MHL) program will not be sending beneficiaries information about this program Beneficiaries who previously opted out will not be passively enrolled according to an email from the MHL staff The MHL staff wrote

bull ldquoThere is currently no MI Health Link enrollment letter sent to beneficiaries when eligibility is re-determined A person who becomes eligible for MI Health Link enrollment may opt-in at any time

bull When Medicaid re-determination takes place the beneficiary remains in the same ICO unless that beneficiary lost Medicaid coverage If the enrollee loses Medicaid coverage and later regains it they are not passively enrolled into MI Health Link The beneficiary may choose to opt back in to the program at that time if desiredrdquo

bull MHL staff did state that about 1500 beneficiaries will be passively enrolled effective January 1 2016 These specific individuals were given normal notice of 60 and 30 days in which to opt-in or opt-out if they so chose No other large scale passive enrollment is scheduled according to the MHL staff 31

MI Health Link Portals

bull Meridian Health Planbull httpwwwmhplancommibull Amerihealthbull httpwwwamerihealthcaritasvipcarepluscomproviderself-service-

toolsindexaspxbull AetnaCoventrybull httpwwwaetnabetterhealthcomMichiganprovidersportalbull Molinabull httpwwwmolinahealthcarecommembersmien-usmemPageshomeaspxbull HAPMidwestbull httpswwwmidwesthealthplancomLoginaspxbull FidelisCentenebull wwwfidelissccommmp 32

MI Health Authorizationsbull We need to watch these authorization that the plans are giving us for the MI

Health program Some plans are assigning a diagnosis for residents in their prior authorizations They are assigning diagnosis that the residents do not even have You need to make sure these are correct diagnosis and if not you need to work with the case managers of the plans to fix the issue The authorization numbers do change

bull Make sure that any resident that is in a MI Health plan that you have a prior authorization All plans are giving different periods authorizing the residents stay in the facility You need to set up a system to make sure you always have a authorization for the period of time you are rendering the service Here is an example of time frame of authorizations

bull Meridian is authorizing 12 monthsbull Aetna is authorizing 3 monthsbull Molina is authorizing 6 monthsbull The authorization numbers need to go on your claims to the payer You need to

put the authorizations in your software and track the dates

33

MI Health Issuesbull We are seeing some issues with MI Health where the resident does not have the correct LOC or it shows

up correct on CHAMPS but ancillary providers such as Dentist and such cannot see it I think we still have some issues with the information crossing between Bridges DHS system CMS and CHAMPS It in return is creating some access of care issues If it is a true LOC issues Facilities with LOC issues need to submit the Medicaid ID numbers to the MSA-MHL-EnrollmentMichigangov box with the subject line Nursing home LOC Issue so they may work to resolve the issues

bull If it becomes an access to care issue email the information to INTEGRATEDCAREmichigangov Remember in these emails only send the Medicaid ID and explain the situation The State will work with the plans to try to fix the process or improve the process

bull We are also seeing with new admission with LOC 015 or 005 that the plans are stating they have 14 days to authorize admission These are resident in the emergency room and possibly be admitted to you for Rehab The hospital will not keep the resident in ER for 14 days and you cannot admit the resident until you have a prior authorization I would recommend when you are told this by the plan that you need to ask to speak to a manager We will have to work through this

bull Ancillary Provider You need to work with your ancillary providers such as Lab Pharmacy X-Ray Physician and such to get the to be credentialed with the plans We are hearing that some of the pharmacies are not participating with the plans this will create issues for you so I would continue to ask these groups to participate

34

LOC 02 dropping MI Health Issuesbull The passive enrollments have occurred in Macomb amp Wayne for

Medicaid dual eligible We are having the same issue we did as in the Southwest MI amp UP with the passive enrollments I am starting to hear from facilities who are checking there CHAMPS member screens that those residents that have opted out (some residents not all) have lost there 02 Make sure you are checking your CHAMPS member screen both for those that were passively enrolled and those that might have lost there 02 Medicaid that opted out

bull Facilities with LOC issues need to submit the Medicaid ID numbers to the (Only MI Health)MSA-MHL-Enrollmentmichigangov box with the subject line Nursing home LOC Issue so they may work to resolve the issues

35

PPA Offset

bull There are no co-pays deductibles or premiums in MI Health Link so there should be no need to offset the PPA with code 25 MI Health Link enrollees can continue to offset their PPA for non-program covered medical expenses (like Vision-Code 27 Dental-Code 28 and Hearing-Code 26) and use the appropriate codes to offset the PPA when billing the health plan for nursing facility services

bull Resident pay PPA when MedicareMedicaid coinsurance

36

LOCDbull Nursing Facility Level of Care Determination (NFLOCD)

bull The MI Health Link health plan will be responsible for conducting the Michigan Medicaid NFLOCD tool for enrollees seeking admission to a nursing facility For existing residents at the time of enrollment the existing NFLOCD will be adopted for capitation payment purposes The health plan will complete a new NFLCOD tool within the first 90 days of enrollment If a nursing facility resident is disenrolled from MI Health Link the nursing facility will be responsible for conducting a new NFLOCD tool in accordance with published Medicaid policy

37

MI Health Issues-New

bull INTEGRATEDCAREmichigangov

bull Email with Insurance Plan issues Case Manager Issues

38

ACOWhat are they

39

Families Receiving Letters for ACO

40

ACO What is It

bull Whats an ACObull Accountable Care Organizations (ACOs) are groups of doctors hospitals

and other health care providers who come together voluntarily to give coordinated high quality care to their Medicare patients

bull The goal of coordinated care is to ensure that patients especially the chronically ill get the right care at the right time while avoiding

unnecessary duplication of services and preventing medical errorsbull When an ACO succeeds both in delivering high-quality care and

spending health care dollars more wisely it will share in the savings it achieves for the Medicare program

41

Payroll Based JournalMandatory on July 1 2016Internet Explorer Version

Internet Explorer v 10 and v 11 will need to operate in compatibility mode

42

43

If you submit data manually should you also submit it through the XML

bull Now you have three options

bull Submit Manually only

bull Submit through the XML only

bull You are able to submit manually and using the XML

44

45

Staffing Submission Frequently Asked Questions

bull ldquoWho are direct care staffrdquo (Who do we submit data for)bull Submission of data for contract staffbull Medical directors and consultantsbull Staff switching roles or tasks throughout the daybull Hours paid vs hours worked ndash Must be verifiablebull Public postingQuality MeasuresFive Starbull Enforcementbull Voluntary submission risks (noneSo register now)

CMS defines

bull 37 job title codes that are required to match employees to the number of hours each direct care function was performed It is important to work with your teams to define the workers that contribute to each job type and how those daily worked hours are recorded and converted to a PBJ submission

bull The PBJ does include some more specific job descriptions than the 671 For example the PBJ system includes job descriptions for RNs with administrative duties and LPNs with administrative duties versus the 671rsquos more general ldquoNurses with Administrative Duties

Page 46

47

PBJ Medical Director Rolebull Physician Leadership

bull Help the facility ensure that patients have appropriate physician coverage and ensure the provision of physician and health care practitioner services and

bull Help the facility develop a process for reviewing physician and health care practitioner credentials

bull Provide specific guidance for physician performance expectations

bull Help the facility ensure that a system is in place for monitoring the performance of health care practitioners and

bull Facilitate feedback to physicians and other health care practitioners on performance and practices

bull Patient Care - Clinical Leadership

bull Participate in administrative decision-making and the development of policies and procedures related to patient care

bull Help develop approve and implement specific clinical practices for the facility to incorporate into its care-related policies and procedures including areas required by laws and regulations

bull Develop procedures and guidance for facility staff regarding contacting practitioners including information gathering and presentation change in condition assessment and when to contact the medical director

bull Review consider andor act upon consultant recommendations as appropriate that affect the facilitys resident care policies and procedures or the care of an individual resident

bull Review respond to and participate in federal state local and other external surveys and inspections and

bull Help review policies and procedures regarding the adequate protection of patients rights advance care planning and other ethical issues48

PBJ Medical Director Rolebull Quality of Care

bull Help the facility establish systems and methods for reviewing the quality and appropriateness of clinical care and other health-related services and provide appropriate feedback and

bull Participate in the facilitys quality improvement process

bull Advise on infection control issues and approve specific infection control policies to be incorporated into facility policies and procedures

bull Help the facility provide a safe and caring environment

bull Help promote employee health and safety and

bull Assist in the development and implementation of employee health policies and programs

bull Education Information and Communication

bull Promote a learning culture within the facility by educating informing and communicating

bull Provide information to help the facility provide care consistent with current standards of practice (defined as approaches to care procedures techniques and treatments that are based on research and or expert consensus and that are contained in current manuals textbooks and or publications or that are accepted adopted or promulgated by recognized organizations or national bodies)

bull Help the facility develop medical information and communication systems with staff patients and families and others

bull Represent the facility to the professional and lay community on medical and patient care issues

bull Maintain knowledge of the changing social regulatory political and economic factors that affect medical and health services of long term care patients and

bull Help establish appropriate relationships with other health care organizations

49

Dietician

bull When the dietary or food services supervisor is other than a registered dietitian the supervisor shall receive routine consultation and technical assistance from a registered dietitian (RD) Consultation time shall not be less than 4 hours every 60 days Additional consultation time may be needed based on the total number of patients incidence of nutrition-related health problems and food service management needs of the facility

50

Pharmacy Consultant

bull At least once per month a licensed pharmacist must perform a drug regimen review (DRR) for each resident The pharmacist must report any irregularities to the attending physician or director of nursing Furthermore these reports must be acted upon

51

What are the names for the Medicare Numberbull OSCAR -Online Survey Certification and Reporting

bull PTAN-PTAN number is assigned by Medicare to authenticate the provider when using the local Medicare Administrative Contractorrsquos (MAC) self-help tools like the IVR internet portal on-line application status etc Provider Transactions Access Number

bull CCN- CMS Certification Number

bull Medicare Number- example 23-

bull All of the above mean the same thing

52

QTSO

bull Once you are logged in the QTSO site bull You will have a state login to the site to access the various site specific

to your facilitybull Installing you will need administrator rights to your network

53

Medicare UpdateWhat are we seeing

54

CMS Final Rule On Returning Credits

httpswwwfederalregistergovarticles201602122016-02789medicare-program-reporting-and-returning-of-overpayments

55

Over Payment Rule

bull Medicare payments for non covered services

bull Medicare payments in excess of the allowable amount for an identified covered service

bull Errors and non reimbursable expenditures in cost reportsbull Duplicate payment

bull Receipt of Medicare payments when another payor had the primary responsibility for payment

56

Questions to MAC

bull Does the Medicare credit balance report change with this overpayment rule

bull No Medicare Credit Balances are still required at the end of each quarter

bull Will that still be the communication to let CMS or the MAC know that we have received an overpayment

bull Submission of Medicare Credit Balance is one form of communicating overpayments to CMS Other methods include submitting a voluntary refund with required claim information or the submission of a standard overpayment form

57

Questions to MAC

bull Will the MAC still deduct from a future RAbull If the recovery of the overpayment includes adjusting a claim then

the overpayment would be netted against future claims payments and reflected on the RA

bull Or will that process change with this new rulebull Process will remain the samebull Will NGS send communication out on thisbull Yes NGS will communicate this once the final rule is communicated

to the MACs by CMS However this could change depending on final CMS instructions

58

Final Rule on Returning Credits

bull Providers will want to immediately update their current policies governing overpayments in order to comply with this new rule which will take effect on March 14 2016

bull Providers and suppliers are required to use reasonable diligence to investigate credible information regarding overpayments through both proactive compliance efforts and reactive investigations

bull If an overpayment is identified then it must be repaid within 60 days An overpayment is identified when a person has or should have through the exercise of reasonable diligence determined that the person received an overpayment and quantified the amount

bull Providers and suppliers have a maximum of 8 months to report and return overpayments ndash up to 6 months to investigate and quantify the overpayment (ie to identify it) and up to 60 days to report and return the overpayment

59

Final Rule on Returning Credits

bull Providers and suppliers are required to report and return all overpayments within a 6-year lookback period

bull The cause and amount of the overpayment is irrelevant for the determination eg it was due to a mistake it was someone elsersquos fault it is a minor amount An overpayment is an overpayment and must be returned

bull Providers and suppliers must make their own determination to which entity to report and return the overpayment ie to the Medicare contractor or using the OIG Self Disclosure Protocol or the CMS Self Referral Disclosure Protocol

60

Final Rule on Returning Credits

bull Providers and suppliers may use the claims adjustment credit balance self-reported refund process or another appropriate process to report and return overpayments At this time there is no standard refund form to use

bull Failure to report and return an overpayment could subject the provider or supplier to False Claims Act liability Civil Monetary Penalties Law liability and exclusion from federal health care programs

61

P S amp R-Accountants will be asking for this information

The location you login into has changed it is now on EIDM EIDM is the acronym for CMS Enterprise Identity Management system which includes Identity Verification Access Management Authorization Assistance Workflow Tools and Identity Lifecycle Management functions

httpswwwcmsgovResearch-Statistics-Data-and-SystemsCMS-Information-TechnologyIACSCMS-Applications-Loginhtml

Go down the page and click on the PSampRSTARThis will take you to the login pagewill look the same as the old P S amp R didChanges Affecting PSampR System Access (Please Read) (posted 01292015)(Updated 5262015)is changingThe system which controls your PSampR user ID (currently IACS)The new system is referred to as EIDMThis will result in a different way to create new accounts or change passwords to existing accountsIf you already have an account in EIDM you may have to use that account for accessing PSampR after the transitionWhen is the change effectiveJune 13 2015What is staying the sameThe internet address for accessing PSampR remains the sameThe PSampR systemfunctionality is NOT changing 62

Medicare Advantage Payorsbull Medicare Advantage payors are pullingdenying payments on admissions if the patient was readmitted within 30 days after discharge The

client believes that the payors systematically denying payments for all readmissions within 30 days They believe this practice denies them due process to address whether the readmissions were justified and not due to a premature discharge of patient The payors seem to want to act like a QIO without having the same accountabilities of the QIO related to determinations of non-payment

bull Heres the QIO process under section 4240 of the QIO Manualbull 4240 - Readmission Review - (Rev 2 07-11-03)bull Readmission review involves admissions to an acute general short-term hospital occurring less than 31 calendar days from the date of

discharge from the same or another acute general short-term hospital (see sect1154(a)(13) and 42 CFR 47671(a)(8)(ii)) Neither the day of discharge nor the day of admission is counted when determining whether a readmission has occurred

bull A Medical Review Proceduresbull Obtain the appropriate medical records for the initial admission and readmission Perform case review on both stays Analyze the cases

specifically to determine whether the patient was prematurely discharged from the first confinement thus causing readmission Perform an analysis of the stay at the first hospital to determine the cause(s) and extent of any problem(s) (eg incomplete or substandard treatment) Consider the information available to the attending physician who discharged the patient from the first confinement Do not base a determination of a premature discharge on information that the physician or provider could not have known or events that could not have been anticipated at the time of discharge

bull Review both the initial admission and the readmission at the same time unless one of them has previously been reviewed In these cases use at a minimum the PRAF case summary of the other admission in addition to the medical record of the case under review

bull C Denialsbull Deny readmissions under the following circumstancesbull If the readmission was medically unnecessarybull If the readmission resulted from a premature discharge from the same hospital orbull If the readmission was a result of circumvention of PPS by the same hospital (see sect4255)bull With the QIO process there is an appeal within the QIO here the hospital is getting no opportunity to challenge the denials

63

Medicare Provider Enrollment Feebull Provider Enrollment Application Fee Amount for CY 2016bull On December 3 CMS issued a notice Provider Enrollment Application

Fee Amount for CY 2016 [CMSndash6066ndashN] Effective January 1 2016 the CY 2016 application fee is $554 for institutional providers that are

bull Initially enrolling in the Medicare or Medicaid program or the Childrens Health Insurance Program (CHIP)

bull Revalidating their Medicare Medicaid or CHIP enrollmentbull Adding a new Medicare practice locationbull This fee is required with any enrollment application submitted from

January 1 through December 31 2016

64

Medicare MAC-Higlas

bull Effective 142016 CMS has implemented a change to begin netting (offsetting) provider money across workloads within a single organization What this means is that any related providers conducting business in two different workloads (example New York and Maine) will have their money applied to any account receivables (AR) with a remaining balance owed to Medicare within both workloads For example Provider ABC is located in New York and is scheduled to receive a payment of $1000 on todays remittance advice Provider XYZ is related to provider ABC but is located in Maine and has ARs with a balance owed of $200 Provider ABCs $1000 payment will have the $200 applied against provider XYZs ARs resulting in a net payment of $800 This will be reflected on the remittance advice by the same PLB code as seen today for offsets for the $200

65

Two Midnight RuleChange January 1 2016 httpswwwcmsgovMedicareMedicare-Fee-for-Service-PaymentHospitalOutpatientPPSHospital-Outpatient-Regulations-and-Notices-ItemsCMS-1633-FChtml

66

Two Midnight Rulebull However effective January 1 2016 CMS will allow exceptions to the

Two-Midnight Benchmark to be determined on a case-by-case basis by the physician responsible for the care of the beneficiary subject to medical review Said differently Part A payment may be appropriate in some circumstances even though there is no expectation by the physician (or qualified ordering practitioner) of a two-midnight stay and one of the two pre-existing categorical exceptions (CMS ldquoinpatient onlyrdquo list and newly initiated mechanical ventilation) does not apply CMS has indicated that this change to the Two Midnight Rule is in response to stakeholder concern and CMSrsquos continued efforts to develop the most appropriate standard for determining Medicare Part A payment

67

Two Midnight Rulebull A new 42 CFR sect4123(a) provides that a patient is considered an

inpatient of a hospitalhellipif formally admitted as an inpatient pursuant to an order for inpatient admission by a physician or other qualified practitionerhellip The physician orders inpatient status when he or she expects the patient to require a stay that crosses at least 2 midnights[10] Stays expected to be shorter than at least two midnights are generally inappropriate for inpatient admission and inpatient payment under Medicare Part A unless the surgical procedure is specified by Medicare as inpatient only under sect41922(n)[11] The physicians expectationhellipshould be based on such complex medical factors as patient history and comorbidities the severity of signs and symptoms current medical needs and the risk of an adverse event[12] The physician order is part of physician certification of the medical necessity of hospital inpatient serviceshellip[13]

68

InPatient Vs Observation Conthellip

bull Physician certification which begins with an order for inpatient admission requires the physician to certify the reasons for the hospitalization the estimated time the patient will remain in the hospital and plans for post-hospital care if appropriate[14] The certification must be completed signed and documented in the medical record prior to discharge[15]

bull A physicians admission order has no presumptive weight and both the admission order and the physician certification will be evaluated in the context of the evidence in the medical record[16] CMS intends to provide additional information about what evidence in the medical record means in future instructions and manual revisions[17]

69

Two Midnight Rulebull Although the new case-by-case exception appears to be inherently

subjective to a certain extent CMS states that the following factors (among others) would be relevant to determining whether a patient requires inpatient admission under the expanded policy

bull The severity of the signs and symptoms exhibited by the patient bull The medical predictability of something adverse happening to the patient

and bull The need for diagnostic studies that appropriately are outpatient services

(that is their performance does not ordinarily require the patient to remain at the hospital for 24 hours or more)

bull CMS also notes that an inpatient admission (and Part A payment) should be ldquorare and unusualrdquo for minor surgical procedures or other treatment that is expected to keep the patient in the hospital ldquofor only a few hoursrdquo or for a period of time that ldquodoes not span at least overnightrdquo (thus a subset of stays not meeting the Two Midnight Benchmark) CMS indicates that such cases will be prioritized for medical review

70

Health Data Insights amp Medicare Plus Blue

RAC (Retrospective Audits)

71

HDI Health Data amp Med Plus Blue

bull httpwwwhealthdatainsightscombull Blue Cross Medicare Advantage Auditsbull Facilities seeing 10 to 15 requests for Medical Recordsbull In January amp Feburarybull Selected Health Data Insights because they were a premier Audit

Vendor for CMS Recovery Audit Contractor (RAC) demonstration Project They are a audit vendor for Humana

bull Providers not sending Medical Record will get technical denial and lose payments

72

Health Data InSight

bull In 2010 they began the Hospital Reviewbull Medicare Advantage encounter datandashCMS oversight of data integrity OIG

2016bull We will review CMSs oversight of MA encounter data validation and assess

the extent to which CMSrsquos Integrated Data Repository contains timely valid and complete MA encounter data In 2012 CMS began collecting from MA organizations a more comprehensive set of encounter data reflecting the items and services provided to MA plan enrollees Prior CMS and OIG audits have indicated vulnerabilities in the accuracy of data reporting by MA organizations Realizing the potential benefits of the MA encounter data for payment and program integrity oversight is contingent upon the datarsquos completeness validity and timeliness (OEI 03-15-00060 expected issue date FY 2017)

73

Pepper Reports

bull httpswwwpepperresourcesorg

bull Program for Evaluating Payment Patterns Electronic Report ( PEPPER)

bull Annually on or about April 18 2016 will be released

bull Pepper Portal httpssecurefiletmforg

74

CGI Technologies and Solutions Inc httpracbcgicomContactInfoaspxst=1

bull Indiana bull Michiganbull Minnesotabull Illinoisbull Kentuckybull Ohiobull Wisconsin CGI Technologies and Solutions Incbull For general and administrative questions regarding client service outreach

quality assurance or project-specific issues contactbull 1877316RACB (7222)bull Email racbcgicom Tamara Tate Tamaratatecmshhsgovbull 4107861288

75

CGI Federal RAC

bull CGI Federal RAC Region Bbull Email racbcgicombull Phone 1-877-316-RACB (7222)bull Mailing Addressbull Send medical records as followsbull Medical records for Indiana Illinois Kentucky Michigan Ohio Wisconsin

Minnesota DME and Home Health CGI Federal Inc Attn RACB Imaging Dept 1001 Lakeside Ave Suite 800 Cleveland OH 44114

bull If submitting paper records please send medical records as follows For Therapy Reviews CGI Federal Inc Attn RACB Imaging 1001 Lakeside Avenue Suite 800 Cleveland OH 44114

76

How to survive RAC Audit

bull National health expenditures totaled $1679 Billion in 2003 bull National health expenditures were 153 of GROSS Domestic Product

(GDP) in 2003 bull Health care cost increasing at +9 per year bull Doomsday predictions of Medicare running out bull Congressional Action

77

RAC Audits

bull Medicare Modernization Act (MMA) of 2003Mandated a three year audit demonstration project 2005-2008

bull Appoint audit contractors to review Medicare billings for proper coding DRG assignment and medical necessity

bull Audits will apply to all health care providers (hospitals physicians homecare dme etc)

bull Audit contractors to be paid on a contingency basis a percentage of overpayments recovered

78

How Did we get here

bull Overpayments collected due to errors in Medically Unnecessary Services ndash 40

bull Incorrectly Coded ndash 35

bull Other ndash 17

bull NoInsufficient Documentation ndash 8

79

Where are we now

bull All RACrsquos completed required provider outreachAccess to Medicare billing data base given to all RAC RAC review methodology

bull Automated Review-Black amp White Issues (current) bull DRG Validation-complex review (current) bull Complex Review for coding errors (current) bull DME Medical Necessity Reviews ndashcomplex review (calendar year

2010) bull Medical Necessity Reviews-complex review (calendar year 2010)

80

RAC Reviews

bull Responsibilities of the Team Leader bull Must learn each insurance provider participating in a RAC or RAC type

program bull What are their operating rulesbull What is their appeal process Time limits

May be different process for each insurance provider bull Develop a response team

Identify who does what when why and alternate bull individual

Build and develop a manual process Review of computerized system

81

Priority Health SCIO Health Analytics

bull httpswwwsciohealthanalyticscomcore-capabilitiespayment-integrityfacility-auditsskilled-nursing-facility-audits

bull Claims for Medicare members treated at Skilled Nursing Facilities are reimbursed based on the patientsrsquo RUG (Resource Utilization Group) score which is determined using the Minimum Data Set (MDS) Using SCIOs robust analytics claims andor providers that merit review are selected for audit SCIOs auditors conduct a detailed review of the complete medical record and associated MDS to determine if the billed RUG score is valid In the event the review determines that an incorrect RUG score was billed SCIOreg provides the valid score reports the reason the change was necessary and calculates the resulting overpayment

82

+ Cheer

Onward and Upward she shall prevail We are here to care for the residents and provide a wonderful

service

13 83

84

References

bull Priority Healthbull Blue Crossbull Medicaidbull Medicare

85

  • Medicare Mange Care amp Medicaid Changes in the New World We Live In
  • Medicaid
  • NEW Medicaid Change MIlogin
  • Blueprint for Health Innovation MI
  • Provider Enrollment Electronic Signature Form Submission Process MSA 15-54
  • Provider Enrollment Electronic Signature Form Submission Process
  • Provider Enrollment Domain Administrator
  • Medicaid Coinsurance Medicare Advantage
  • Slide Number 9
  • Lawsuit DHS Changes on Caregivers
  • TPL Medicaid Change
  • CHAMPS Member Screen
  • LOC dropping off Not Due to MI Health
  • Issues
  • Secure Email Information
  • Medicaid amp Hospice
  • Medicaid
  • Medicaid Medicare Buy In
  • Manage Medicaid
  • Healthy Michigan Residents
  • Healthy Michigan Medicaid Days
  • McLaren Health Plan
  • Manage Medicaid Plans January 1
  • Slide Number 24
  • MI Health Link
  • MI Health Link 2565
  • What are the Names
  • MI Health Dual Eligible
  • MI Health LOC
  • LOC Medicaid
  • Medicaid Redetermination and MHL Enrollment
  • MI Health Link Portals
  • MI Health Authorizations
  • MI Health Issues
  • LOC 02 dropping MI Health Issues
  • PPA Offset
  • LOCD
  • MI Health Issues-New
  • ACO
  • Families Receiving Letters for ACO
  • ACO What is It
  • Payroll Based Journal
  • Slide Number 43
  • If you submit data manually should you also submit it through the XML
  • Staffing Submission Frequently Asked Questions
  • CMS defines
  • Slide Number 47
  • PBJ Medical Director Role
  • PBJ Medical Director Role
  • Dietician
  • Pharmacy Consultant
  • What are the names for the Medicare Number
  • QTSO
  • Medicare Update
  • CMS Final Rule On Returning Credits
  • Over Payment Rule
  • Questions to MAC
  • Questions to MAC
  • Final Rule on Returning Credits
  • Final Rule on Returning Credits
  • Final Rule on Returning Credits
  • Slide Number 62
  • Medicare Advantage Payors
  • Medicare Provider Enrollment Fee
  • Medicare MAC-Higlas
  • Two Midnight Rule
  • Two Midnight Rule
  • Two Midnight Rule
  • InPatient Vs Observation Conthellip
  • Two Midnight Rule
  • Health Data Insights amp Medicare Plus Blue
  • HDI Health Data amp Med Plus Blue
  • Health Data InSight
  • Pepper Reports
  • CGI Technologies and Solutions Inc httpracbcgicomContactInfoaspxst=1
  • CGI Federal RAC
  • How to survive RAC Audit
  • RAC Audits
  • How Did we get here
  • Where are we now
  • RAC Reviews
  • Priority Health SCIO Health Analytics
  • Cheer
  • References
Page 10: Medicare, Mange Care & Medicaid Changes in the New World we live in

Lawsuit DHS Changes on Caregivers

bull A recent Michigan Court of Appeals decision has played havoc on the rules surrounding payments to non-family caregivers DHS rules regarding payments to caregivers state that payments are divestment in two situations 1) prospective payments made to any caregiver (family or non-related) before care is provided and 2) payments to family caregivers absent a Medicaid qualified caregiving contract The Court of Appeals decision Jensen v Department of Human Services confuses the rules and applies the family caregiving contract requirements to all caregivers even professional caregiving agencies The result of the case is that payments to non-family caregivers may be divestment unless the Medicaid applicant has a contract with the caregiver meeting the extremely specific rules found in the Medicaid manual

10

TPL Medicaid Changebull Attention Providersbull Effective October 26 2015 the MDHHS Third Party Liability (TPL)

Update Other Insurance Now Online form will be updated You will now receive a confirmation number when you submit your request If an email address is added within the Requestor Information section once TPL completes your request you will receive an email with the confirmation number and the status of your request Please allow up to 10 business days for information to be verified and updated in the system Please check your spam or junk email folders if you do not receive the email after 10 business days

bull Providers with further questions can contact Provider Support by phone 1-800-292-2550 or email ProviderSupportmichigangov

bull httpsminotifytplstatemiustedpubliccoveragerequestsindex11

CHAMPS Member Screen

bull Attention Providersbull Effective September 25 2015 a change was made to the CHAMPS

system This change modified the provider view for the Member Eligibility Inquiry screen If a member no longer has active Medicaid the hyperlink to view ldquoCommercialOtherrdquo Third Party Liability (TPL) information is disabled Because TPL does not always maintain TPLOther Insurance information for members that do not have active Medicaid coverage this information was disabled to prevent inaccurate information from being reported

12

LOC dropping off Not Due to MI Health

bull If after 30 days the county hasnrsquot processed the 2565 that you have send via the central scan (517-346-9888) AND other methods you choose to use you can email the 2565 to ArdeneMartin

bull At the following mailbox I ask that you put the beneficiaries name in the subject line

bull MSA2565michigangov

13

Issues

bull PPA going all over the place

bull LOC 02 dropping off not related to MI Health

bull LOCD tons of money written off

bull Must check CHAMPS member screen all the time and you must check pending

14

Secure Email Information

bull The State of Michigan asked me to remind you when you are communicating with them regarding residents to not send Resident names Birthdates or Social security numbers in those emails What you send is the Medicaid ID and they can look it up Or if it is a billing issue send them the TCN and the Medicaid ID We have been in the practice of emailing DHS Ardene Martin Integrated Health and Provider Support with all the resident name and such

15

Medicaid amp Hospicebull LOC 07 Manage Medicaid Hospice included so plan would pay

provider and not switch to a LOC 16

bull LOC 02 Medicaid (Regular Medicaid) Hospice not included so switch to 16 Hospice and Hospice pays provider

bull LOC 11 Healthy Michigan is included in plan so plan would pay provider and not switch to LOC 16

bull LOC 005 amp 015 MI Health is up in the air waiting for CMS Currently Hospice is now included

bull LOC 16 is Hospice when they switch from Regular Medicaid only and Hospice pays provider

16

Medicaidbull Going forward please make sure that your Champs ID amp NPI on your member screen matches your facility CHAMPS ID

amp NPI for each resident and matches for all new admissions or new approved Medicaid going forward

bull The edit will be turned on soon to stop the payment of these claims if the CHAMPS ID and NPI do not Match your facility on the Medicaid member screen

bull Make sure you are putting the information correct on the 2565 you send in to DHS

bull 1 I attached a 2565 When you fill this out for new people make sure in box 12 a you put your NPI and 12 b you put your CHAMPS ID This will help the DHS case workers assign the person to your facility

bull 2 I would check all your residents CHAMPS member screens and make sure the NPI and CHAMPS ID are your facilities If not you will have to work with the DHS worker to fix this The DHS worker is the only one that can fix this

bull 3 We are having some issues where the DHS case workers will not change this NPI and CHAMPS ID to your facilities You have to get them to change it or you just will not get paid

bull 4 We situations where the resident is in a facility in Kent County (as an example) but the family lives in Livingston County and completes the applications in Livingston County You will have to get the DHS worker in Livingston to fix it not the local DHS worker in Kent County where your facility is

17

Medicaid Medicare Buy Inbull Based on the information from the Office of Personnel Management Federal

Employeersquos employed as of January 1 1983 are eligible for Medicare Part A(see page 5 of attached document) This was also confirmed with our Social Security liaison If the beneficiary did not retire before 1983 he can enroll in Medicare Part B and pay the premium and then he can enroll in Medicare Part A and pay that premium as well or may qualify for Medicare Buy in of Part A

bull If a beneficiary has an SSA document stating they are not eligible for Medicare as they do not have enough work credits the beneficiarybeneficiary representative needs to go to SSA and let them know that while they know they are not eligible for Medicare Part A free or reduced however they are eligible for Medicare Part B and would like to enroll Once the beneficiary enrolls in Medicare Part B (enrollment period January 1st ndash March 31 each year) and pays the premium then the beneficiary is eligible to either pay for Medicare Part A or that beneficiary may qualify for Medicare Part A buy in through Medicaid Once the beneficiary is enrolled in Medicare Part A and Medicare Part B Medicaid will begin to make payments on claims

18

Manage Medicaid Where are we

19

Healthy Michigan Residents

20

Healthy Michigan Medicaid Days

21

McLaren Health Plan

22

Manage Medicaid Plans January 1bull Region 1 ndash Upper Peninsula Health Planbull Region 2 ndash McLaren Health Plan Meridian Health Plan of Michigan Molina Healthcare of Michigan

UnitedHealthcare Community Planbull Region 3 ndash McLaren Health Plan Meridian Health Plan of Michigan Molina Healthcare of Michigan

UnitedHealthcare Community Planbull Region 4 ndash Blue Cross Complete of Michigan McLaren Health Plan Meridian Health Plan of Michigan Molina

Healthcare of Michigan Priority Health Choice UnitedHealthcare Community Planbull Region 5 ndash McLaren Health Plan Meridian Health Plan of Michigan Molina Healthcare of Michigan

UnitedHealthcare Community Planbull Region 6 ndash Blue Cross Complete of Michigan HAP Midwest Health Plan McLaren Health Plan Meridian Health

Plan of Michigan Molina Healthcare of Michigan UnitedHealthcare Community Planbull Region 7 ndash Blue Cross Complete of Michigan McLaren Health Plan Meridian Health Plan UnitedHealthcare

Community Planbull Region 8 ndash Aetna Better Health of Michigan McLaren Health Plan Meridian Health Plan of Michigan Molina

Healthcare of Michigan Priority Health Choice UnitedHealthcare Community Planbull Region 9 ndash Aetna Better Health of Michigan Blue Cross Complete of Michigan McLaren Health Plan Meridian

Health Plan of Michigan Molina Healthcare of Michigan UnitedHealthcare Community Planbull Region 10 ndash Aetna Better Health of Michigan Blue Cross Complete of Michigan Harbor Health Plan McLaren

Health Plan Meridian Health Plan of Michigan Molina Healthcare of Michigan Total Health Care UnitedHealthcare Community Plan 23

24

MI Health LinkWhere are we

25

MI Health Link 2565

bull This notification is being sent to providers of long term care services including nursing facilities county medical care facilities and hospital long term care units to provide clarification on the process involved with the submission of the Facility Admission Form (MSA-2565-C) for an individual enrolled in the MI Health Link program

bull The MI Health Link program covers the custodiallong term nursing facility service benefit When an individual who is enrolled in the MI Health Link program is admitted to a nursing facility for custodiallong term nursing services a disenrollment from the Integrated Care Organization (MI Health Link health plan) is NOT REQUIRED The Facility Admission Form (MSA-2565-C) should NOT be sent to the Michigan Department of Health and Human Services (MDHHS) Enrollment Services Section for a disenrollment to be processed

26

What are the Names

bull Started as Integrated Health

bull Then called MMP (Medicare Medicaid Program)

bull Duals (Also Known as Duals as in Dual Eligible)

bull Now called MI Health Link

bull Total confusion

27

MI Health Dual Eligible28

MI Health LOC

29

LOC Medicaidbull We have the new pilot program which started on March

1 2015 in Southwest Michigan Region 4 Counties Macomb Wayne and the UP You could see these patients they are dual eligible in the Pilot program in counties surrounding the pilot

bull MHL-LOC 005 (All other Facilities) or LOC 015 (County Care) These residents have to call Michigan Enrolls to dis-enroll toll-free at 1-800-975-7630 (TTY 1-888-263-5897) Monday-Friday from 8 AM to 7 PM Once they dis-enroll they will go to a LOC 02 you have to do a new LOCD

30

Medicaid Redetermination and MHL Enrollmentbull At the time of re-determination for Medicaid financial eligibility the MI

Health Link (MHL) program will not be sending beneficiaries information about this program Beneficiaries who previously opted out will not be passively enrolled according to an email from the MHL staff The MHL staff wrote

bull ldquoThere is currently no MI Health Link enrollment letter sent to beneficiaries when eligibility is re-determined A person who becomes eligible for MI Health Link enrollment may opt-in at any time

bull When Medicaid re-determination takes place the beneficiary remains in the same ICO unless that beneficiary lost Medicaid coverage If the enrollee loses Medicaid coverage and later regains it they are not passively enrolled into MI Health Link The beneficiary may choose to opt back in to the program at that time if desiredrdquo

bull MHL staff did state that about 1500 beneficiaries will be passively enrolled effective January 1 2016 These specific individuals were given normal notice of 60 and 30 days in which to opt-in or opt-out if they so chose No other large scale passive enrollment is scheduled according to the MHL staff 31

MI Health Link Portals

bull Meridian Health Planbull httpwwwmhplancommibull Amerihealthbull httpwwwamerihealthcaritasvipcarepluscomproviderself-service-

toolsindexaspxbull AetnaCoventrybull httpwwwaetnabetterhealthcomMichiganprovidersportalbull Molinabull httpwwwmolinahealthcarecommembersmien-usmemPageshomeaspxbull HAPMidwestbull httpswwwmidwesthealthplancomLoginaspxbull FidelisCentenebull wwwfidelissccommmp 32

MI Health Authorizationsbull We need to watch these authorization that the plans are giving us for the MI

Health program Some plans are assigning a diagnosis for residents in their prior authorizations They are assigning diagnosis that the residents do not even have You need to make sure these are correct diagnosis and if not you need to work with the case managers of the plans to fix the issue The authorization numbers do change

bull Make sure that any resident that is in a MI Health plan that you have a prior authorization All plans are giving different periods authorizing the residents stay in the facility You need to set up a system to make sure you always have a authorization for the period of time you are rendering the service Here is an example of time frame of authorizations

bull Meridian is authorizing 12 monthsbull Aetna is authorizing 3 monthsbull Molina is authorizing 6 monthsbull The authorization numbers need to go on your claims to the payer You need to

put the authorizations in your software and track the dates

33

MI Health Issuesbull We are seeing some issues with MI Health where the resident does not have the correct LOC or it shows

up correct on CHAMPS but ancillary providers such as Dentist and such cannot see it I think we still have some issues with the information crossing between Bridges DHS system CMS and CHAMPS It in return is creating some access of care issues If it is a true LOC issues Facilities with LOC issues need to submit the Medicaid ID numbers to the MSA-MHL-EnrollmentMichigangov box with the subject line Nursing home LOC Issue so they may work to resolve the issues

bull If it becomes an access to care issue email the information to INTEGRATEDCAREmichigangov Remember in these emails only send the Medicaid ID and explain the situation The State will work with the plans to try to fix the process or improve the process

bull We are also seeing with new admission with LOC 015 or 005 that the plans are stating they have 14 days to authorize admission These are resident in the emergency room and possibly be admitted to you for Rehab The hospital will not keep the resident in ER for 14 days and you cannot admit the resident until you have a prior authorization I would recommend when you are told this by the plan that you need to ask to speak to a manager We will have to work through this

bull Ancillary Provider You need to work with your ancillary providers such as Lab Pharmacy X-Ray Physician and such to get the to be credentialed with the plans We are hearing that some of the pharmacies are not participating with the plans this will create issues for you so I would continue to ask these groups to participate

34

LOC 02 dropping MI Health Issuesbull The passive enrollments have occurred in Macomb amp Wayne for

Medicaid dual eligible We are having the same issue we did as in the Southwest MI amp UP with the passive enrollments I am starting to hear from facilities who are checking there CHAMPS member screens that those residents that have opted out (some residents not all) have lost there 02 Make sure you are checking your CHAMPS member screen both for those that were passively enrolled and those that might have lost there 02 Medicaid that opted out

bull Facilities with LOC issues need to submit the Medicaid ID numbers to the (Only MI Health)MSA-MHL-Enrollmentmichigangov box with the subject line Nursing home LOC Issue so they may work to resolve the issues

35

PPA Offset

bull There are no co-pays deductibles or premiums in MI Health Link so there should be no need to offset the PPA with code 25 MI Health Link enrollees can continue to offset their PPA for non-program covered medical expenses (like Vision-Code 27 Dental-Code 28 and Hearing-Code 26) and use the appropriate codes to offset the PPA when billing the health plan for nursing facility services

bull Resident pay PPA when MedicareMedicaid coinsurance

36

LOCDbull Nursing Facility Level of Care Determination (NFLOCD)

bull The MI Health Link health plan will be responsible for conducting the Michigan Medicaid NFLOCD tool for enrollees seeking admission to a nursing facility For existing residents at the time of enrollment the existing NFLOCD will be adopted for capitation payment purposes The health plan will complete a new NFLCOD tool within the first 90 days of enrollment If a nursing facility resident is disenrolled from MI Health Link the nursing facility will be responsible for conducting a new NFLOCD tool in accordance with published Medicaid policy

37

MI Health Issues-New

bull INTEGRATEDCAREmichigangov

bull Email with Insurance Plan issues Case Manager Issues

38

ACOWhat are they

39

Families Receiving Letters for ACO

40

ACO What is It

bull Whats an ACObull Accountable Care Organizations (ACOs) are groups of doctors hospitals

and other health care providers who come together voluntarily to give coordinated high quality care to their Medicare patients

bull The goal of coordinated care is to ensure that patients especially the chronically ill get the right care at the right time while avoiding

unnecessary duplication of services and preventing medical errorsbull When an ACO succeeds both in delivering high-quality care and

spending health care dollars more wisely it will share in the savings it achieves for the Medicare program

41

Payroll Based JournalMandatory on July 1 2016Internet Explorer Version

Internet Explorer v 10 and v 11 will need to operate in compatibility mode

42

43

If you submit data manually should you also submit it through the XML

bull Now you have three options

bull Submit Manually only

bull Submit through the XML only

bull You are able to submit manually and using the XML

44

45

Staffing Submission Frequently Asked Questions

bull ldquoWho are direct care staffrdquo (Who do we submit data for)bull Submission of data for contract staffbull Medical directors and consultantsbull Staff switching roles or tasks throughout the daybull Hours paid vs hours worked ndash Must be verifiablebull Public postingQuality MeasuresFive Starbull Enforcementbull Voluntary submission risks (noneSo register now)

CMS defines

bull 37 job title codes that are required to match employees to the number of hours each direct care function was performed It is important to work with your teams to define the workers that contribute to each job type and how those daily worked hours are recorded and converted to a PBJ submission

bull The PBJ does include some more specific job descriptions than the 671 For example the PBJ system includes job descriptions for RNs with administrative duties and LPNs with administrative duties versus the 671rsquos more general ldquoNurses with Administrative Duties

Page 46

47

PBJ Medical Director Rolebull Physician Leadership

bull Help the facility ensure that patients have appropriate physician coverage and ensure the provision of physician and health care practitioner services and

bull Help the facility develop a process for reviewing physician and health care practitioner credentials

bull Provide specific guidance for physician performance expectations

bull Help the facility ensure that a system is in place for monitoring the performance of health care practitioners and

bull Facilitate feedback to physicians and other health care practitioners on performance and practices

bull Patient Care - Clinical Leadership

bull Participate in administrative decision-making and the development of policies and procedures related to patient care

bull Help develop approve and implement specific clinical practices for the facility to incorporate into its care-related policies and procedures including areas required by laws and regulations

bull Develop procedures and guidance for facility staff regarding contacting practitioners including information gathering and presentation change in condition assessment and when to contact the medical director

bull Review consider andor act upon consultant recommendations as appropriate that affect the facilitys resident care policies and procedures or the care of an individual resident

bull Review respond to and participate in federal state local and other external surveys and inspections and

bull Help review policies and procedures regarding the adequate protection of patients rights advance care planning and other ethical issues48

PBJ Medical Director Rolebull Quality of Care

bull Help the facility establish systems and methods for reviewing the quality and appropriateness of clinical care and other health-related services and provide appropriate feedback and

bull Participate in the facilitys quality improvement process

bull Advise on infection control issues and approve specific infection control policies to be incorporated into facility policies and procedures

bull Help the facility provide a safe and caring environment

bull Help promote employee health and safety and

bull Assist in the development and implementation of employee health policies and programs

bull Education Information and Communication

bull Promote a learning culture within the facility by educating informing and communicating

bull Provide information to help the facility provide care consistent with current standards of practice (defined as approaches to care procedures techniques and treatments that are based on research and or expert consensus and that are contained in current manuals textbooks and or publications or that are accepted adopted or promulgated by recognized organizations or national bodies)

bull Help the facility develop medical information and communication systems with staff patients and families and others

bull Represent the facility to the professional and lay community on medical and patient care issues

bull Maintain knowledge of the changing social regulatory political and economic factors that affect medical and health services of long term care patients and

bull Help establish appropriate relationships with other health care organizations

49

Dietician

bull When the dietary or food services supervisor is other than a registered dietitian the supervisor shall receive routine consultation and technical assistance from a registered dietitian (RD) Consultation time shall not be less than 4 hours every 60 days Additional consultation time may be needed based on the total number of patients incidence of nutrition-related health problems and food service management needs of the facility

50

Pharmacy Consultant

bull At least once per month a licensed pharmacist must perform a drug regimen review (DRR) for each resident The pharmacist must report any irregularities to the attending physician or director of nursing Furthermore these reports must be acted upon

51

What are the names for the Medicare Numberbull OSCAR -Online Survey Certification and Reporting

bull PTAN-PTAN number is assigned by Medicare to authenticate the provider when using the local Medicare Administrative Contractorrsquos (MAC) self-help tools like the IVR internet portal on-line application status etc Provider Transactions Access Number

bull CCN- CMS Certification Number

bull Medicare Number- example 23-

bull All of the above mean the same thing

52

QTSO

bull Once you are logged in the QTSO site bull You will have a state login to the site to access the various site specific

to your facilitybull Installing you will need administrator rights to your network

53

Medicare UpdateWhat are we seeing

54

CMS Final Rule On Returning Credits

httpswwwfederalregistergovarticles201602122016-02789medicare-program-reporting-and-returning-of-overpayments

55

Over Payment Rule

bull Medicare payments for non covered services

bull Medicare payments in excess of the allowable amount for an identified covered service

bull Errors and non reimbursable expenditures in cost reportsbull Duplicate payment

bull Receipt of Medicare payments when another payor had the primary responsibility for payment

56

Questions to MAC

bull Does the Medicare credit balance report change with this overpayment rule

bull No Medicare Credit Balances are still required at the end of each quarter

bull Will that still be the communication to let CMS or the MAC know that we have received an overpayment

bull Submission of Medicare Credit Balance is one form of communicating overpayments to CMS Other methods include submitting a voluntary refund with required claim information or the submission of a standard overpayment form

57

Questions to MAC

bull Will the MAC still deduct from a future RAbull If the recovery of the overpayment includes adjusting a claim then

the overpayment would be netted against future claims payments and reflected on the RA

bull Or will that process change with this new rulebull Process will remain the samebull Will NGS send communication out on thisbull Yes NGS will communicate this once the final rule is communicated

to the MACs by CMS However this could change depending on final CMS instructions

58

Final Rule on Returning Credits

bull Providers will want to immediately update their current policies governing overpayments in order to comply with this new rule which will take effect on March 14 2016

bull Providers and suppliers are required to use reasonable diligence to investigate credible information regarding overpayments through both proactive compliance efforts and reactive investigations

bull If an overpayment is identified then it must be repaid within 60 days An overpayment is identified when a person has or should have through the exercise of reasonable diligence determined that the person received an overpayment and quantified the amount

bull Providers and suppliers have a maximum of 8 months to report and return overpayments ndash up to 6 months to investigate and quantify the overpayment (ie to identify it) and up to 60 days to report and return the overpayment

59

Final Rule on Returning Credits

bull Providers and suppliers are required to report and return all overpayments within a 6-year lookback period

bull The cause and amount of the overpayment is irrelevant for the determination eg it was due to a mistake it was someone elsersquos fault it is a minor amount An overpayment is an overpayment and must be returned

bull Providers and suppliers must make their own determination to which entity to report and return the overpayment ie to the Medicare contractor or using the OIG Self Disclosure Protocol or the CMS Self Referral Disclosure Protocol

60

Final Rule on Returning Credits

bull Providers and suppliers may use the claims adjustment credit balance self-reported refund process or another appropriate process to report and return overpayments At this time there is no standard refund form to use

bull Failure to report and return an overpayment could subject the provider or supplier to False Claims Act liability Civil Monetary Penalties Law liability and exclusion from federal health care programs

61

P S amp R-Accountants will be asking for this information

The location you login into has changed it is now on EIDM EIDM is the acronym for CMS Enterprise Identity Management system which includes Identity Verification Access Management Authorization Assistance Workflow Tools and Identity Lifecycle Management functions

httpswwwcmsgovResearch-Statistics-Data-and-SystemsCMS-Information-TechnologyIACSCMS-Applications-Loginhtml

Go down the page and click on the PSampRSTARThis will take you to the login pagewill look the same as the old P S amp R didChanges Affecting PSampR System Access (Please Read) (posted 01292015)(Updated 5262015)is changingThe system which controls your PSampR user ID (currently IACS)The new system is referred to as EIDMThis will result in a different way to create new accounts or change passwords to existing accountsIf you already have an account in EIDM you may have to use that account for accessing PSampR after the transitionWhen is the change effectiveJune 13 2015What is staying the sameThe internet address for accessing PSampR remains the sameThe PSampR systemfunctionality is NOT changing 62

Medicare Advantage Payorsbull Medicare Advantage payors are pullingdenying payments on admissions if the patient was readmitted within 30 days after discharge The

client believes that the payors systematically denying payments for all readmissions within 30 days They believe this practice denies them due process to address whether the readmissions were justified and not due to a premature discharge of patient The payors seem to want to act like a QIO without having the same accountabilities of the QIO related to determinations of non-payment

bull Heres the QIO process under section 4240 of the QIO Manualbull 4240 - Readmission Review - (Rev 2 07-11-03)bull Readmission review involves admissions to an acute general short-term hospital occurring less than 31 calendar days from the date of

discharge from the same or another acute general short-term hospital (see sect1154(a)(13) and 42 CFR 47671(a)(8)(ii)) Neither the day of discharge nor the day of admission is counted when determining whether a readmission has occurred

bull A Medical Review Proceduresbull Obtain the appropriate medical records for the initial admission and readmission Perform case review on both stays Analyze the cases

specifically to determine whether the patient was prematurely discharged from the first confinement thus causing readmission Perform an analysis of the stay at the first hospital to determine the cause(s) and extent of any problem(s) (eg incomplete or substandard treatment) Consider the information available to the attending physician who discharged the patient from the first confinement Do not base a determination of a premature discharge on information that the physician or provider could not have known or events that could not have been anticipated at the time of discharge

bull Review both the initial admission and the readmission at the same time unless one of them has previously been reviewed In these cases use at a minimum the PRAF case summary of the other admission in addition to the medical record of the case under review

bull C Denialsbull Deny readmissions under the following circumstancesbull If the readmission was medically unnecessarybull If the readmission resulted from a premature discharge from the same hospital orbull If the readmission was a result of circumvention of PPS by the same hospital (see sect4255)bull With the QIO process there is an appeal within the QIO here the hospital is getting no opportunity to challenge the denials

63

Medicare Provider Enrollment Feebull Provider Enrollment Application Fee Amount for CY 2016bull On December 3 CMS issued a notice Provider Enrollment Application

Fee Amount for CY 2016 [CMSndash6066ndashN] Effective January 1 2016 the CY 2016 application fee is $554 for institutional providers that are

bull Initially enrolling in the Medicare or Medicaid program or the Childrens Health Insurance Program (CHIP)

bull Revalidating their Medicare Medicaid or CHIP enrollmentbull Adding a new Medicare practice locationbull This fee is required with any enrollment application submitted from

January 1 through December 31 2016

64

Medicare MAC-Higlas

bull Effective 142016 CMS has implemented a change to begin netting (offsetting) provider money across workloads within a single organization What this means is that any related providers conducting business in two different workloads (example New York and Maine) will have their money applied to any account receivables (AR) with a remaining balance owed to Medicare within both workloads For example Provider ABC is located in New York and is scheduled to receive a payment of $1000 on todays remittance advice Provider XYZ is related to provider ABC but is located in Maine and has ARs with a balance owed of $200 Provider ABCs $1000 payment will have the $200 applied against provider XYZs ARs resulting in a net payment of $800 This will be reflected on the remittance advice by the same PLB code as seen today for offsets for the $200

65

Two Midnight RuleChange January 1 2016 httpswwwcmsgovMedicareMedicare-Fee-for-Service-PaymentHospitalOutpatientPPSHospital-Outpatient-Regulations-and-Notices-ItemsCMS-1633-FChtml

66

Two Midnight Rulebull However effective January 1 2016 CMS will allow exceptions to the

Two-Midnight Benchmark to be determined on a case-by-case basis by the physician responsible for the care of the beneficiary subject to medical review Said differently Part A payment may be appropriate in some circumstances even though there is no expectation by the physician (or qualified ordering practitioner) of a two-midnight stay and one of the two pre-existing categorical exceptions (CMS ldquoinpatient onlyrdquo list and newly initiated mechanical ventilation) does not apply CMS has indicated that this change to the Two Midnight Rule is in response to stakeholder concern and CMSrsquos continued efforts to develop the most appropriate standard for determining Medicare Part A payment

67

Two Midnight Rulebull A new 42 CFR sect4123(a) provides that a patient is considered an

inpatient of a hospitalhellipif formally admitted as an inpatient pursuant to an order for inpatient admission by a physician or other qualified practitionerhellip The physician orders inpatient status when he or she expects the patient to require a stay that crosses at least 2 midnights[10] Stays expected to be shorter than at least two midnights are generally inappropriate for inpatient admission and inpatient payment under Medicare Part A unless the surgical procedure is specified by Medicare as inpatient only under sect41922(n)[11] The physicians expectationhellipshould be based on such complex medical factors as patient history and comorbidities the severity of signs and symptoms current medical needs and the risk of an adverse event[12] The physician order is part of physician certification of the medical necessity of hospital inpatient serviceshellip[13]

68

InPatient Vs Observation Conthellip

bull Physician certification which begins with an order for inpatient admission requires the physician to certify the reasons for the hospitalization the estimated time the patient will remain in the hospital and plans for post-hospital care if appropriate[14] The certification must be completed signed and documented in the medical record prior to discharge[15]

bull A physicians admission order has no presumptive weight and both the admission order and the physician certification will be evaluated in the context of the evidence in the medical record[16] CMS intends to provide additional information about what evidence in the medical record means in future instructions and manual revisions[17]

69

Two Midnight Rulebull Although the new case-by-case exception appears to be inherently

subjective to a certain extent CMS states that the following factors (among others) would be relevant to determining whether a patient requires inpatient admission under the expanded policy

bull The severity of the signs and symptoms exhibited by the patient bull The medical predictability of something adverse happening to the patient

and bull The need for diagnostic studies that appropriately are outpatient services

(that is their performance does not ordinarily require the patient to remain at the hospital for 24 hours or more)

bull CMS also notes that an inpatient admission (and Part A payment) should be ldquorare and unusualrdquo for minor surgical procedures or other treatment that is expected to keep the patient in the hospital ldquofor only a few hoursrdquo or for a period of time that ldquodoes not span at least overnightrdquo (thus a subset of stays not meeting the Two Midnight Benchmark) CMS indicates that such cases will be prioritized for medical review

70

Health Data Insights amp Medicare Plus Blue

RAC (Retrospective Audits)

71

HDI Health Data amp Med Plus Blue

bull httpwwwhealthdatainsightscombull Blue Cross Medicare Advantage Auditsbull Facilities seeing 10 to 15 requests for Medical Recordsbull In January amp Feburarybull Selected Health Data Insights because they were a premier Audit

Vendor for CMS Recovery Audit Contractor (RAC) demonstration Project They are a audit vendor for Humana

bull Providers not sending Medical Record will get technical denial and lose payments

72

Health Data InSight

bull In 2010 they began the Hospital Reviewbull Medicare Advantage encounter datandashCMS oversight of data integrity OIG

2016bull We will review CMSs oversight of MA encounter data validation and assess

the extent to which CMSrsquos Integrated Data Repository contains timely valid and complete MA encounter data In 2012 CMS began collecting from MA organizations a more comprehensive set of encounter data reflecting the items and services provided to MA plan enrollees Prior CMS and OIG audits have indicated vulnerabilities in the accuracy of data reporting by MA organizations Realizing the potential benefits of the MA encounter data for payment and program integrity oversight is contingent upon the datarsquos completeness validity and timeliness (OEI 03-15-00060 expected issue date FY 2017)

73

Pepper Reports

bull httpswwwpepperresourcesorg

bull Program for Evaluating Payment Patterns Electronic Report ( PEPPER)

bull Annually on or about April 18 2016 will be released

bull Pepper Portal httpssecurefiletmforg

74

CGI Technologies and Solutions Inc httpracbcgicomContactInfoaspxst=1

bull Indiana bull Michiganbull Minnesotabull Illinoisbull Kentuckybull Ohiobull Wisconsin CGI Technologies and Solutions Incbull For general and administrative questions regarding client service outreach

quality assurance or project-specific issues contactbull 1877316RACB (7222)bull Email racbcgicom Tamara Tate Tamaratatecmshhsgovbull 4107861288

75

CGI Federal RAC

bull CGI Federal RAC Region Bbull Email racbcgicombull Phone 1-877-316-RACB (7222)bull Mailing Addressbull Send medical records as followsbull Medical records for Indiana Illinois Kentucky Michigan Ohio Wisconsin

Minnesota DME and Home Health CGI Federal Inc Attn RACB Imaging Dept 1001 Lakeside Ave Suite 800 Cleveland OH 44114

bull If submitting paper records please send medical records as follows For Therapy Reviews CGI Federal Inc Attn RACB Imaging 1001 Lakeside Avenue Suite 800 Cleveland OH 44114

76

How to survive RAC Audit

bull National health expenditures totaled $1679 Billion in 2003 bull National health expenditures were 153 of GROSS Domestic Product

(GDP) in 2003 bull Health care cost increasing at +9 per year bull Doomsday predictions of Medicare running out bull Congressional Action

77

RAC Audits

bull Medicare Modernization Act (MMA) of 2003Mandated a three year audit demonstration project 2005-2008

bull Appoint audit contractors to review Medicare billings for proper coding DRG assignment and medical necessity

bull Audits will apply to all health care providers (hospitals physicians homecare dme etc)

bull Audit contractors to be paid on a contingency basis a percentage of overpayments recovered

78

How Did we get here

bull Overpayments collected due to errors in Medically Unnecessary Services ndash 40

bull Incorrectly Coded ndash 35

bull Other ndash 17

bull NoInsufficient Documentation ndash 8

79

Where are we now

bull All RACrsquos completed required provider outreachAccess to Medicare billing data base given to all RAC RAC review methodology

bull Automated Review-Black amp White Issues (current) bull DRG Validation-complex review (current) bull Complex Review for coding errors (current) bull DME Medical Necessity Reviews ndashcomplex review (calendar year

2010) bull Medical Necessity Reviews-complex review (calendar year 2010)

80

RAC Reviews

bull Responsibilities of the Team Leader bull Must learn each insurance provider participating in a RAC or RAC type

program bull What are their operating rulesbull What is their appeal process Time limits

May be different process for each insurance provider bull Develop a response team

Identify who does what when why and alternate bull individual

Build and develop a manual process Review of computerized system

81

Priority Health SCIO Health Analytics

bull httpswwwsciohealthanalyticscomcore-capabilitiespayment-integrityfacility-auditsskilled-nursing-facility-audits

bull Claims for Medicare members treated at Skilled Nursing Facilities are reimbursed based on the patientsrsquo RUG (Resource Utilization Group) score which is determined using the Minimum Data Set (MDS) Using SCIOs robust analytics claims andor providers that merit review are selected for audit SCIOs auditors conduct a detailed review of the complete medical record and associated MDS to determine if the billed RUG score is valid In the event the review determines that an incorrect RUG score was billed SCIOreg provides the valid score reports the reason the change was necessary and calculates the resulting overpayment

82

+ Cheer

Onward and Upward she shall prevail We are here to care for the residents and provide a wonderful

service

13 83

84

References

bull Priority Healthbull Blue Crossbull Medicaidbull Medicare

85

  • Medicare Mange Care amp Medicaid Changes in the New World We Live In
  • Medicaid
  • NEW Medicaid Change MIlogin
  • Blueprint for Health Innovation MI
  • Provider Enrollment Electronic Signature Form Submission Process MSA 15-54
  • Provider Enrollment Electronic Signature Form Submission Process
  • Provider Enrollment Domain Administrator
  • Medicaid Coinsurance Medicare Advantage
  • Slide Number 9
  • Lawsuit DHS Changes on Caregivers
  • TPL Medicaid Change
  • CHAMPS Member Screen
  • LOC dropping off Not Due to MI Health
  • Issues
  • Secure Email Information
  • Medicaid amp Hospice
  • Medicaid
  • Medicaid Medicare Buy In
  • Manage Medicaid
  • Healthy Michigan Residents
  • Healthy Michigan Medicaid Days
  • McLaren Health Plan
  • Manage Medicaid Plans January 1
  • Slide Number 24
  • MI Health Link
  • MI Health Link 2565
  • What are the Names
  • MI Health Dual Eligible
  • MI Health LOC
  • LOC Medicaid
  • Medicaid Redetermination and MHL Enrollment
  • MI Health Link Portals
  • MI Health Authorizations
  • MI Health Issues
  • LOC 02 dropping MI Health Issues
  • PPA Offset
  • LOCD
  • MI Health Issues-New
  • ACO
  • Families Receiving Letters for ACO
  • ACO What is It
  • Payroll Based Journal
  • Slide Number 43
  • If you submit data manually should you also submit it through the XML
  • Staffing Submission Frequently Asked Questions
  • CMS defines
  • Slide Number 47
  • PBJ Medical Director Role
  • PBJ Medical Director Role
  • Dietician
  • Pharmacy Consultant
  • What are the names for the Medicare Number
  • QTSO
  • Medicare Update
  • CMS Final Rule On Returning Credits
  • Over Payment Rule
  • Questions to MAC
  • Questions to MAC
  • Final Rule on Returning Credits
  • Final Rule on Returning Credits
  • Final Rule on Returning Credits
  • Slide Number 62
  • Medicare Advantage Payors
  • Medicare Provider Enrollment Fee
  • Medicare MAC-Higlas
  • Two Midnight Rule
  • Two Midnight Rule
  • Two Midnight Rule
  • InPatient Vs Observation Conthellip
  • Two Midnight Rule
  • Health Data Insights amp Medicare Plus Blue
  • HDI Health Data amp Med Plus Blue
  • Health Data InSight
  • Pepper Reports
  • CGI Technologies and Solutions Inc httpracbcgicomContactInfoaspxst=1
  • CGI Federal RAC
  • How to survive RAC Audit
  • RAC Audits
  • How Did we get here
  • Where are we now
  • RAC Reviews
  • Priority Health SCIO Health Analytics
  • Cheer
  • References
Page 11: Medicare, Mange Care & Medicaid Changes in the New World we live in

TPL Medicaid Changebull Attention Providersbull Effective October 26 2015 the MDHHS Third Party Liability (TPL)

Update Other Insurance Now Online form will be updated You will now receive a confirmation number when you submit your request If an email address is added within the Requestor Information section once TPL completes your request you will receive an email with the confirmation number and the status of your request Please allow up to 10 business days for information to be verified and updated in the system Please check your spam or junk email folders if you do not receive the email after 10 business days

bull Providers with further questions can contact Provider Support by phone 1-800-292-2550 or email ProviderSupportmichigangov

bull httpsminotifytplstatemiustedpubliccoveragerequestsindex11

CHAMPS Member Screen

bull Attention Providersbull Effective September 25 2015 a change was made to the CHAMPS

system This change modified the provider view for the Member Eligibility Inquiry screen If a member no longer has active Medicaid the hyperlink to view ldquoCommercialOtherrdquo Third Party Liability (TPL) information is disabled Because TPL does not always maintain TPLOther Insurance information for members that do not have active Medicaid coverage this information was disabled to prevent inaccurate information from being reported

12

LOC dropping off Not Due to MI Health

bull If after 30 days the county hasnrsquot processed the 2565 that you have send via the central scan (517-346-9888) AND other methods you choose to use you can email the 2565 to ArdeneMartin

bull At the following mailbox I ask that you put the beneficiaries name in the subject line

bull MSA2565michigangov

13

Issues

bull PPA going all over the place

bull LOC 02 dropping off not related to MI Health

bull LOCD tons of money written off

bull Must check CHAMPS member screen all the time and you must check pending

14

Secure Email Information

bull The State of Michigan asked me to remind you when you are communicating with them regarding residents to not send Resident names Birthdates or Social security numbers in those emails What you send is the Medicaid ID and they can look it up Or if it is a billing issue send them the TCN and the Medicaid ID We have been in the practice of emailing DHS Ardene Martin Integrated Health and Provider Support with all the resident name and such

15

Medicaid amp Hospicebull LOC 07 Manage Medicaid Hospice included so plan would pay

provider and not switch to a LOC 16

bull LOC 02 Medicaid (Regular Medicaid) Hospice not included so switch to 16 Hospice and Hospice pays provider

bull LOC 11 Healthy Michigan is included in plan so plan would pay provider and not switch to LOC 16

bull LOC 005 amp 015 MI Health is up in the air waiting for CMS Currently Hospice is now included

bull LOC 16 is Hospice when they switch from Regular Medicaid only and Hospice pays provider

16

Medicaidbull Going forward please make sure that your Champs ID amp NPI on your member screen matches your facility CHAMPS ID

amp NPI for each resident and matches for all new admissions or new approved Medicaid going forward

bull The edit will be turned on soon to stop the payment of these claims if the CHAMPS ID and NPI do not Match your facility on the Medicaid member screen

bull Make sure you are putting the information correct on the 2565 you send in to DHS

bull 1 I attached a 2565 When you fill this out for new people make sure in box 12 a you put your NPI and 12 b you put your CHAMPS ID This will help the DHS case workers assign the person to your facility

bull 2 I would check all your residents CHAMPS member screens and make sure the NPI and CHAMPS ID are your facilities If not you will have to work with the DHS worker to fix this The DHS worker is the only one that can fix this

bull 3 We are having some issues where the DHS case workers will not change this NPI and CHAMPS ID to your facilities You have to get them to change it or you just will not get paid

bull 4 We situations where the resident is in a facility in Kent County (as an example) but the family lives in Livingston County and completes the applications in Livingston County You will have to get the DHS worker in Livingston to fix it not the local DHS worker in Kent County where your facility is

17

Medicaid Medicare Buy Inbull Based on the information from the Office of Personnel Management Federal

Employeersquos employed as of January 1 1983 are eligible for Medicare Part A(see page 5 of attached document) This was also confirmed with our Social Security liaison If the beneficiary did not retire before 1983 he can enroll in Medicare Part B and pay the premium and then he can enroll in Medicare Part A and pay that premium as well or may qualify for Medicare Buy in of Part A

bull If a beneficiary has an SSA document stating they are not eligible for Medicare as they do not have enough work credits the beneficiarybeneficiary representative needs to go to SSA and let them know that while they know they are not eligible for Medicare Part A free or reduced however they are eligible for Medicare Part B and would like to enroll Once the beneficiary enrolls in Medicare Part B (enrollment period January 1st ndash March 31 each year) and pays the premium then the beneficiary is eligible to either pay for Medicare Part A or that beneficiary may qualify for Medicare Part A buy in through Medicaid Once the beneficiary is enrolled in Medicare Part A and Medicare Part B Medicaid will begin to make payments on claims

18

Manage Medicaid Where are we

19

Healthy Michigan Residents

20

Healthy Michigan Medicaid Days

21

McLaren Health Plan

22

Manage Medicaid Plans January 1bull Region 1 ndash Upper Peninsula Health Planbull Region 2 ndash McLaren Health Plan Meridian Health Plan of Michigan Molina Healthcare of Michigan

UnitedHealthcare Community Planbull Region 3 ndash McLaren Health Plan Meridian Health Plan of Michigan Molina Healthcare of Michigan

UnitedHealthcare Community Planbull Region 4 ndash Blue Cross Complete of Michigan McLaren Health Plan Meridian Health Plan of Michigan Molina

Healthcare of Michigan Priority Health Choice UnitedHealthcare Community Planbull Region 5 ndash McLaren Health Plan Meridian Health Plan of Michigan Molina Healthcare of Michigan

UnitedHealthcare Community Planbull Region 6 ndash Blue Cross Complete of Michigan HAP Midwest Health Plan McLaren Health Plan Meridian Health

Plan of Michigan Molina Healthcare of Michigan UnitedHealthcare Community Planbull Region 7 ndash Blue Cross Complete of Michigan McLaren Health Plan Meridian Health Plan UnitedHealthcare

Community Planbull Region 8 ndash Aetna Better Health of Michigan McLaren Health Plan Meridian Health Plan of Michigan Molina

Healthcare of Michigan Priority Health Choice UnitedHealthcare Community Planbull Region 9 ndash Aetna Better Health of Michigan Blue Cross Complete of Michigan McLaren Health Plan Meridian

Health Plan of Michigan Molina Healthcare of Michigan UnitedHealthcare Community Planbull Region 10 ndash Aetna Better Health of Michigan Blue Cross Complete of Michigan Harbor Health Plan McLaren

Health Plan Meridian Health Plan of Michigan Molina Healthcare of Michigan Total Health Care UnitedHealthcare Community Plan 23

24

MI Health LinkWhere are we

25

MI Health Link 2565

bull This notification is being sent to providers of long term care services including nursing facilities county medical care facilities and hospital long term care units to provide clarification on the process involved with the submission of the Facility Admission Form (MSA-2565-C) for an individual enrolled in the MI Health Link program

bull The MI Health Link program covers the custodiallong term nursing facility service benefit When an individual who is enrolled in the MI Health Link program is admitted to a nursing facility for custodiallong term nursing services a disenrollment from the Integrated Care Organization (MI Health Link health plan) is NOT REQUIRED The Facility Admission Form (MSA-2565-C) should NOT be sent to the Michigan Department of Health and Human Services (MDHHS) Enrollment Services Section for a disenrollment to be processed

26

What are the Names

bull Started as Integrated Health

bull Then called MMP (Medicare Medicaid Program)

bull Duals (Also Known as Duals as in Dual Eligible)

bull Now called MI Health Link

bull Total confusion

27

MI Health Dual Eligible28

MI Health LOC

29

LOC Medicaidbull We have the new pilot program which started on March

1 2015 in Southwest Michigan Region 4 Counties Macomb Wayne and the UP You could see these patients they are dual eligible in the Pilot program in counties surrounding the pilot

bull MHL-LOC 005 (All other Facilities) or LOC 015 (County Care) These residents have to call Michigan Enrolls to dis-enroll toll-free at 1-800-975-7630 (TTY 1-888-263-5897) Monday-Friday from 8 AM to 7 PM Once they dis-enroll they will go to a LOC 02 you have to do a new LOCD

30

Medicaid Redetermination and MHL Enrollmentbull At the time of re-determination for Medicaid financial eligibility the MI

Health Link (MHL) program will not be sending beneficiaries information about this program Beneficiaries who previously opted out will not be passively enrolled according to an email from the MHL staff The MHL staff wrote

bull ldquoThere is currently no MI Health Link enrollment letter sent to beneficiaries when eligibility is re-determined A person who becomes eligible for MI Health Link enrollment may opt-in at any time

bull When Medicaid re-determination takes place the beneficiary remains in the same ICO unless that beneficiary lost Medicaid coverage If the enrollee loses Medicaid coverage and later regains it they are not passively enrolled into MI Health Link The beneficiary may choose to opt back in to the program at that time if desiredrdquo

bull MHL staff did state that about 1500 beneficiaries will be passively enrolled effective January 1 2016 These specific individuals were given normal notice of 60 and 30 days in which to opt-in or opt-out if they so chose No other large scale passive enrollment is scheduled according to the MHL staff 31

MI Health Link Portals

bull Meridian Health Planbull httpwwwmhplancommibull Amerihealthbull httpwwwamerihealthcaritasvipcarepluscomproviderself-service-

toolsindexaspxbull AetnaCoventrybull httpwwwaetnabetterhealthcomMichiganprovidersportalbull Molinabull httpwwwmolinahealthcarecommembersmien-usmemPageshomeaspxbull HAPMidwestbull httpswwwmidwesthealthplancomLoginaspxbull FidelisCentenebull wwwfidelissccommmp 32

MI Health Authorizationsbull We need to watch these authorization that the plans are giving us for the MI

Health program Some plans are assigning a diagnosis for residents in their prior authorizations They are assigning diagnosis that the residents do not even have You need to make sure these are correct diagnosis and if not you need to work with the case managers of the plans to fix the issue The authorization numbers do change

bull Make sure that any resident that is in a MI Health plan that you have a prior authorization All plans are giving different periods authorizing the residents stay in the facility You need to set up a system to make sure you always have a authorization for the period of time you are rendering the service Here is an example of time frame of authorizations

bull Meridian is authorizing 12 monthsbull Aetna is authorizing 3 monthsbull Molina is authorizing 6 monthsbull The authorization numbers need to go on your claims to the payer You need to

put the authorizations in your software and track the dates

33

MI Health Issuesbull We are seeing some issues with MI Health where the resident does not have the correct LOC or it shows

up correct on CHAMPS but ancillary providers such as Dentist and such cannot see it I think we still have some issues with the information crossing between Bridges DHS system CMS and CHAMPS It in return is creating some access of care issues If it is a true LOC issues Facilities with LOC issues need to submit the Medicaid ID numbers to the MSA-MHL-EnrollmentMichigangov box with the subject line Nursing home LOC Issue so they may work to resolve the issues

bull If it becomes an access to care issue email the information to INTEGRATEDCAREmichigangov Remember in these emails only send the Medicaid ID and explain the situation The State will work with the plans to try to fix the process or improve the process

bull We are also seeing with new admission with LOC 015 or 005 that the plans are stating they have 14 days to authorize admission These are resident in the emergency room and possibly be admitted to you for Rehab The hospital will not keep the resident in ER for 14 days and you cannot admit the resident until you have a prior authorization I would recommend when you are told this by the plan that you need to ask to speak to a manager We will have to work through this

bull Ancillary Provider You need to work with your ancillary providers such as Lab Pharmacy X-Ray Physician and such to get the to be credentialed with the plans We are hearing that some of the pharmacies are not participating with the plans this will create issues for you so I would continue to ask these groups to participate

34

LOC 02 dropping MI Health Issuesbull The passive enrollments have occurred in Macomb amp Wayne for

Medicaid dual eligible We are having the same issue we did as in the Southwest MI amp UP with the passive enrollments I am starting to hear from facilities who are checking there CHAMPS member screens that those residents that have opted out (some residents not all) have lost there 02 Make sure you are checking your CHAMPS member screen both for those that were passively enrolled and those that might have lost there 02 Medicaid that opted out

bull Facilities with LOC issues need to submit the Medicaid ID numbers to the (Only MI Health)MSA-MHL-Enrollmentmichigangov box with the subject line Nursing home LOC Issue so they may work to resolve the issues

35

PPA Offset

bull There are no co-pays deductibles or premiums in MI Health Link so there should be no need to offset the PPA with code 25 MI Health Link enrollees can continue to offset their PPA for non-program covered medical expenses (like Vision-Code 27 Dental-Code 28 and Hearing-Code 26) and use the appropriate codes to offset the PPA when billing the health plan for nursing facility services

bull Resident pay PPA when MedicareMedicaid coinsurance

36

LOCDbull Nursing Facility Level of Care Determination (NFLOCD)

bull The MI Health Link health plan will be responsible for conducting the Michigan Medicaid NFLOCD tool for enrollees seeking admission to a nursing facility For existing residents at the time of enrollment the existing NFLOCD will be adopted for capitation payment purposes The health plan will complete a new NFLCOD tool within the first 90 days of enrollment If a nursing facility resident is disenrolled from MI Health Link the nursing facility will be responsible for conducting a new NFLOCD tool in accordance with published Medicaid policy

37

MI Health Issues-New

bull INTEGRATEDCAREmichigangov

bull Email with Insurance Plan issues Case Manager Issues

38

ACOWhat are they

39

Families Receiving Letters for ACO

40

ACO What is It

bull Whats an ACObull Accountable Care Organizations (ACOs) are groups of doctors hospitals

and other health care providers who come together voluntarily to give coordinated high quality care to their Medicare patients

bull The goal of coordinated care is to ensure that patients especially the chronically ill get the right care at the right time while avoiding

unnecessary duplication of services and preventing medical errorsbull When an ACO succeeds both in delivering high-quality care and

spending health care dollars more wisely it will share in the savings it achieves for the Medicare program

41

Payroll Based JournalMandatory on July 1 2016Internet Explorer Version

Internet Explorer v 10 and v 11 will need to operate in compatibility mode

42

43

If you submit data manually should you also submit it through the XML

bull Now you have three options

bull Submit Manually only

bull Submit through the XML only

bull You are able to submit manually and using the XML

44

45

Staffing Submission Frequently Asked Questions

bull ldquoWho are direct care staffrdquo (Who do we submit data for)bull Submission of data for contract staffbull Medical directors and consultantsbull Staff switching roles or tasks throughout the daybull Hours paid vs hours worked ndash Must be verifiablebull Public postingQuality MeasuresFive Starbull Enforcementbull Voluntary submission risks (noneSo register now)

CMS defines

bull 37 job title codes that are required to match employees to the number of hours each direct care function was performed It is important to work with your teams to define the workers that contribute to each job type and how those daily worked hours are recorded and converted to a PBJ submission

bull The PBJ does include some more specific job descriptions than the 671 For example the PBJ system includes job descriptions for RNs with administrative duties and LPNs with administrative duties versus the 671rsquos more general ldquoNurses with Administrative Duties

Page 46

47

PBJ Medical Director Rolebull Physician Leadership

bull Help the facility ensure that patients have appropriate physician coverage and ensure the provision of physician and health care practitioner services and

bull Help the facility develop a process for reviewing physician and health care practitioner credentials

bull Provide specific guidance for physician performance expectations

bull Help the facility ensure that a system is in place for monitoring the performance of health care practitioners and

bull Facilitate feedback to physicians and other health care practitioners on performance and practices

bull Patient Care - Clinical Leadership

bull Participate in administrative decision-making and the development of policies and procedures related to patient care

bull Help develop approve and implement specific clinical practices for the facility to incorporate into its care-related policies and procedures including areas required by laws and regulations

bull Develop procedures and guidance for facility staff regarding contacting practitioners including information gathering and presentation change in condition assessment and when to contact the medical director

bull Review consider andor act upon consultant recommendations as appropriate that affect the facilitys resident care policies and procedures or the care of an individual resident

bull Review respond to and participate in federal state local and other external surveys and inspections and

bull Help review policies and procedures regarding the adequate protection of patients rights advance care planning and other ethical issues48

PBJ Medical Director Rolebull Quality of Care

bull Help the facility establish systems and methods for reviewing the quality and appropriateness of clinical care and other health-related services and provide appropriate feedback and

bull Participate in the facilitys quality improvement process

bull Advise on infection control issues and approve specific infection control policies to be incorporated into facility policies and procedures

bull Help the facility provide a safe and caring environment

bull Help promote employee health and safety and

bull Assist in the development and implementation of employee health policies and programs

bull Education Information and Communication

bull Promote a learning culture within the facility by educating informing and communicating

bull Provide information to help the facility provide care consistent with current standards of practice (defined as approaches to care procedures techniques and treatments that are based on research and or expert consensus and that are contained in current manuals textbooks and or publications or that are accepted adopted or promulgated by recognized organizations or national bodies)

bull Help the facility develop medical information and communication systems with staff patients and families and others

bull Represent the facility to the professional and lay community on medical and patient care issues

bull Maintain knowledge of the changing social regulatory political and economic factors that affect medical and health services of long term care patients and

bull Help establish appropriate relationships with other health care organizations

49

Dietician

bull When the dietary or food services supervisor is other than a registered dietitian the supervisor shall receive routine consultation and technical assistance from a registered dietitian (RD) Consultation time shall not be less than 4 hours every 60 days Additional consultation time may be needed based on the total number of patients incidence of nutrition-related health problems and food service management needs of the facility

50

Pharmacy Consultant

bull At least once per month a licensed pharmacist must perform a drug regimen review (DRR) for each resident The pharmacist must report any irregularities to the attending physician or director of nursing Furthermore these reports must be acted upon

51

What are the names for the Medicare Numberbull OSCAR -Online Survey Certification and Reporting

bull PTAN-PTAN number is assigned by Medicare to authenticate the provider when using the local Medicare Administrative Contractorrsquos (MAC) self-help tools like the IVR internet portal on-line application status etc Provider Transactions Access Number

bull CCN- CMS Certification Number

bull Medicare Number- example 23-

bull All of the above mean the same thing

52

QTSO

bull Once you are logged in the QTSO site bull You will have a state login to the site to access the various site specific

to your facilitybull Installing you will need administrator rights to your network

53

Medicare UpdateWhat are we seeing

54

CMS Final Rule On Returning Credits

httpswwwfederalregistergovarticles201602122016-02789medicare-program-reporting-and-returning-of-overpayments

55

Over Payment Rule

bull Medicare payments for non covered services

bull Medicare payments in excess of the allowable amount for an identified covered service

bull Errors and non reimbursable expenditures in cost reportsbull Duplicate payment

bull Receipt of Medicare payments when another payor had the primary responsibility for payment

56

Questions to MAC

bull Does the Medicare credit balance report change with this overpayment rule

bull No Medicare Credit Balances are still required at the end of each quarter

bull Will that still be the communication to let CMS or the MAC know that we have received an overpayment

bull Submission of Medicare Credit Balance is one form of communicating overpayments to CMS Other methods include submitting a voluntary refund with required claim information or the submission of a standard overpayment form

57

Questions to MAC

bull Will the MAC still deduct from a future RAbull If the recovery of the overpayment includes adjusting a claim then

the overpayment would be netted against future claims payments and reflected on the RA

bull Or will that process change with this new rulebull Process will remain the samebull Will NGS send communication out on thisbull Yes NGS will communicate this once the final rule is communicated

to the MACs by CMS However this could change depending on final CMS instructions

58

Final Rule on Returning Credits

bull Providers will want to immediately update their current policies governing overpayments in order to comply with this new rule which will take effect on March 14 2016

bull Providers and suppliers are required to use reasonable diligence to investigate credible information regarding overpayments through both proactive compliance efforts and reactive investigations

bull If an overpayment is identified then it must be repaid within 60 days An overpayment is identified when a person has or should have through the exercise of reasonable diligence determined that the person received an overpayment and quantified the amount

bull Providers and suppliers have a maximum of 8 months to report and return overpayments ndash up to 6 months to investigate and quantify the overpayment (ie to identify it) and up to 60 days to report and return the overpayment

59

Final Rule on Returning Credits

bull Providers and suppliers are required to report and return all overpayments within a 6-year lookback period

bull The cause and amount of the overpayment is irrelevant for the determination eg it was due to a mistake it was someone elsersquos fault it is a minor amount An overpayment is an overpayment and must be returned

bull Providers and suppliers must make their own determination to which entity to report and return the overpayment ie to the Medicare contractor or using the OIG Self Disclosure Protocol or the CMS Self Referral Disclosure Protocol

60

Final Rule on Returning Credits

bull Providers and suppliers may use the claims adjustment credit balance self-reported refund process or another appropriate process to report and return overpayments At this time there is no standard refund form to use

bull Failure to report and return an overpayment could subject the provider or supplier to False Claims Act liability Civil Monetary Penalties Law liability and exclusion from federal health care programs

61

P S amp R-Accountants will be asking for this information

The location you login into has changed it is now on EIDM EIDM is the acronym for CMS Enterprise Identity Management system which includes Identity Verification Access Management Authorization Assistance Workflow Tools and Identity Lifecycle Management functions

httpswwwcmsgovResearch-Statistics-Data-and-SystemsCMS-Information-TechnologyIACSCMS-Applications-Loginhtml

Go down the page and click on the PSampRSTARThis will take you to the login pagewill look the same as the old P S amp R didChanges Affecting PSampR System Access (Please Read) (posted 01292015)(Updated 5262015)is changingThe system which controls your PSampR user ID (currently IACS)The new system is referred to as EIDMThis will result in a different way to create new accounts or change passwords to existing accountsIf you already have an account in EIDM you may have to use that account for accessing PSampR after the transitionWhen is the change effectiveJune 13 2015What is staying the sameThe internet address for accessing PSampR remains the sameThe PSampR systemfunctionality is NOT changing 62

Medicare Advantage Payorsbull Medicare Advantage payors are pullingdenying payments on admissions if the patient was readmitted within 30 days after discharge The

client believes that the payors systematically denying payments for all readmissions within 30 days They believe this practice denies them due process to address whether the readmissions were justified and not due to a premature discharge of patient The payors seem to want to act like a QIO without having the same accountabilities of the QIO related to determinations of non-payment

bull Heres the QIO process under section 4240 of the QIO Manualbull 4240 - Readmission Review - (Rev 2 07-11-03)bull Readmission review involves admissions to an acute general short-term hospital occurring less than 31 calendar days from the date of

discharge from the same or another acute general short-term hospital (see sect1154(a)(13) and 42 CFR 47671(a)(8)(ii)) Neither the day of discharge nor the day of admission is counted when determining whether a readmission has occurred

bull A Medical Review Proceduresbull Obtain the appropriate medical records for the initial admission and readmission Perform case review on both stays Analyze the cases

specifically to determine whether the patient was prematurely discharged from the first confinement thus causing readmission Perform an analysis of the stay at the first hospital to determine the cause(s) and extent of any problem(s) (eg incomplete or substandard treatment) Consider the information available to the attending physician who discharged the patient from the first confinement Do not base a determination of a premature discharge on information that the physician or provider could not have known or events that could not have been anticipated at the time of discharge

bull Review both the initial admission and the readmission at the same time unless one of them has previously been reviewed In these cases use at a minimum the PRAF case summary of the other admission in addition to the medical record of the case under review

bull C Denialsbull Deny readmissions under the following circumstancesbull If the readmission was medically unnecessarybull If the readmission resulted from a premature discharge from the same hospital orbull If the readmission was a result of circumvention of PPS by the same hospital (see sect4255)bull With the QIO process there is an appeal within the QIO here the hospital is getting no opportunity to challenge the denials

63

Medicare Provider Enrollment Feebull Provider Enrollment Application Fee Amount for CY 2016bull On December 3 CMS issued a notice Provider Enrollment Application

Fee Amount for CY 2016 [CMSndash6066ndashN] Effective January 1 2016 the CY 2016 application fee is $554 for institutional providers that are

bull Initially enrolling in the Medicare or Medicaid program or the Childrens Health Insurance Program (CHIP)

bull Revalidating their Medicare Medicaid or CHIP enrollmentbull Adding a new Medicare practice locationbull This fee is required with any enrollment application submitted from

January 1 through December 31 2016

64

Medicare MAC-Higlas

bull Effective 142016 CMS has implemented a change to begin netting (offsetting) provider money across workloads within a single organization What this means is that any related providers conducting business in two different workloads (example New York and Maine) will have their money applied to any account receivables (AR) with a remaining balance owed to Medicare within both workloads For example Provider ABC is located in New York and is scheduled to receive a payment of $1000 on todays remittance advice Provider XYZ is related to provider ABC but is located in Maine and has ARs with a balance owed of $200 Provider ABCs $1000 payment will have the $200 applied against provider XYZs ARs resulting in a net payment of $800 This will be reflected on the remittance advice by the same PLB code as seen today for offsets for the $200

65

Two Midnight RuleChange January 1 2016 httpswwwcmsgovMedicareMedicare-Fee-for-Service-PaymentHospitalOutpatientPPSHospital-Outpatient-Regulations-and-Notices-ItemsCMS-1633-FChtml

66

Two Midnight Rulebull However effective January 1 2016 CMS will allow exceptions to the

Two-Midnight Benchmark to be determined on a case-by-case basis by the physician responsible for the care of the beneficiary subject to medical review Said differently Part A payment may be appropriate in some circumstances even though there is no expectation by the physician (or qualified ordering practitioner) of a two-midnight stay and one of the two pre-existing categorical exceptions (CMS ldquoinpatient onlyrdquo list and newly initiated mechanical ventilation) does not apply CMS has indicated that this change to the Two Midnight Rule is in response to stakeholder concern and CMSrsquos continued efforts to develop the most appropriate standard for determining Medicare Part A payment

67

Two Midnight Rulebull A new 42 CFR sect4123(a) provides that a patient is considered an

inpatient of a hospitalhellipif formally admitted as an inpatient pursuant to an order for inpatient admission by a physician or other qualified practitionerhellip The physician orders inpatient status when he or she expects the patient to require a stay that crosses at least 2 midnights[10] Stays expected to be shorter than at least two midnights are generally inappropriate for inpatient admission and inpatient payment under Medicare Part A unless the surgical procedure is specified by Medicare as inpatient only under sect41922(n)[11] The physicians expectationhellipshould be based on such complex medical factors as patient history and comorbidities the severity of signs and symptoms current medical needs and the risk of an adverse event[12] The physician order is part of physician certification of the medical necessity of hospital inpatient serviceshellip[13]

68

InPatient Vs Observation Conthellip

bull Physician certification which begins with an order for inpatient admission requires the physician to certify the reasons for the hospitalization the estimated time the patient will remain in the hospital and plans for post-hospital care if appropriate[14] The certification must be completed signed and documented in the medical record prior to discharge[15]

bull A physicians admission order has no presumptive weight and both the admission order and the physician certification will be evaluated in the context of the evidence in the medical record[16] CMS intends to provide additional information about what evidence in the medical record means in future instructions and manual revisions[17]

69

Two Midnight Rulebull Although the new case-by-case exception appears to be inherently

subjective to a certain extent CMS states that the following factors (among others) would be relevant to determining whether a patient requires inpatient admission under the expanded policy

bull The severity of the signs and symptoms exhibited by the patient bull The medical predictability of something adverse happening to the patient

and bull The need for diagnostic studies that appropriately are outpatient services

(that is their performance does not ordinarily require the patient to remain at the hospital for 24 hours or more)

bull CMS also notes that an inpatient admission (and Part A payment) should be ldquorare and unusualrdquo for minor surgical procedures or other treatment that is expected to keep the patient in the hospital ldquofor only a few hoursrdquo or for a period of time that ldquodoes not span at least overnightrdquo (thus a subset of stays not meeting the Two Midnight Benchmark) CMS indicates that such cases will be prioritized for medical review

70

Health Data Insights amp Medicare Plus Blue

RAC (Retrospective Audits)

71

HDI Health Data amp Med Plus Blue

bull httpwwwhealthdatainsightscombull Blue Cross Medicare Advantage Auditsbull Facilities seeing 10 to 15 requests for Medical Recordsbull In January amp Feburarybull Selected Health Data Insights because they were a premier Audit

Vendor for CMS Recovery Audit Contractor (RAC) demonstration Project They are a audit vendor for Humana

bull Providers not sending Medical Record will get technical denial and lose payments

72

Health Data InSight

bull In 2010 they began the Hospital Reviewbull Medicare Advantage encounter datandashCMS oversight of data integrity OIG

2016bull We will review CMSs oversight of MA encounter data validation and assess

the extent to which CMSrsquos Integrated Data Repository contains timely valid and complete MA encounter data In 2012 CMS began collecting from MA organizations a more comprehensive set of encounter data reflecting the items and services provided to MA plan enrollees Prior CMS and OIG audits have indicated vulnerabilities in the accuracy of data reporting by MA organizations Realizing the potential benefits of the MA encounter data for payment and program integrity oversight is contingent upon the datarsquos completeness validity and timeliness (OEI 03-15-00060 expected issue date FY 2017)

73

Pepper Reports

bull httpswwwpepperresourcesorg

bull Program for Evaluating Payment Patterns Electronic Report ( PEPPER)

bull Annually on or about April 18 2016 will be released

bull Pepper Portal httpssecurefiletmforg

74

CGI Technologies and Solutions Inc httpracbcgicomContactInfoaspxst=1

bull Indiana bull Michiganbull Minnesotabull Illinoisbull Kentuckybull Ohiobull Wisconsin CGI Technologies and Solutions Incbull For general and administrative questions regarding client service outreach

quality assurance or project-specific issues contactbull 1877316RACB (7222)bull Email racbcgicom Tamara Tate Tamaratatecmshhsgovbull 4107861288

75

CGI Federal RAC

bull CGI Federal RAC Region Bbull Email racbcgicombull Phone 1-877-316-RACB (7222)bull Mailing Addressbull Send medical records as followsbull Medical records for Indiana Illinois Kentucky Michigan Ohio Wisconsin

Minnesota DME and Home Health CGI Federal Inc Attn RACB Imaging Dept 1001 Lakeside Ave Suite 800 Cleveland OH 44114

bull If submitting paper records please send medical records as follows For Therapy Reviews CGI Federal Inc Attn RACB Imaging 1001 Lakeside Avenue Suite 800 Cleveland OH 44114

76

How to survive RAC Audit

bull National health expenditures totaled $1679 Billion in 2003 bull National health expenditures were 153 of GROSS Domestic Product

(GDP) in 2003 bull Health care cost increasing at +9 per year bull Doomsday predictions of Medicare running out bull Congressional Action

77

RAC Audits

bull Medicare Modernization Act (MMA) of 2003Mandated a three year audit demonstration project 2005-2008

bull Appoint audit contractors to review Medicare billings for proper coding DRG assignment and medical necessity

bull Audits will apply to all health care providers (hospitals physicians homecare dme etc)

bull Audit contractors to be paid on a contingency basis a percentage of overpayments recovered

78

How Did we get here

bull Overpayments collected due to errors in Medically Unnecessary Services ndash 40

bull Incorrectly Coded ndash 35

bull Other ndash 17

bull NoInsufficient Documentation ndash 8

79

Where are we now

bull All RACrsquos completed required provider outreachAccess to Medicare billing data base given to all RAC RAC review methodology

bull Automated Review-Black amp White Issues (current) bull DRG Validation-complex review (current) bull Complex Review for coding errors (current) bull DME Medical Necessity Reviews ndashcomplex review (calendar year

2010) bull Medical Necessity Reviews-complex review (calendar year 2010)

80

RAC Reviews

bull Responsibilities of the Team Leader bull Must learn each insurance provider participating in a RAC or RAC type

program bull What are their operating rulesbull What is their appeal process Time limits

May be different process for each insurance provider bull Develop a response team

Identify who does what when why and alternate bull individual

Build and develop a manual process Review of computerized system

81

Priority Health SCIO Health Analytics

bull httpswwwsciohealthanalyticscomcore-capabilitiespayment-integrityfacility-auditsskilled-nursing-facility-audits

bull Claims for Medicare members treated at Skilled Nursing Facilities are reimbursed based on the patientsrsquo RUG (Resource Utilization Group) score which is determined using the Minimum Data Set (MDS) Using SCIOs robust analytics claims andor providers that merit review are selected for audit SCIOs auditors conduct a detailed review of the complete medical record and associated MDS to determine if the billed RUG score is valid In the event the review determines that an incorrect RUG score was billed SCIOreg provides the valid score reports the reason the change was necessary and calculates the resulting overpayment

82

+ Cheer

Onward and Upward she shall prevail We are here to care for the residents and provide a wonderful

service

13 83

84

References

bull Priority Healthbull Blue Crossbull Medicaidbull Medicare

85

  • Medicare Mange Care amp Medicaid Changes in the New World We Live In
  • Medicaid
  • NEW Medicaid Change MIlogin
  • Blueprint for Health Innovation MI
  • Provider Enrollment Electronic Signature Form Submission Process MSA 15-54
  • Provider Enrollment Electronic Signature Form Submission Process
  • Provider Enrollment Domain Administrator
  • Medicaid Coinsurance Medicare Advantage
  • Slide Number 9
  • Lawsuit DHS Changes on Caregivers
  • TPL Medicaid Change
  • CHAMPS Member Screen
  • LOC dropping off Not Due to MI Health
  • Issues
  • Secure Email Information
  • Medicaid amp Hospice
  • Medicaid
  • Medicaid Medicare Buy In
  • Manage Medicaid
  • Healthy Michigan Residents
  • Healthy Michigan Medicaid Days
  • McLaren Health Plan
  • Manage Medicaid Plans January 1
  • Slide Number 24
  • MI Health Link
  • MI Health Link 2565
  • What are the Names
  • MI Health Dual Eligible
  • MI Health LOC
  • LOC Medicaid
  • Medicaid Redetermination and MHL Enrollment
  • MI Health Link Portals
  • MI Health Authorizations
  • MI Health Issues
  • LOC 02 dropping MI Health Issues
  • PPA Offset
  • LOCD
  • MI Health Issues-New
  • ACO
  • Families Receiving Letters for ACO
  • ACO What is It
  • Payroll Based Journal
  • Slide Number 43
  • If you submit data manually should you also submit it through the XML
  • Staffing Submission Frequently Asked Questions
  • CMS defines
  • Slide Number 47
  • PBJ Medical Director Role
  • PBJ Medical Director Role
  • Dietician
  • Pharmacy Consultant
  • What are the names for the Medicare Number
  • QTSO
  • Medicare Update
  • CMS Final Rule On Returning Credits
  • Over Payment Rule
  • Questions to MAC
  • Questions to MAC
  • Final Rule on Returning Credits
  • Final Rule on Returning Credits
  • Final Rule on Returning Credits
  • Slide Number 62
  • Medicare Advantage Payors
  • Medicare Provider Enrollment Fee
  • Medicare MAC-Higlas
  • Two Midnight Rule
  • Two Midnight Rule
  • Two Midnight Rule
  • InPatient Vs Observation Conthellip
  • Two Midnight Rule
  • Health Data Insights amp Medicare Plus Blue
  • HDI Health Data amp Med Plus Blue
  • Health Data InSight
  • Pepper Reports
  • CGI Technologies and Solutions Inc httpracbcgicomContactInfoaspxst=1
  • CGI Federal RAC
  • How to survive RAC Audit
  • RAC Audits
  • How Did we get here
  • Where are we now
  • RAC Reviews
  • Priority Health SCIO Health Analytics
  • Cheer
  • References
Page 12: Medicare, Mange Care & Medicaid Changes in the New World we live in

CHAMPS Member Screen

bull Attention Providersbull Effective September 25 2015 a change was made to the CHAMPS

system This change modified the provider view for the Member Eligibility Inquiry screen If a member no longer has active Medicaid the hyperlink to view ldquoCommercialOtherrdquo Third Party Liability (TPL) information is disabled Because TPL does not always maintain TPLOther Insurance information for members that do not have active Medicaid coverage this information was disabled to prevent inaccurate information from being reported

12

LOC dropping off Not Due to MI Health

bull If after 30 days the county hasnrsquot processed the 2565 that you have send via the central scan (517-346-9888) AND other methods you choose to use you can email the 2565 to ArdeneMartin

bull At the following mailbox I ask that you put the beneficiaries name in the subject line

bull MSA2565michigangov

13

Issues

bull PPA going all over the place

bull LOC 02 dropping off not related to MI Health

bull LOCD tons of money written off

bull Must check CHAMPS member screen all the time and you must check pending

14

Secure Email Information

bull The State of Michigan asked me to remind you when you are communicating with them regarding residents to not send Resident names Birthdates or Social security numbers in those emails What you send is the Medicaid ID and they can look it up Or if it is a billing issue send them the TCN and the Medicaid ID We have been in the practice of emailing DHS Ardene Martin Integrated Health and Provider Support with all the resident name and such

15

Medicaid amp Hospicebull LOC 07 Manage Medicaid Hospice included so plan would pay

provider and not switch to a LOC 16

bull LOC 02 Medicaid (Regular Medicaid) Hospice not included so switch to 16 Hospice and Hospice pays provider

bull LOC 11 Healthy Michigan is included in plan so plan would pay provider and not switch to LOC 16

bull LOC 005 amp 015 MI Health is up in the air waiting for CMS Currently Hospice is now included

bull LOC 16 is Hospice when they switch from Regular Medicaid only and Hospice pays provider

16

Medicaidbull Going forward please make sure that your Champs ID amp NPI on your member screen matches your facility CHAMPS ID

amp NPI for each resident and matches for all new admissions or new approved Medicaid going forward

bull The edit will be turned on soon to stop the payment of these claims if the CHAMPS ID and NPI do not Match your facility on the Medicaid member screen

bull Make sure you are putting the information correct on the 2565 you send in to DHS

bull 1 I attached a 2565 When you fill this out for new people make sure in box 12 a you put your NPI and 12 b you put your CHAMPS ID This will help the DHS case workers assign the person to your facility

bull 2 I would check all your residents CHAMPS member screens and make sure the NPI and CHAMPS ID are your facilities If not you will have to work with the DHS worker to fix this The DHS worker is the only one that can fix this

bull 3 We are having some issues where the DHS case workers will not change this NPI and CHAMPS ID to your facilities You have to get them to change it or you just will not get paid

bull 4 We situations where the resident is in a facility in Kent County (as an example) but the family lives in Livingston County and completes the applications in Livingston County You will have to get the DHS worker in Livingston to fix it not the local DHS worker in Kent County where your facility is

17

Medicaid Medicare Buy Inbull Based on the information from the Office of Personnel Management Federal

Employeersquos employed as of January 1 1983 are eligible for Medicare Part A(see page 5 of attached document) This was also confirmed with our Social Security liaison If the beneficiary did not retire before 1983 he can enroll in Medicare Part B and pay the premium and then he can enroll in Medicare Part A and pay that premium as well or may qualify for Medicare Buy in of Part A

bull If a beneficiary has an SSA document stating they are not eligible for Medicare as they do not have enough work credits the beneficiarybeneficiary representative needs to go to SSA and let them know that while they know they are not eligible for Medicare Part A free or reduced however they are eligible for Medicare Part B and would like to enroll Once the beneficiary enrolls in Medicare Part B (enrollment period January 1st ndash March 31 each year) and pays the premium then the beneficiary is eligible to either pay for Medicare Part A or that beneficiary may qualify for Medicare Part A buy in through Medicaid Once the beneficiary is enrolled in Medicare Part A and Medicare Part B Medicaid will begin to make payments on claims

18

Manage Medicaid Where are we

19

Healthy Michigan Residents

20

Healthy Michigan Medicaid Days

21

McLaren Health Plan

22

Manage Medicaid Plans January 1bull Region 1 ndash Upper Peninsula Health Planbull Region 2 ndash McLaren Health Plan Meridian Health Plan of Michigan Molina Healthcare of Michigan

UnitedHealthcare Community Planbull Region 3 ndash McLaren Health Plan Meridian Health Plan of Michigan Molina Healthcare of Michigan

UnitedHealthcare Community Planbull Region 4 ndash Blue Cross Complete of Michigan McLaren Health Plan Meridian Health Plan of Michigan Molina

Healthcare of Michigan Priority Health Choice UnitedHealthcare Community Planbull Region 5 ndash McLaren Health Plan Meridian Health Plan of Michigan Molina Healthcare of Michigan

UnitedHealthcare Community Planbull Region 6 ndash Blue Cross Complete of Michigan HAP Midwest Health Plan McLaren Health Plan Meridian Health

Plan of Michigan Molina Healthcare of Michigan UnitedHealthcare Community Planbull Region 7 ndash Blue Cross Complete of Michigan McLaren Health Plan Meridian Health Plan UnitedHealthcare

Community Planbull Region 8 ndash Aetna Better Health of Michigan McLaren Health Plan Meridian Health Plan of Michigan Molina

Healthcare of Michigan Priority Health Choice UnitedHealthcare Community Planbull Region 9 ndash Aetna Better Health of Michigan Blue Cross Complete of Michigan McLaren Health Plan Meridian

Health Plan of Michigan Molina Healthcare of Michigan UnitedHealthcare Community Planbull Region 10 ndash Aetna Better Health of Michigan Blue Cross Complete of Michigan Harbor Health Plan McLaren

Health Plan Meridian Health Plan of Michigan Molina Healthcare of Michigan Total Health Care UnitedHealthcare Community Plan 23

24

MI Health LinkWhere are we

25

MI Health Link 2565

bull This notification is being sent to providers of long term care services including nursing facilities county medical care facilities and hospital long term care units to provide clarification on the process involved with the submission of the Facility Admission Form (MSA-2565-C) for an individual enrolled in the MI Health Link program

bull The MI Health Link program covers the custodiallong term nursing facility service benefit When an individual who is enrolled in the MI Health Link program is admitted to a nursing facility for custodiallong term nursing services a disenrollment from the Integrated Care Organization (MI Health Link health plan) is NOT REQUIRED The Facility Admission Form (MSA-2565-C) should NOT be sent to the Michigan Department of Health and Human Services (MDHHS) Enrollment Services Section for a disenrollment to be processed

26

What are the Names

bull Started as Integrated Health

bull Then called MMP (Medicare Medicaid Program)

bull Duals (Also Known as Duals as in Dual Eligible)

bull Now called MI Health Link

bull Total confusion

27

MI Health Dual Eligible28

MI Health LOC

29

LOC Medicaidbull We have the new pilot program which started on March

1 2015 in Southwest Michigan Region 4 Counties Macomb Wayne and the UP You could see these patients they are dual eligible in the Pilot program in counties surrounding the pilot

bull MHL-LOC 005 (All other Facilities) or LOC 015 (County Care) These residents have to call Michigan Enrolls to dis-enroll toll-free at 1-800-975-7630 (TTY 1-888-263-5897) Monday-Friday from 8 AM to 7 PM Once they dis-enroll they will go to a LOC 02 you have to do a new LOCD

30

Medicaid Redetermination and MHL Enrollmentbull At the time of re-determination for Medicaid financial eligibility the MI

Health Link (MHL) program will not be sending beneficiaries information about this program Beneficiaries who previously opted out will not be passively enrolled according to an email from the MHL staff The MHL staff wrote

bull ldquoThere is currently no MI Health Link enrollment letter sent to beneficiaries when eligibility is re-determined A person who becomes eligible for MI Health Link enrollment may opt-in at any time

bull When Medicaid re-determination takes place the beneficiary remains in the same ICO unless that beneficiary lost Medicaid coverage If the enrollee loses Medicaid coverage and later regains it they are not passively enrolled into MI Health Link The beneficiary may choose to opt back in to the program at that time if desiredrdquo

bull MHL staff did state that about 1500 beneficiaries will be passively enrolled effective January 1 2016 These specific individuals were given normal notice of 60 and 30 days in which to opt-in or opt-out if they so chose No other large scale passive enrollment is scheduled according to the MHL staff 31

MI Health Link Portals

bull Meridian Health Planbull httpwwwmhplancommibull Amerihealthbull httpwwwamerihealthcaritasvipcarepluscomproviderself-service-

toolsindexaspxbull AetnaCoventrybull httpwwwaetnabetterhealthcomMichiganprovidersportalbull Molinabull httpwwwmolinahealthcarecommembersmien-usmemPageshomeaspxbull HAPMidwestbull httpswwwmidwesthealthplancomLoginaspxbull FidelisCentenebull wwwfidelissccommmp 32

MI Health Authorizationsbull We need to watch these authorization that the plans are giving us for the MI

Health program Some plans are assigning a diagnosis for residents in their prior authorizations They are assigning diagnosis that the residents do not even have You need to make sure these are correct diagnosis and if not you need to work with the case managers of the plans to fix the issue The authorization numbers do change

bull Make sure that any resident that is in a MI Health plan that you have a prior authorization All plans are giving different periods authorizing the residents stay in the facility You need to set up a system to make sure you always have a authorization for the period of time you are rendering the service Here is an example of time frame of authorizations

bull Meridian is authorizing 12 monthsbull Aetna is authorizing 3 monthsbull Molina is authorizing 6 monthsbull The authorization numbers need to go on your claims to the payer You need to

put the authorizations in your software and track the dates

33

MI Health Issuesbull We are seeing some issues with MI Health where the resident does not have the correct LOC or it shows

up correct on CHAMPS but ancillary providers such as Dentist and such cannot see it I think we still have some issues with the information crossing between Bridges DHS system CMS and CHAMPS It in return is creating some access of care issues If it is a true LOC issues Facilities with LOC issues need to submit the Medicaid ID numbers to the MSA-MHL-EnrollmentMichigangov box with the subject line Nursing home LOC Issue so they may work to resolve the issues

bull If it becomes an access to care issue email the information to INTEGRATEDCAREmichigangov Remember in these emails only send the Medicaid ID and explain the situation The State will work with the plans to try to fix the process or improve the process

bull We are also seeing with new admission with LOC 015 or 005 that the plans are stating they have 14 days to authorize admission These are resident in the emergency room and possibly be admitted to you for Rehab The hospital will not keep the resident in ER for 14 days and you cannot admit the resident until you have a prior authorization I would recommend when you are told this by the plan that you need to ask to speak to a manager We will have to work through this

bull Ancillary Provider You need to work with your ancillary providers such as Lab Pharmacy X-Ray Physician and such to get the to be credentialed with the plans We are hearing that some of the pharmacies are not participating with the plans this will create issues for you so I would continue to ask these groups to participate

34

LOC 02 dropping MI Health Issuesbull The passive enrollments have occurred in Macomb amp Wayne for

Medicaid dual eligible We are having the same issue we did as in the Southwest MI amp UP with the passive enrollments I am starting to hear from facilities who are checking there CHAMPS member screens that those residents that have opted out (some residents not all) have lost there 02 Make sure you are checking your CHAMPS member screen both for those that were passively enrolled and those that might have lost there 02 Medicaid that opted out

bull Facilities with LOC issues need to submit the Medicaid ID numbers to the (Only MI Health)MSA-MHL-Enrollmentmichigangov box with the subject line Nursing home LOC Issue so they may work to resolve the issues

35

PPA Offset

bull There are no co-pays deductibles or premiums in MI Health Link so there should be no need to offset the PPA with code 25 MI Health Link enrollees can continue to offset their PPA for non-program covered medical expenses (like Vision-Code 27 Dental-Code 28 and Hearing-Code 26) and use the appropriate codes to offset the PPA when billing the health plan for nursing facility services

bull Resident pay PPA when MedicareMedicaid coinsurance

36

LOCDbull Nursing Facility Level of Care Determination (NFLOCD)

bull The MI Health Link health plan will be responsible for conducting the Michigan Medicaid NFLOCD tool for enrollees seeking admission to a nursing facility For existing residents at the time of enrollment the existing NFLOCD will be adopted for capitation payment purposes The health plan will complete a new NFLCOD tool within the first 90 days of enrollment If a nursing facility resident is disenrolled from MI Health Link the nursing facility will be responsible for conducting a new NFLOCD tool in accordance with published Medicaid policy

37

MI Health Issues-New

bull INTEGRATEDCAREmichigangov

bull Email with Insurance Plan issues Case Manager Issues

38

ACOWhat are they

39

Families Receiving Letters for ACO

40

ACO What is It

bull Whats an ACObull Accountable Care Organizations (ACOs) are groups of doctors hospitals

and other health care providers who come together voluntarily to give coordinated high quality care to their Medicare patients

bull The goal of coordinated care is to ensure that patients especially the chronically ill get the right care at the right time while avoiding

unnecessary duplication of services and preventing medical errorsbull When an ACO succeeds both in delivering high-quality care and

spending health care dollars more wisely it will share in the savings it achieves for the Medicare program

41

Payroll Based JournalMandatory on July 1 2016Internet Explorer Version

Internet Explorer v 10 and v 11 will need to operate in compatibility mode

42

43

If you submit data manually should you also submit it through the XML

bull Now you have three options

bull Submit Manually only

bull Submit through the XML only

bull You are able to submit manually and using the XML

44

45

Staffing Submission Frequently Asked Questions

bull ldquoWho are direct care staffrdquo (Who do we submit data for)bull Submission of data for contract staffbull Medical directors and consultantsbull Staff switching roles or tasks throughout the daybull Hours paid vs hours worked ndash Must be verifiablebull Public postingQuality MeasuresFive Starbull Enforcementbull Voluntary submission risks (noneSo register now)

CMS defines

bull 37 job title codes that are required to match employees to the number of hours each direct care function was performed It is important to work with your teams to define the workers that contribute to each job type and how those daily worked hours are recorded and converted to a PBJ submission

bull The PBJ does include some more specific job descriptions than the 671 For example the PBJ system includes job descriptions for RNs with administrative duties and LPNs with administrative duties versus the 671rsquos more general ldquoNurses with Administrative Duties

Page 46

47

PBJ Medical Director Rolebull Physician Leadership

bull Help the facility ensure that patients have appropriate physician coverage and ensure the provision of physician and health care practitioner services and

bull Help the facility develop a process for reviewing physician and health care practitioner credentials

bull Provide specific guidance for physician performance expectations

bull Help the facility ensure that a system is in place for monitoring the performance of health care practitioners and

bull Facilitate feedback to physicians and other health care practitioners on performance and practices

bull Patient Care - Clinical Leadership

bull Participate in administrative decision-making and the development of policies and procedures related to patient care

bull Help develop approve and implement specific clinical practices for the facility to incorporate into its care-related policies and procedures including areas required by laws and regulations

bull Develop procedures and guidance for facility staff regarding contacting practitioners including information gathering and presentation change in condition assessment and when to contact the medical director

bull Review consider andor act upon consultant recommendations as appropriate that affect the facilitys resident care policies and procedures or the care of an individual resident

bull Review respond to and participate in federal state local and other external surveys and inspections and

bull Help review policies and procedures regarding the adequate protection of patients rights advance care planning and other ethical issues48

PBJ Medical Director Rolebull Quality of Care

bull Help the facility establish systems and methods for reviewing the quality and appropriateness of clinical care and other health-related services and provide appropriate feedback and

bull Participate in the facilitys quality improvement process

bull Advise on infection control issues and approve specific infection control policies to be incorporated into facility policies and procedures

bull Help the facility provide a safe and caring environment

bull Help promote employee health and safety and

bull Assist in the development and implementation of employee health policies and programs

bull Education Information and Communication

bull Promote a learning culture within the facility by educating informing and communicating

bull Provide information to help the facility provide care consistent with current standards of practice (defined as approaches to care procedures techniques and treatments that are based on research and or expert consensus and that are contained in current manuals textbooks and or publications or that are accepted adopted or promulgated by recognized organizations or national bodies)

bull Help the facility develop medical information and communication systems with staff patients and families and others

bull Represent the facility to the professional and lay community on medical and patient care issues

bull Maintain knowledge of the changing social regulatory political and economic factors that affect medical and health services of long term care patients and

bull Help establish appropriate relationships with other health care organizations

49

Dietician

bull When the dietary or food services supervisor is other than a registered dietitian the supervisor shall receive routine consultation and technical assistance from a registered dietitian (RD) Consultation time shall not be less than 4 hours every 60 days Additional consultation time may be needed based on the total number of patients incidence of nutrition-related health problems and food service management needs of the facility

50

Pharmacy Consultant

bull At least once per month a licensed pharmacist must perform a drug regimen review (DRR) for each resident The pharmacist must report any irregularities to the attending physician or director of nursing Furthermore these reports must be acted upon

51

What are the names for the Medicare Numberbull OSCAR -Online Survey Certification and Reporting

bull PTAN-PTAN number is assigned by Medicare to authenticate the provider when using the local Medicare Administrative Contractorrsquos (MAC) self-help tools like the IVR internet portal on-line application status etc Provider Transactions Access Number

bull CCN- CMS Certification Number

bull Medicare Number- example 23-

bull All of the above mean the same thing

52

QTSO

bull Once you are logged in the QTSO site bull You will have a state login to the site to access the various site specific

to your facilitybull Installing you will need administrator rights to your network

53

Medicare UpdateWhat are we seeing

54

CMS Final Rule On Returning Credits

httpswwwfederalregistergovarticles201602122016-02789medicare-program-reporting-and-returning-of-overpayments

55

Over Payment Rule

bull Medicare payments for non covered services

bull Medicare payments in excess of the allowable amount for an identified covered service

bull Errors and non reimbursable expenditures in cost reportsbull Duplicate payment

bull Receipt of Medicare payments when another payor had the primary responsibility for payment

56

Questions to MAC

bull Does the Medicare credit balance report change with this overpayment rule

bull No Medicare Credit Balances are still required at the end of each quarter

bull Will that still be the communication to let CMS or the MAC know that we have received an overpayment

bull Submission of Medicare Credit Balance is one form of communicating overpayments to CMS Other methods include submitting a voluntary refund with required claim information or the submission of a standard overpayment form

57

Questions to MAC

bull Will the MAC still deduct from a future RAbull If the recovery of the overpayment includes adjusting a claim then

the overpayment would be netted against future claims payments and reflected on the RA

bull Or will that process change with this new rulebull Process will remain the samebull Will NGS send communication out on thisbull Yes NGS will communicate this once the final rule is communicated

to the MACs by CMS However this could change depending on final CMS instructions

58

Final Rule on Returning Credits

bull Providers will want to immediately update their current policies governing overpayments in order to comply with this new rule which will take effect on March 14 2016

bull Providers and suppliers are required to use reasonable diligence to investigate credible information regarding overpayments through both proactive compliance efforts and reactive investigations

bull If an overpayment is identified then it must be repaid within 60 days An overpayment is identified when a person has or should have through the exercise of reasonable diligence determined that the person received an overpayment and quantified the amount

bull Providers and suppliers have a maximum of 8 months to report and return overpayments ndash up to 6 months to investigate and quantify the overpayment (ie to identify it) and up to 60 days to report and return the overpayment

59

Final Rule on Returning Credits

bull Providers and suppliers are required to report and return all overpayments within a 6-year lookback period

bull The cause and amount of the overpayment is irrelevant for the determination eg it was due to a mistake it was someone elsersquos fault it is a minor amount An overpayment is an overpayment and must be returned

bull Providers and suppliers must make their own determination to which entity to report and return the overpayment ie to the Medicare contractor or using the OIG Self Disclosure Protocol or the CMS Self Referral Disclosure Protocol

60

Final Rule on Returning Credits

bull Providers and suppliers may use the claims adjustment credit balance self-reported refund process or another appropriate process to report and return overpayments At this time there is no standard refund form to use

bull Failure to report and return an overpayment could subject the provider or supplier to False Claims Act liability Civil Monetary Penalties Law liability and exclusion from federal health care programs

61

P S amp R-Accountants will be asking for this information

The location you login into has changed it is now on EIDM EIDM is the acronym for CMS Enterprise Identity Management system which includes Identity Verification Access Management Authorization Assistance Workflow Tools and Identity Lifecycle Management functions

httpswwwcmsgovResearch-Statistics-Data-and-SystemsCMS-Information-TechnologyIACSCMS-Applications-Loginhtml

Go down the page and click on the PSampRSTARThis will take you to the login pagewill look the same as the old P S amp R didChanges Affecting PSampR System Access (Please Read) (posted 01292015)(Updated 5262015)is changingThe system which controls your PSampR user ID (currently IACS)The new system is referred to as EIDMThis will result in a different way to create new accounts or change passwords to existing accountsIf you already have an account in EIDM you may have to use that account for accessing PSampR after the transitionWhen is the change effectiveJune 13 2015What is staying the sameThe internet address for accessing PSampR remains the sameThe PSampR systemfunctionality is NOT changing 62

Medicare Advantage Payorsbull Medicare Advantage payors are pullingdenying payments on admissions if the patient was readmitted within 30 days after discharge The

client believes that the payors systematically denying payments for all readmissions within 30 days They believe this practice denies them due process to address whether the readmissions were justified and not due to a premature discharge of patient The payors seem to want to act like a QIO without having the same accountabilities of the QIO related to determinations of non-payment

bull Heres the QIO process under section 4240 of the QIO Manualbull 4240 - Readmission Review - (Rev 2 07-11-03)bull Readmission review involves admissions to an acute general short-term hospital occurring less than 31 calendar days from the date of

discharge from the same or another acute general short-term hospital (see sect1154(a)(13) and 42 CFR 47671(a)(8)(ii)) Neither the day of discharge nor the day of admission is counted when determining whether a readmission has occurred

bull A Medical Review Proceduresbull Obtain the appropriate medical records for the initial admission and readmission Perform case review on both stays Analyze the cases

specifically to determine whether the patient was prematurely discharged from the first confinement thus causing readmission Perform an analysis of the stay at the first hospital to determine the cause(s) and extent of any problem(s) (eg incomplete or substandard treatment) Consider the information available to the attending physician who discharged the patient from the first confinement Do not base a determination of a premature discharge on information that the physician or provider could not have known or events that could not have been anticipated at the time of discharge

bull Review both the initial admission and the readmission at the same time unless one of them has previously been reviewed In these cases use at a minimum the PRAF case summary of the other admission in addition to the medical record of the case under review

bull C Denialsbull Deny readmissions under the following circumstancesbull If the readmission was medically unnecessarybull If the readmission resulted from a premature discharge from the same hospital orbull If the readmission was a result of circumvention of PPS by the same hospital (see sect4255)bull With the QIO process there is an appeal within the QIO here the hospital is getting no opportunity to challenge the denials

63

Medicare Provider Enrollment Feebull Provider Enrollment Application Fee Amount for CY 2016bull On December 3 CMS issued a notice Provider Enrollment Application

Fee Amount for CY 2016 [CMSndash6066ndashN] Effective January 1 2016 the CY 2016 application fee is $554 for institutional providers that are

bull Initially enrolling in the Medicare or Medicaid program or the Childrens Health Insurance Program (CHIP)

bull Revalidating their Medicare Medicaid or CHIP enrollmentbull Adding a new Medicare practice locationbull This fee is required with any enrollment application submitted from

January 1 through December 31 2016

64

Medicare MAC-Higlas

bull Effective 142016 CMS has implemented a change to begin netting (offsetting) provider money across workloads within a single organization What this means is that any related providers conducting business in two different workloads (example New York and Maine) will have their money applied to any account receivables (AR) with a remaining balance owed to Medicare within both workloads For example Provider ABC is located in New York and is scheduled to receive a payment of $1000 on todays remittance advice Provider XYZ is related to provider ABC but is located in Maine and has ARs with a balance owed of $200 Provider ABCs $1000 payment will have the $200 applied against provider XYZs ARs resulting in a net payment of $800 This will be reflected on the remittance advice by the same PLB code as seen today for offsets for the $200

65

Two Midnight RuleChange January 1 2016 httpswwwcmsgovMedicareMedicare-Fee-for-Service-PaymentHospitalOutpatientPPSHospital-Outpatient-Regulations-and-Notices-ItemsCMS-1633-FChtml

66

Two Midnight Rulebull However effective January 1 2016 CMS will allow exceptions to the

Two-Midnight Benchmark to be determined on a case-by-case basis by the physician responsible for the care of the beneficiary subject to medical review Said differently Part A payment may be appropriate in some circumstances even though there is no expectation by the physician (or qualified ordering practitioner) of a two-midnight stay and one of the two pre-existing categorical exceptions (CMS ldquoinpatient onlyrdquo list and newly initiated mechanical ventilation) does not apply CMS has indicated that this change to the Two Midnight Rule is in response to stakeholder concern and CMSrsquos continued efforts to develop the most appropriate standard for determining Medicare Part A payment

67

Two Midnight Rulebull A new 42 CFR sect4123(a) provides that a patient is considered an

inpatient of a hospitalhellipif formally admitted as an inpatient pursuant to an order for inpatient admission by a physician or other qualified practitionerhellip The physician orders inpatient status when he or she expects the patient to require a stay that crosses at least 2 midnights[10] Stays expected to be shorter than at least two midnights are generally inappropriate for inpatient admission and inpatient payment under Medicare Part A unless the surgical procedure is specified by Medicare as inpatient only under sect41922(n)[11] The physicians expectationhellipshould be based on such complex medical factors as patient history and comorbidities the severity of signs and symptoms current medical needs and the risk of an adverse event[12] The physician order is part of physician certification of the medical necessity of hospital inpatient serviceshellip[13]

68

InPatient Vs Observation Conthellip

bull Physician certification which begins with an order for inpatient admission requires the physician to certify the reasons for the hospitalization the estimated time the patient will remain in the hospital and plans for post-hospital care if appropriate[14] The certification must be completed signed and documented in the medical record prior to discharge[15]

bull A physicians admission order has no presumptive weight and both the admission order and the physician certification will be evaluated in the context of the evidence in the medical record[16] CMS intends to provide additional information about what evidence in the medical record means in future instructions and manual revisions[17]

69

Two Midnight Rulebull Although the new case-by-case exception appears to be inherently

subjective to a certain extent CMS states that the following factors (among others) would be relevant to determining whether a patient requires inpatient admission under the expanded policy

bull The severity of the signs and symptoms exhibited by the patient bull The medical predictability of something adverse happening to the patient

and bull The need for diagnostic studies that appropriately are outpatient services

(that is their performance does not ordinarily require the patient to remain at the hospital for 24 hours or more)

bull CMS also notes that an inpatient admission (and Part A payment) should be ldquorare and unusualrdquo for minor surgical procedures or other treatment that is expected to keep the patient in the hospital ldquofor only a few hoursrdquo or for a period of time that ldquodoes not span at least overnightrdquo (thus a subset of stays not meeting the Two Midnight Benchmark) CMS indicates that such cases will be prioritized for medical review

70

Health Data Insights amp Medicare Plus Blue

RAC (Retrospective Audits)

71

HDI Health Data amp Med Plus Blue

bull httpwwwhealthdatainsightscombull Blue Cross Medicare Advantage Auditsbull Facilities seeing 10 to 15 requests for Medical Recordsbull In January amp Feburarybull Selected Health Data Insights because they were a premier Audit

Vendor for CMS Recovery Audit Contractor (RAC) demonstration Project They are a audit vendor for Humana

bull Providers not sending Medical Record will get technical denial and lose payments

72

Health Data InSight

bull In 2010 they began the Hospital Reviewbull Medicare Advantage encounter datandashCMS oversight of data integrity OIG

2016bull We will review CMSs oversight of MA encounter data validation and assess

the extent to which CMSrsquos Integrated Data Repository contains timely valid and complete MA encounter data In 2012 CMS began collecting from MA organizations a more comprehensive set of encounter data reflecting the items and services provided to MA plan enrollees Prior CMS and OIG audits have indicated vulnerabilities in the accuracy of data reporting by MA organizations Realizing the potential benefits of the MA encounter data for payment and program integrity oversight is contingent upon the datarsquos completeness validity and timeliness (OEI 03-15-00060 expected issue date FY 2017)

73

Pepper Reports

bull httpswwwpepperresourcesorg

bull Program for Evaluating Payment Patterns Electronic Report ( PEPPER)

bull Annually on or about April 18 2016 will be released

bull Pepper Portal httpssecurefiletmforg

74

CGI Technologies and Solutions Inc httpracbcgicomContactInfoaspxst=1

bull Indiana bull Michiganbull Minnesotabull Illinoisbull Kentuckybull Ohiobull Wisconsin CGI Technologies and Solutions Incbull For general and administrative questions regarding client service outreach

quality assurance or project-specific issues contactbull 1877316RACB (7222)bull Email racbcgicom Tamara Tate Tamaratatecmshhsgovbull 4107861288

75

CGI Federal RAC

bull CGI Federal RAC Region Bbull Email racbcgicombull Phone 1-877-316-RACB (7222)bull Mailing Addressbull Send medical records as followsbull Medical records for Indiana Illinois Kentucky Michigan Ohio Wisconsin

Minnesota DME and Home Health CGI Federal Inc Attn RACB Imaging Dept 1001 Lakeside Ave Suite 800 Cleveland OH 44114

bull If submitting paper records please send medical records as follows For Therapy Reviews CGI Federal Inc Attn RACB Imaging 1001 Lakeside Avenue Suite 800 Cleveland OH 44114

76

How to survive RAC Audit

bull National health expenditures totaled $1679 Billion in 2003 bull National health expenditures were 153 of GROSS Domestic Product

(GDP) in 2003 bull Health care cost increasing at +9 per year bull Doomsday predictions of Medicare running out bull Congressional Action

77

RAC Audits

bull Medicare Modernization Act (MMA) of 2003Mandated a three year audit demonstration project 2005-2008

bull Appoint audit contractors to review Medicare billings for proper coding DRG assignment and medical necessity

bull Audits will apply to all health care providers (hospitals physicians homecare dme etc)

bull Audit contractors to be paid on a contingency basis a percentage of overpayments recovered

78

How Did we get here

bull Overpayments collected due to errors in Medically Unnecessary Services ndash 40

bull Incorrectly Coded ndash 35

bull Other ndash 17

bull NoInsufficient Documentation ndash 8

79

Where are we now

bull All RACrsquos completed required provider outreachAccess to Medicare billing data base given to all RAC RAC review methodology

bull Automated Review-Black amp White Issues (current) bull DRG Validation-complex review (current) bull Complex Review for coding errors (current) bull DME Medical Necessity Reviews ndashcomplex review (calendar year

2010) bull Medical Necessity Reviews-complex review (calendar year 2010)

80

RAC Reviews

bull Responsibilities of the Team Leader bull Must learn each insurance provider participating in a RAC or RAC type

program bull What are their operating rulesbull What is their appeal process Time limits

May be different process for each insurance provider bull Develop a response team

Identify who does what when why and alternate bull individual

Build and develop a manual process Review of computerized system

81

Priority Health SCIO Health Analytics

bull httpswwwsciohealthanalyticscomcore-capabilitiespayment-integrityfacility-auditsskilled-nursing-facility-audits

bull Claims for Medicare members treated at Skilled Nursing Facilities are reimbursed based on the patientsrsquo RUG (Resource Utilization Group) score which is determined using the Minimum Data Set (MDS) Using SCIOs robust analytics claims andor providers that merit review are selected for audit SCIOs auditors conduct a detailed review of the complete medical record and associated MDS to determine if the billed RUG score is valid In the event the review determines that an incorrect RUG score was billed SCIOreg provides the valid score reports the reason the change was necessary and calculates the resulting overpayment

82

+ Cheer

Onward and Upward she shall prevail We are here to care for the residents and provide a wonderful

service

13 83

84

References

bull Priority Healthbull Blue Crossbull Medicaidbull Medicare

85

  • Medicare Mange Care amp Medicaid Changes in the New World We Live In
  • Medicaid
  • NEW Medicaid Change MIlogin
  • Blueprint for Health Innovation MI
  • Provider Enrollment Electronic Signature Form Submission Process MSA 15-54
  • Provider Enrollment Electronic Signature Form Submission Process
  • Provider Enrollment Domain Administrator
  • Medicaid Coinsurance Medicare Advantage
  • Slide Number 9
  • Lawsuit DHS Changes on Caregivers
  • TPL Medicaid Change
  • CHAMPS Member Screen
  • LOC dropping off Not Due to MI Health
  • Issues
  • Secure Email Information
  • Medicaid amp Hospice
  • Medicaid
  • Medicaid Medicare Buy In
  • Manage Medicaid
  • Healthy Michigan Residents
  • Healthy Michigan Medicaid Days
  • McLaren Health Plan
  • Manage Medicaid Plans January 1
  • Slide Number 24
  • MI Health Link
  • MI Health Link 2565
  • What are the Names
  • MI Health Dual Eligible
  • MI Health LOC
  • LOC Medicaid
  • Medicaid Redetermination and MHL Enrollment
  • MI Health Link Portals
  • MI Health Authorizations
  • MI Health Issues
  • LOC 02 dropping MI Health Issues
  • PPA Offset
  • LOCD
  • MI Health Issues-New
  • ACO
  • Families Receiving Letters for ACO
  • ACO What is It
  • Payroll Based Journal
  • Slide Number 43
  • If you submit data manually should you also submit it through the XML
  • Staffing Submission Frequently Asked Questions
  • CMS defines
  • Slide Number 47
  • PBJ Medical Director Role
  • PBJ Medical Director Role
  • Dietician
  • Pharmacy Consultant
  • What are the names for the Medicare Number
  • QTSO
  • Medicare Update
  • CMS Final Rule On Returning Credits
  • Over Payment Rule
  • Questions to MAC
  • Questions to MAC
  • Final Rule on Returning Credits
  • Final Rule on Returning Credits
  • Final Rule on Returning Credits
  • Slide Number 62
  • Medicare Advantage Payors
  • Medicare Provider Enrollment Fee
  • Medicare MAC-Higlas
  • Two Midnight Rule
  • Two Midnight Rule
  • Two Midnight Rule
  • InPatient Vs Observation Conthellip
  • Two Midnight Rule
  • Health Data Insights amp Medicare Plus Blue
  • HDI Health Data amp Med Plus Blue
  • Health Data InSight
  • Pepper Reports
  • CGI Technologies and Solutions Inc httpracbcgicomContactInfoaspxst=1
  • CGI Federal RAC
  • How to survive RAC Audit
  • RAC Audits
  • How Did we get here
  • Where are we now
  • RAC Reviews
  • Priority Health SCIO Health Analytics
  • Cheer
  • References
Page 13: Medicare, Mange Care & Medicaid Changes in the New World we live in

LOC dropping off Not Due to MI Health

bull If after 30 days the county hasnrsquot processed the 2565 that you have send via the central scan (517-346-9888) AND other methods you choose to use you can email the 2565 to ArdeneMartin

bull At the following mailbox I ask that you put the beneficiaries name in the subject line

bull MSA2565michigangov

13

Issues

bull PPA going all over the place

bull LOC 02 dropping off not related to MI Health

bull LOCD tons of money written off

bull Must check CHAMPS member screen all the time and you must check pending

14

Secure Email Information

bull The State of Michigan asked me to remind you when you are communicating with them regarding residents to not send Resident names Birthdates or Social security numbers in those emails What you send is the Medicaid ID and they can look it up Or if it is a billing issue send them the TCN and the Medicaid ID We have been in the practice of emailing DHS Ardene Martin Integrated Health and Provider Support with all the resident name and such

15

Medicaid amp Hospicebull LOC 07 Manage Medicaid Hospice included so plan would pay

provider and not switch to a LOC 16

bull LOC 02 Medicaid (Regular Medicaid) Hospice not included so switch to 16 Hospice and Hospice pays provider

bull LOC 11 Healthy Michigan is included in plan so plan would pay provider and not switch to LOC 16

bull LOC 005 amp 015 MI Health is up in the air waiting for CMS Currently Hospice is now included

bull LOC 16 is Hospice when they switch from Regular Medicaid only and Hospice pays provider

16

Medicaidbull Going forward please make sure that your Champs ID amp NPI on your member screen matches your facility CHAMPS ID

amp NPI for each resident and matches for all new admissions or new approved Medicaid going forward

bull The edit will be turned on soon to stop the payment of these claims if the CHAMPS ID and NPI do not Match your facility on the Medicaid member screen

bull Make sure you are putting the information correct on the 2565 you send in to DHS

bull 1 I attached a 2565 When you fill this out for new people make sure in box 12 a you put your NPI and 12 b you put your CHAMPS ID This will help the DHS case workers assign the person to your facility

bull 2 I would check all your residents CHAMPS member screens and make sure the NPI and CHAMPS ID are your facilities If not you will have to work with the DHS worker to fix this The DHS worker is the only one that can fix this

bull 3 We are having some issues where the DHS case workers will not change this NPI and CHAMPS ID to your facilities You have to get them to change it or you just will not get paid

bull 4 We situations where the resident is in a facility in Kent County (as an example) but the family lives in Livingston County and completes the applications in Livingston County You will have to get the DHS worker in Livingston to fix it not the local DHS worker in Kent County where your facility is

17

Medicaid Medicare Buy Inbull Based on the information from the Office of Personnel Management Federal

Employeersquos employed as of January 1 1983 are eligible for Medicare Part A(see page 5 of attached document) This was also confirmed with our Social Security liaison If the beneficiary did not retire before 1983 he can enroll in Medicare Part B and pay the premium and then he can enroll in Medicare Part A and pay that premium as well or may qualify for Medicare Buy in of Part A

bull If a beneficiary has an SSA document stating they are not eligible for Medicare as they do not have enough work credits the beneficiarybeneficiary representative needs to go to SSA and let them know that while they know they are not eligible for Medicare Part A free or reduced however they are eligible for Medicare Part B and would like to enroll Once the beneficiary enrolls in Medicare Part B (enrollment period January 1st ndash March 31 each year) and pays the premium then the beneficiary is eligible to either pay for Medicare Part A or that beneficiary may qualify for Medicare Part A buy in through Medicaid Once the beneficiary is enrolled in Medicare Part A and Medicare Part B Medicaid will begin to make payments on claims

18

Manage Medicaid Where are we

19

Healthy Michigan Residents

20

Healthy Michigan Medicaid Days

21

McLaren Health Plan

22

Manage Medicaid Plans January 1bull Region 1 ndash Upper Peninsula Health Planbull Region 2 ndash McLaren Health Plan Meridian Health Plan of Michigan Molina Healthcare of Michigan

UnitedHealthcare Community Planbull Region 3 ndash McLaren Health Plan Meridian Health Plan of Michigan Molina Healthcare of Michigan

UnitedHealthcare Community Planbull Region 4 ndash Blue Cross Complete of Michigan McLaren Health Plan Meridian Health Plan of Michigan Molina

Healthcare of Michigan Priority Health Choice UnitedHealthcare Community Planbull Region 5 ndash McLaren Health Plan Meridian Health Plan of Michigan Molina Healthcare of Michigan

UnitedHealthcare Community Planbull Region 6 ndash Blue Cross Complete of Michigan HAP Midwest Health Plan McLaren Health Plan Meridian Health

Plan of Michigan Molina Healthcare of Michigan UnitedHealthcare Community Planbull Region 7 ndash Blue Cross Complete of Michigan McLaren Health Plan Meridian Health Plan UnitedHealthcare

Community Planbull Region 8 ndash Aetna Better Health of Michigan McLaren Health Plan Meridian Health Plan of Michigan Molina

Healthcare of Michigan Priority Health Choice UnitedHealthcare Community Planbull Region 9 ndash Aetna Better Health of Michigan Blue Cross Complete of Michigan McLaren Health Plan Meridian

Health Plan of Michigan Molina Healthcare of Michigan UnitedHealthcare Community Planbull Region 10 ndash Aetna Better Health of Michigan Blue Cross Complete of Michigan Harbor Health Plan McLaren

Health Plan Meridian Health Plan of Michigan Molina Healthcare of Michigan Total Health Care UnitedHealthcare Community Plan 23

24

MI Health LinkWhere are we

25

MI Health Link 2565

bull This notification is being sent to providers of long term care services including nursing facilities county medical care facilities and hospital long term care units to provide clarification on the process involved with the submission of the Facility Admission Form (MSA-2565-C) for an individual enrolled in the MI Health Link program

bull The MI Health Link program covers the custodiallong term nursing facility service benefit When an individual who is enrolled in the MI Health Link program is admitted to a nursing facility for custodiallong term nursing services a disenrollment from the Integrated Care Organization (MI Health Link health plan) is NOT REQUIRED The Facility Admission Form (MSA-2565-C) should NOT be sent to the Michigan Department of Health and Human Services (MDHHS) Enrollment Services Section for a disenrollment to be processed

26

What are the Names

bull Started as Integrated Health

bull Then called MMP (Medicare Medicaid Program)

bull Duals (Also Known as Duals as in Dual Eligible)

bull Now called MI Health Link

bull Total confusion

27

MI Health Dual Eligible28

MI Health LOC

29

LOC Medicaidbull We have the new pilot program which started on March

1 2015 in Southwest Michigan Region 4 Counties Macomb Wayne and the UP You could see these patients they are dual eligible in the Pilot program in counties surrounding the pilot

bull MHL-LOC 005 (All other Facilities) or LOC 015 (County Care) These residents have to call Michigan Enrolls to dis-enroll toll-free at 1-800-975-7630 (TTY 1-888-263-5897) Monday-Friday from 8 AM to 7 PM Once they dis-enroll they will go to a LOC 02 you have to do a new LOCD

30

Medicaid Redetermination and MHL Enrollmentbull At the time of re-determination for Medicaid financial eligibility the MI

Health Link (MHL) program will not be sending beneficiaries information about this program Beneficiaries who previously opted out will not be passively enrolled according to an email from the MHL staff The MHL staff wrote

bull ldquoThere is currently no MI Health Link enrollment letter sent to beneficiaries when eligibility is re-determined A person who becomes eligible for MI Health Link enrollment may opt-in at any time

bull When Medicaid re-determination takes place the beneficiary remains in the same ICO unless that beneficiary lost Medicaid coverage If the enrollee loses Medicaid coverage and later regains it they are not passively enrolled into MI Health Link The beneficiary may choose to opt back in to the program at that time if desiredrdquo

bull MHL staff did state that about 1500 beneficiaries will be passively enrolled effective January 1 2016 These specific individuals were given normal notice of 60 and 30 days in which to opt-in or opt-out if they so chose No other large scale passive enrollment is scheduled according to the MHL staff 31

MI Health Link Portals

bull Meridian Health Planbull httpwwwmhplancommibull Amerihealthbull httpwwwamerihealthcaritasvipcarepluscomproviderself-service-

toolsindexaspxbull AetnaCoventrybull httpwwwaetnabetterhealthcomMichiganprovidersportalbull Molinabull httpwwwmolinahealthcarecommembersmien-usmemPageshomeaspxbull HAPMidwestbull httpswwwmidwesthealthplancomLoginaspxbull FidelisCentenebull wwwfidelissccommmp 32

MI Health Authorizationsbull We need to watch these authorization that the plans are giving us for the MI

Health program Some plans are assigning a diagnosis for residents in their prior authorizations They are assigning diagnosis that the residents do not even have You need to make sure these are correct diagnosis and if not you need to work with the case managers of the plans to fix the issue The authorization numbers do change

bull Make sure that any resident that is in a MI Health plan that you have a prior authorization All plans are giving different periods authorizing the residents stay in the facility You need to set up a system to make sure you always have a authorization for the period of time you are rendering the service Here is an example of time frame of authorizations

bull Meridian is authorizing 12 monthsbull Aetna is authorizing 3 monthsbull Molina is authorizing 6 monthsbull The authorization numbers need to go on your claims to the payer You need to

put the authorizations in your software and track the dates

33

MI Health Issuesbull We are seeing some issues with MI Health where the resident does not have the correct LOC or it shows

up correct on CHAMPS but ancillary providers such as Dentist and such cannot see it I think we still have some issues with the information crossing between Bridges DHS system CMS and CHAMPS It in return is creating some access of care issues If it is a true LOC issues Facilities with LOC issues need to submit the Medicaid ID numbers to the MSA-MHL-EnrollmentMichigangov box with the subject line Nursing home LOC Issue so they may work to resolve the issues

bull If it becomes an access to care issue email the information to INTEGRATEDCAREmichigangov Remember in these emails only send the Medicaid ID and explain the situation The State will work with the plans to try to fix the process or improve the process

bull We are also seeing with new admission with LOC 015 or 005 that the plans are stating they have 14 days to authorize admission These are resident in the emergency room and possibly be admitted to you for Rehab The hospital will not keep the resident in ER for 14 days and you cannot admit the resident until you have a prior authorization I would recommend when you are told this by the plan that you need to ask to speak to a manager We will have to work through this

bull Ancillary Provider You need to work with your ancillary providers such as Lab Pharmacy X-Ray Physician and such to get the to be credentialed with the plans We are hearing that some of the pharmacies are not participating with the plans this will create issues for you so I would continue to ask these groups to participate

34

LOC 02 dropping MI Health Issuesbull The passive enrollments have occurred in Macomb amp Wayne for

Medicaid dual eligible We are having the same issue we did as in the Southwest MI amp UP with the passive enrollments I am starting to hear from facilities who are checking there CHAMPS member screens that those residents that have opted out (some residents not all) have lost there 02 Make sure you are checking your CHAMPS member screen both for those that were passively enrolled and those that might have lost there 02 Medicaid that opted out

bull Facilities with LOC issues need to submit the Medicaid ID numbers to the (Only MI Health)MSA-MHL-Enrollmentmichigangov box with the subject line Nursing home LOC Issue so they may work to resolve the issues

35

PPA Offset

bull There are no co-pays deductibles or premiums in MI Health Link so there should be no need to offset the PPA with code 25 MI Health Link enrollees can continue to offset their PPA for non-program covered medical expenses (like Vision-Code 27 Dental-Code 28 and Hearing-Code 26) and use the appropriate codes to offset the PPA when billing the health plan for nursing facility services

bull Resident pay PPA when MedicareMedicaid coinsurance

36

LOCDbull Nursing Facility Level of Care Determination (NFLOCD)

bull The MI Health Link health plan will be responsible for conducting the Michigan Medicaid NFLOCD tool for enrollees seeking admission to a nursing facility For existing residents at the time of enrollment the existing NFLOCD will be adopted for capitation payment purposes The health plan will complete a new NFLCOD tool within the first 90 days of enrollment If a nursing facility resident is disenrolled from MI Health Link the nursing facility will be responsible for conducting a new NFLOCD tool in accordance with published Medicaid policy

37

MI Health Issues-New

bull INTEGRATEDCAREmichigangov

bull Email with Insurance Plan issues Case Manager Issues

38

ACOWhat are they

39

Families Receiving Letters for ACO

40

ACO What is It

bull Whats an ACObull Accountable Care Organizations (ACOs) are groups of doctors hospitals

and other health care providers who come together voluntarily to give coordinated high quality care to their Medicare patients

bull The goal of coordinated care is to ensure that patients especially the chronically ill get the right care at the right time while avoiding

unnecessary duplication of services and preventing medical errorsbull When an ACO succeeds both in delivering high-quality care and

spending health care dollars more wisely it will share in the savings it achieves for the Medicare program

41

Payroll Based JournalMandatory on July 1 2016Internet Explorer Version

Internet Explorer v 10 and v 11 will need to operate in compatibility mode

42

43

If you submit data manually should you also submit it through the XML

bull Now you have three options

bull Submit Manually only

bull Submit through the XML only

bull You are able to submit manually and using the XML

44

45

Staffing Submission Frequently Asked Questions

bull ldquoWho are direct care staffrdquo (Who do we submit data for)bull Submission of data for contract staffbull Medical directors and consultantsbull Staff switching roles or tasks throughout the daybull Hours paid vs hours worked ndash Must be verifiablebull Public postingQuality MeasuresFive Starbull Enforcementbull Voluntary submission risks (noneSo register now)

CMS defines

bull 37 job title codes that are required to match employees to the number of hours each direct care function was performed It is important to work with your teams to define the workers that contribute to each job type and how those daily worked hours are recorded and converted to a PBJ submission

bull The PBJ does include some more specific job descriptions than the 671 For example the PBJ system includes job descriptions for RNs with administrative duties and LPNs with administrative duties versus the 671rsquos more general ldquoNurses with Administrative Duties

Page 46

47

PBJ Medical Director Rolebull Physician Leadership

bull Help the facility ensure that patients have appropriate physician coverage and ensure the provision of physician and health care practitioner services and

bull Help the facility develop a process for reviewing physician and health care practitioner credentials

bull Provide specific guidance for physician performance expectations

bull Help the facility ensure that a system is in place for monitoring the performance of health care practitioners and

bull Facilitate feedback to physicians and other health care practitioners on performance and practices

bull Patient Care - Clinical Leadership

bull Participate in administrative decision-making and the development of policies and procedures related to patient care

bull Help develop approve and implement specific clinical practices for the facility to incorporate into its care-related policies and procedures including areas required by laws and regulations

bull Develop procedures and guidance for facility staff regarding contacting practitioners including information gathering and presentation change in condition assessment and when to contact the medical director

bull Review consider andor act upon consultant recommendations as appropriate that affect the facilitys resident care policies and procedures or the care of an individual resident

bull Review respond to and participate in federal state local and other external surveys and inspections and

bull Help review policies and procedures regarding the adequate protection of patients rights advance care planning and other ethical issues48

PBJ Medical Director Rolebull Quality of Care

bull Help the facility establish systems and methods for reviewing the quality and appropriateness of clinical care and other health-related services and provide appropriate feedback and

bull Participate in the facilitys quality improvement process

bull Advise on infection control issues and approve specific infection control policies to be incorporated into facility policies and procedures

bull Help the facility provide a safe and caring environment

bull Help promote employee health and safety and

bull Assist in the development and implementation of employee health policies and programs

bull Education Information and Communication

bull Promote a learning culture within the facility by educating informing and communicating

bull Provide information to help the facility provide care consistent with current standards of practice (defined as approaches to care procedures techniques and treatments that are based on research and or expert consensus and that are contained in current manuals textbooks and or publications or that are accepted adopted or promulgated by recognized organizations or national bodies)

bull Help the facility develop medical information and communication systems with staff patients and families and others

bull Represent the facility to the professional and lay community on medical and patient care issues

bull Maintain knowledge of the changing social regulatory political and economic factors that affect medical and health services of long term care patients and

bull Help establish appropriate relationships with other health care organizations

49

Dietician

bull When the dietary or food services supervisor is other than a registered dietitian the supervisor shall receive routine consultation and technical assistance from a registered dietitian (RD) Consultation time shall not be less than 4 hours every 60 days Additional consultation time may be needed based on the total number of patients incidence of nutrition-related health problems and food service management needs of the facility

50

Pharmacy Consultant

bull At least once per month a licensed pharmacist must perform a drug regimen review (DRR) for each resident The pharmacist must report any irregularities to the attending physician or director of nursing Furthermore these reports must be acted upon

51

What are the names for the Medicare Numberbull OSCAR -Online Survey Certification and Reporting

bull PTAN-PTAN number is assigned by Medicare to authenticate the provider when using the local Medicare Administrative Contractorrsquos (MAC) self-help tools like the IVR internet portal on-line application status etc Provider Transactions Access Number

bull CCN- CMS Certification Number

bull Medicare Number- example 23-

bull All of the above mean the same thing

52

QTSO

bull Once you are logged in the QTSO site bull You will have a state login to the site to access the various site specific

to your facilitybull Installing you will need administrator rights to your network

53

Medicare UpdateWhat are we seeing

54

CMS Final Rule On Returning Credits

httpswwwfederalregistergovarticles201602122016-02789medicare-program-reporting-and-returning-of-overpayments

55

Over Payment Rule

bull Medicare payments for non covered services

bull Medicare payments in excess of the allowable amount for an identified covered service

bull Errors and non reimbursable expenditures in cost reportsbull Duplicate payment

bull Receipt of Medicare payments when another payor had the primary responsibility for payment

56

Questions to MAC

bull Does the Medicare credit balance report change with this overpayment rule

bull No Medicare Credit Balances are still required at the end of each quarter

bull Will that still be the communication to let CMS or the MAC know that we have received an overpayment

bull Submission of Medicare Credit Balance is one form of communicating overpayments to CMS Other methods include submitting a voluntary refund with required claim information or the submission of a standard overpayment form

57

Questions to MAC

bull Will the MAC still deduct from a future RAbull If the recovery of the overpayment includes adjusting a claim then

the overpayment would be netted against future claims payments and reflected on the RA

bull Or will that process change with this new rulebull Process will remain the samebull Will NGS send communication out on thisbull Yes NGS will communicate this once the final rule is communicated

to the MACs by CMS However this could change depending on final CMS instructions

58

Final Rule on Returning Credits

bull Providers will want to immediately update their current policies governing overpayments in order to comply with this new rule which will take effect on March 14 2016

bull Providers and suppliers are required to use reasonable diligence to investigate credible information regarding overpayments through both proactive compliance efforts and reactive investigations

bull If an overpayment is identified then it must be repaid within 60 days An overpayment is identified when a person has or should have through the exercise of reasonable diligence determined that the person received an overpayment and quantified the amount

bull Providers and suppliers have a maximum of 8 months to report and return overpayments ndash up to 6 months to investigate and quantify the overpayment (ie to identify it) and up to 60 days to report and return the overpayment

59

Final Rule on Returning Credits

bull Providers and suppliers are required to report and return all overpayments within a 6-year lookback period

bull The cause and amount of the overpayment is irrelevant for the determination eg it was due to a mistake it was someone elsersquos fault it is a minor amount An overpayment is an overpayment and must be returned

bull Providers and suppliers must make their own determination to which entity to report and return the overpayment ie to the Medicare contractor or using the OIG Self Disclosure Protocol or the CMS Self Referral Disclosure Protocol

60

Final Rule on Returning Credits

bull Providers and suppliers may use the claims adjustment credit balance self-reported refund process or another appropriate process to report and return overpayments At this time there is no standard refund form to use

bull Failure to report and return an overpayment could subject the provider or supplier to False Claims Act liability Civil Monetary Penalties Law liability and exclusion from federal health care programs

61

P S amp R-Accountants will be asking for this information

The location you login into has changed it is now on EIDM EIDM is the acronym for CMS Enterprise Identity Management system which includes Identity Verification Access Management Authorization Assistance Workflow Tools and Identity Lifecycle Management functions

httpswwwcmsgovResearch-Statistics-Data-and-SystemsCMS-Information-TechnologyIACSCMS-Applications-Loginhtml

Go down the page and click on the PSampRSTARThis will take you to the login pagewill look the same as the old P S amp R didChanges Affecting PSampR System Access (Please Read) (posted 01292015)(Updated 5262015)is changingThe system which controls your PSampR user ID (currently IACS)The new system is referred to as EIDMThis will result in a different way to create new accounts or change passwords to existing accountsIf you already have an account in EIDM you may have to use that account for accessing PSampR after the transitionWhen is the change effectiveJune 13 2015What is staying the sameThe internet address for accessing PSampR remains the sameThe PSampR systemfunctionality is NOT changing 62

Medicare Advantage Payorsbull Medicare Advantage payors are pullingdenying payments on admissions if the patient was readmitted within 30 days after discharge The

client believes that the payors systematically denying payments for all readmissions within 30 days They believe this practice denies them due process to address whether the readmissions were justified and not due to a premature discharge of patient The payors seem to want to act like a QIO without having the same accountabilities of the QIO related to determinations of non-payment

bull Heres the QIO process under section 4240 of the QIO Manualbull 4240 - Readmission Review - (Rev 2 07-11-03)bull Readmission review involves admissions to an acute general short-term hospital occurring less than 31 calendar days from the date of

discharge from the same or another acute general short-term hospital (see sect1154(a)(13) and 42 CFR 47671(a)(8)(ii)) Neither the day of discharge nor the day of admission is counted when determining whether a readmission has occurred

bull A Medical Review Proceduresbull Obtain the appropriate medical records for the initial admission and readmission Perform case review on both stays Analyze the cases

specifically to determine whether the patient was prematurely discharged from the first confinement thus causing readmission Perform an analysis of the stay at the first hospital to determine the cause(s) and extent of any problem(s) (eg incomplete or substandard treatment) Consider the information available to the attending physician who discharged the patient from the first confinement Do not base a determination of a premature discharge on information that the physician or provider could not have known or events that could not have been anticipated at the time of discharge

bull Review both the initial admission and the readmission at the same time unless one of them has previously been reviewed In these cases use at a minimum the PRAF case summary of the other admission in addition to the medical record of the case under review

bull C Denialsbull Deny readmissions under the following circumstancesbull If the readmission was medically unnecessarybull If the readmission resulted from a premature discharge from the same hospital orbull If the readmission was a result of circumvention of PPS by the same hospital (see sect4255)bull With the QIO process there is an appeal within the QIO here the hospital is getting no opportunity to challenge the denials

63

Medicare Provider Enrollment Feebull Provider Enrollment Application Fee Amount for CY 2016bull On December 3 CMS issued a notice Provider Enrollment Application

Fee Amount for CY 2016 [CMSndash6066ndashN] Effective January 1 2016 the CY 2016 application fee is $554 for institutional providers that are

bull Initially enrolling in the Medicare or Medicaid program or the Childrens Health Insurance Program (CHIP)

bull Revalidating their Medicare Medicaid or CHIP enrollmentbull Adding a new Medicare practice locationbull This fee is required with any enrollment application submitted from

January 1 through December 31 2016

64

Medicare MAC-Higlas

bull Effective 142016 CMS has implemented a change to begin netting (offsetting) provider money across workloads within a single organization What this means is that any related providers conducting business in two different workloads (example New York and Maine) will have their money applied to any account receivables (AR) with a remaining balance owed to Medicare within both workloads For example Provider ABC is located in New York and is scheduled to receive a payment of $1000 on todays remittance advice Provider XYZ is related to provider ABC but is located in Maine and has ARs with a balance owed of $200 Provider ABCs $1000 payment will have the $200 applied against provider XYZs ARs resulting in a net payment of $800 This will be reflected on the remittance advice by the same PLB code as seen today for offsets for the $200

65

Two Midnight RuleChange January 1 2016 httpswwwcmsgovMedicareMedicare-Fee-for-Service-PaymentHospitalOutpatientPPSHospital-Outpatient-Regulations-and-Notices-ItemsCMS-1633-FChtml

66

Two Midnight Rulebull However effective January 1 2016 CMS will allow exceptions to the

Two-Midnight Benchmark to be determined on a case-by-case basis by the physician responsible for the care of the beneficiary subject to medical review Said differently Part A payment may be appropriate in some circumstances even though there is no expectation by the physician (or qualified ordering practitioner) of a two-midnight stay and one of the two pre-existing categorical exceptions (CMS ldquoinpatient onlyrdquo list and newly initiated mechanical ventilation) does not apply CMS has indicated that this change to the Two Midnight Rule is in response to stakeholder concern and CMSrsquos continued efforts to develop the most appropriate standard for determining Medicare Part A payment

67

Two Midnight Rulebull A new 42 CFR sect4123(a) provides that a patient is considered an

inpatient of a hospitalhellipif formally admitted as an inpatient pursuant to an order for inpatient admission by a physician or other qualified practitionerhellip The physician orders inpatient status when he or she expects the patient to require a stay that crosses at least 2 midnights[10] Stays expected to be shorter than at least two midnights are generally inappropriate for inpatient admission and inpatient payment under Medicare Part A unless the surgical procedure is specified by Medicare as inpatient only under sect41922(n)[11] The physicians expectationhellipshould be based on such complex medical factors as patient history and comorbidities the severity of signs and symptoms current medical needs and the risk of an adverse event[12] The physician order is part of physician certification of the medical necessity of hospital inpatient serviceshellip[13]

68

InPatient Vs Observation Conthellip

bull Physician certification which begins with an order for inpatient admission requires the physician to certify the reasons for the hospitalization the estimated time the patient will remain in the hospital and plans for post-hospital care if appropriate[14] The certification must be completed signed and documented in the medical record prior to discharge[15]

bull A physicians admission order has no presumptive weight and both the admission order and the physician certification will be evaluated in the context of the evidence in the medical record[16] CMS intends to provide additional information about what evidence in the medical record means in future instructions and manual revisions[17]

69

Two Midnight Rulebull Although the new case-by-case exception appears to be inherently

subjective to a certain extent CMS states that the following factors (among others) would be relevant to determining whether a patient requires inpatient admission under the expanded policy

bull The severity of the signs and symptoms exhibited by the patient bull The medical predictability of something adverse happening to the patient

and bull The need for diagnostic studies that appropriately are outpatient services

(that is their performance does not ordinarily require the patient to remain at the hospital for 24 hours or more)

bull CMS also notes that an inpatient admission (and Part A payment) should be ldquorare and unusualrdquo for minor surgical procedures or other treatment that is expected to keep the patient in the hospital ldquofor only a few hoursrdquo or for a period of time that ldquodoes not span at least overnightrdquo (thus a subset of stays not meeting the Two Midnight Benchmark) CMS indicates that such cases will be prioritized for medical review

70

Health Data Insights amp Medicare Plus Blue

RAC (Retrospective Audits)

71

HDI Health Data amp Med Plus Blue

bull httpwwwhealthdatainsightscombull Blue Cross Medicare Advantage Auditsbull Facilities seeing 10 to 15 requests for Medical Recordsbull In January amp Feburarybull Selected Health Data Insights because they were a premier Audit

Vendor for CMS Recovery Audit Contractor (RAC) demonstration Project They are a audit vendor for Humana

bull Providers not sending Medical Record will get technical denial and lose payments

72

Health Data InSight

bull In 2010 they began the Hospital Reviewbull Medicare Advantage encounter datandashCMS oversight of data integrity OIG

2016bull We will review CMSs oversight of MA encounter data validation and assess

the extent to which CMSrsquos Integrated Data Repository contains timely valid and complete MA encounter data In 2012 CMS began collecting from MA organizations a more comprehensive set of encounter data reflecting the items and services provided to MA plan enrollees Prior CMS and OIG audits have indicated vulnerabilities in the accuracy of data reporting by MA organizations Realizing the potential benefits of the MA encounter data for payment and program integrity oversight is contingent upon the datarsquos completeness validity and timeliness (OEI 03-15-00060 expected issue date FY 2017)

73

Pepper Reports

bull httpswwwpepperresourcesorg

bull Program for Evaluating Payment Patterns Electronic Report ( PEPPER)

bull Annually on or about April 18 2016 will be released

bull Pepper Portal httpssecurefiletmforg

74

CGI Technologies and Solutions Inc httpracbcgicomContactInfoaspxst=1

bull Indiana bull Michiganbull Minnesotabull Illinoisbull Kentuckybull Ohiobull Wisconsin CGI Technologies and Solutions Incbull For general and administrative questions regarding client service outreach

quality assurance or project-specific issues contactbull 1877316RACB (7222)bull Email racbcgicom Tamara Tate Tamaratatecmshhsgovbull 4107861288

75

CGI Federal RAC

bull CGI Federal RAC Region Bbull Email racbcgicombull Phone 1-877-316-RACB (7222)bull Mailing Addressbull Send medical records as followsbull Medical records for Indiana Illinois Kentucky Michigan Ohio Wisconsin

Minnesota DME and Home Health CGI Federal Inc Attn RACB Imaging Dept 1001 Lakeside Ave Suite 800 Cleveland OH 44114

bull If submitting paper records please send medical records as follows For Therapy Reviews CGI Federal Inc Attn RACB Imaging 1001 Lakeside Avenue Suite 800 Cleveland OH 44114

76

How to survive RAC Audit

bull National health expenditures totaled $1679 Billion in 2003 bull National health expenditures were 153 of GROSS Domestic Product

(GDP) in 2003 bull Health care cost increasing at +9 per year bull Doomsday predictions of Medicare running out bull Congressional Action

77

RAC Audits

bull Medicare Modernization Act (MMA) of 2003Mandated a three year audit demonstration project 2005-2008

bull Appoint audit contractors to review Medicare billings for proper coding DRG assignment and medical necessity

bull Audits will apply to all health care providers (hospitals physicians homecare dme etc)

bull Audit contractors to be paid on a contingency basis a percentage of overpayments recovered

78

How Did we get here

bull Overpayments collected due to errors in Medically Unnecessary Services ndash 40

bull Incorrectly Coded ndash 35

bull Other ndash 17

bull NoInsufficient Documentation ndash 8

79

Where are we now

bull All RACrsquos completed required provider outreachAccess to Medicare billing data base given to all RAC RAC review methodology

bull Automated Review-Black amp White Issues (current) bull DRG Validation-complex review (current) bull Complex Review for coding errors (current) bull DME Medical Necessity Reviews ndashcomplex review (calendar year

2010) bull Medical Necessity Reviews-complex review (calendar year 2010)

80

RAC Reviews

bull Responsibilities of the Team Leader bull Must learn each insurance provider participating in a RAC or RAC type

program bull What are their operating rulesbull What is their appeal process Time limits

May be different process for each insurance provider bull Develop a response team

Identify who does what when why and alternate bull individual

Build and develop a manual process Review of computerized system

81

Priority Health SCIO Health Analytics

bull httpswwwsciohealthanalyticscomcore-capabilitiespayment-integrityfacility-auditsskilled-nursing-facility-audits

bull Claims for Medicare members treated at Skilled Nursing Facilities are reimbursed based on the patientsrsquo RUG (Resource Utilization Group) score which is determined using the Minimum Data Set (MDS) Using SCIOs robust analytics claims andor providers that merit review are selected for audit SCIOs auditors conduct a detailed review of the complete medical record and associated MDS to determine if the billed RUG score is valid In the event the review determines that an incorrect RUG score was billed SCIOreg provides the valid score reports the reason the change was necessary and calculates the resulting overpayment

82

+ Cheer

Onward and Upward she shall prevail We are here to care for the residents and provide a wonderful

service

13 83

84

References

bull Priority Healthbull Blue Crossbull Medicaidbull Medicare

85

  • Medicare Mange Care amp Medicaid Changes in the New World We Live In
  • Medicaid
  • NEW Medicaid Change MIlogin
  • Blueprint for Health Innovation MI
  • Provider Enrollment Electronic Signature Form Submission Process MSA 15-54
  • Provider Enrollment Electronic Signature Form Submission Process
  • Provider Enrollment Domain Administrator
  • Medicaid Coinsurance Medicare Advantage
  • Slide Number 9
  • Lawsuit DHS Changes on Caregivers
  • TPL Medicaid Change
  • CHAMPS Member Screen
  • LOC dropping off Not Due to MI Health
  • Issues
  • Secure Email Information
  • Medicaid amp Hospice
  • Medicaid
  • Medicaid Medicare Buy In
  • Manage Medicaid
  • Healthy Michigan Residents
  • Healthy Michigan Medicaid Days
  • McLaren Health Plan
  • Manage Medicaid Plans January 1
  • Slide Number 24
  • MI Health Link
  • MI Health Link 2565
  • What are the Names
  • MI Health Dual Eligible
  • MI Health LOC
  • LOC Medicaid
  • Medicaid Redetermination and MHL Enrollment
  • MI Health Link Portals
  • MI Health Authorizations
  • MI Health Issues
  • LOC 02 dropping MI Health Issues
  • PPA Offset
  • LOCD
  • MI Health Issues-New
  • ACO
  • Families Receiving Letters for ACO
  • ACO What is It
  • Payroll Based Journal
  • Slide Number 43
  • If you submit data manually should you also submit it through the XML
  • Staffing Submission Frequently Asked Questions
  • CMS defines
  • Slide Number 47
  • PBJ Medical Director Role
  • PBJ Medical Director Role
  • Dietician
  • Pharmacy Consultant
  • What are the names for the Medicare Number
  • QTSO
  • Medicare Update
  • CMS Final Rule On Returning Credits
  • Over Payment Rule
  • Questions to MAC
  • Questions to MAC
  • Final Rule on Returning Credits
  • Final Rule on Returning Credits
  • Final Rule on Returning Credits
  • Slide Number 62
  • Medicare Advantage Payors
  • Medicare Provider Enrollment Fee
  • Medicare MAC-Higlas
  • Two Midnight Rule
  • Two Midnight Rule
  • Two Midnight Rule
  • InPatient Vs Observation Conthellip
  • Two Midnight Rule
  • Health Data Insights amp Medicare Plus Blue
  • HDI Health Data amp Med Plus Blue
  • Health Data InSight
  • Pepper Reports
  • CGI Technologies and Solutions Inc httpracbcgicomContactInfoaspxst=1
  • CGI Federal RAC
  • How to survive RAC Audit
  • RAC Audits
  • How Did we get here
  • Where are we now
  • RAC Reviews
  • Priority Health SCIO Health Analytics
  • Cheer
  • References
Page 14: Medicare, Mange Care & Medicaid Changes in the New World we live in

Issues

bull PPA going all over the place

bull LOC 02 dropping off not related to MI Health

bull LOCD tons of money written off

bull Must check CHAMPS member screen all the time and you must check pending

14

Secure Email Information

bull The State of Michigan asked me to remind you when you are communicating with them regarding residents to not send Resident names Birthdates or Social security numbers in those emails What you send is the Medicaid ID and they can look it up Or if it is a billing issue send them the TCN and the Medicaid ID We have been in the practice of emailing DHS Ardene Martin Integrated Health and Provider Support with all the resident name and such

15

Medicaid amp Hospicebull LOC 07 Manage Medicaid Hospice included so plan would pay

provider and not switch to a LOC 16

bull LOC 02 Medicaid (Regular Medicaid) Hospice not included so switch to 16 Hospice and Hospice pays provider

bull LOC 11 Healthy Michigan is included in plan so plan would pay provider and not switch to LOC 16

bull LOC 005 amp 015 MI Health is up in the air waiting for CMS Currently Hospice is now included

bull LOC 16 is Hospice when they switch from Regular Medicaid only and Hospice pays provider

16

Medicaidbull Going forward please make sure that your Champs ID amp NPI on your member screen matches your facility CHAMPS ID

amp NPI for each resident and matches for all new admissions or new approved Medicaid going forward

bull The edit will be turned on soon to stop the payment of these claims if the CHAMPS ID and NPI do not Match your facility on the Medicaid member screen

bull Make sure you are putting the information correct on the 2565 you send in to DHS

bull 1 I attached a 2565 When you fill this out for new people make sure in box 12 a you put your NPI and 12 b you put your CHAMPS ID This will help the DHS case workers assign the person to your facility

bull 2 I would check all your residents CHAMPS member screens and make sure the NPI and CHAMPS ID are your facilities If not you will have to work with the DHS worker to fix this The DHS worker is the only one that can fix this

bull 3 We are having some issues where the DHS case workers will not change this NPI and CHAMPS ID to your facilities You have to get them to change it or you just will not get paid

bull 4 We situations where the resident is in a facility in Kent County (as an example) but the family lives in Livingston County and completes the applications in Livingston County You will have to get the DHS worker in Livingston to fix it not the local DHS worker in Kent County where your facility is

17

Medicaid Medicare Buy Inbull Based on the information from the Office of Personnel Management Federal

Employeersquos employed as of January 1 1983 are eligible for Medicare Part A(see page 5 of attached document) This was also confirmed with our Social Security liaison If the beneficiary did not retire before 1983 he can enroll in Medicare Part B and pay the premium and then he can enroll in Medicare Part A and pay that premium as well or may qualify for Medicare Buy in of Part A

bull If a beneficiary has an SSA document stating they are not eligible for Medicare as they do not have enough work credits the beneficiarybeneficiary representative needs to go to SSA and let them know that while they know they are not eligible for Medicare Part A free or reduced however they are eligible for Medicare Part B and would like to enroll Once the beneficiary enrolls in Medicare Part B (enrollment period January 1st ndash March 31 each year) and pays the premium then the beneficiary is eligible to either pay for Medicare Part A or that beneficiary may qualify for Medicare Part A buy in through Medicaid Once the beneficiary is enrolled in Medicare Part A and Medicare Part B Medicaid will begin to make payments on claims

18

Manage Medicaid Where are we

19

Healthy Michigan Residents

20

Healthy Michigan Medicaid Days

21

McLaren Health Plan

22

Manage Medicaid Plans January 1bull Region 1 ndash Upper Peninsula Health Planbull Region 2 ndash McLaren Health Plan Meridian Health Plan of Michigan Molina Healthcare of Michigan

UnitedHealthcare Community Planbull Region 3 ndash McLaren Health Plan Meridian Health Plan of Michigan Molina Healthcare of Michigan

UnitedHealthcare Community Planbull Region 4 ndash Blue Cross Complete of Michigan McLaren Health Plan Meridian Health Plan of Michigan Molina

Healthcare of Michigan Priority Health Choice UnitedHealthcare Community Planbull Region 5 ndash McLaren Health Plan Meridian Health Plan of Michigan Molina Healthcare of Michigan

UnitedHealthcare Community Planbull Region 6 ndash Blue Cross Complete of Michigan HAP Midwest Health Plan McLaren Health Plan Meridian Health

Plan of Michigan Molina Healthcare of Michigan UnitedHealthcare Community Planbull Region 7 ndash Blue Cross Complete of Michigan McLaren Health Plan Meridian Health Plan UnitedHealthcare

Community Planbull Region 8 ndash Aetna Better Health of Michigan McLaren Health Plan Meridian Health Plan of Michigan Molina

Healthcare of Michigan Priority Health Choice UnitedHealthcare Community Planbull Region 9 ndash Aetna Better Health of Michigan Blue Cross Complete of Michigan McLaren Health Plan Meridian

Health Plan of Michigan Molina Healthcare of Michigan UnitedHealthcare Community Planbull Region 10 ndash Aetna Better Health of Michigan Blue Cross Complete of Michigan Harbor Health Plan McLaren

Health Plan Meridian Health Plan of Michigan Molina Healthcare of Michigan Total Health Care UnitedHealthcare Community Plan 23

24

MI Health LinkWhere are we

25

MI Health Link 2565

bull This notification is being sent to providers of long term care services including nursing facilities county medical care facilities and hospital long term care units to provide clarification on the process involved with the submission of the Facility Admission Form (MSA-2565-C) for an individual enrolled in the MI Health Link program

bull The MI Health Link program covers the custodiallong term nursing facility service benefit When an individual who is enrolled in the MI Health Link program is admitted to a nursing facility for custodiallong term nursing services a disenrollment from the Integrated Care Organization (MI Health Link health plan) is NOT REQUIRED The Facility Admission Form (MSA-2565-C) should NOT be sent to the Michigan Department of Health and Human Services (MDHHS) Enrollment Services Section for a disenrollment to be processed

26

What are the Names

bull Started as Integrated Health

bull Then called MMP (Medicare Medicaid Program)

bull Duals (Also Known as Duals as in Dual Eligible)

bull Now called MI Health Link

bull Total confusion

27

MI Health Dual Eligible28

MI Health LOC

29

LOC Medicaidbull We have the new pilot program which started on March

1 2015 in Southwest Michigan Region 4 Counties Macomb Wayne and the UP You could see these patients they are dual eligible in the Pilot program in counties surrounding the pilot

bull MHL-LOC 005 (All other Facilities) or LOC 015 (County Care) These residents have to call Michigan Enrolls to dis-enroll toll-free at 1-800-975-7630 (TTY 1-888-263-5897) Monday-Friday from 8 AM to 7 PM Once they dis-enroll they will go to a LOC 02 you have to do a new LOCD

30

Medicaid Redetermination and MHL Enrollmentbull At the time of re-determination for Medicaid financial eligibility the MI

Health Link (MHL) program will not be sending beneficiaries information about this program Beneficiaries who previously opted out will not be passively enrolled according to an email from the MHL staff The MHL staff wrote

bull ldquoThere is currently no MI Health Link enrollment letter sent to beneficiaries when eligibility is re-determined A person who becomes eligible for MI Health Link enrollment may opt-in at any time

bull When Medicaid re-determination takes place the beneficiary remains in the same ICO unless that beneficiary lost Medicaid coverage If the enrollee loses Medicaid coverage and later regains it they are not passively enrolled into MI Health Link The beneficiary may choose to opt back in to the program at that time if desiredrdquo

bull MHL staff did state that about 1500 beneficiaries will be passively enrolled effective January 1 2016 These specific individuals were given normal notice of 60 and 30 days in which to opt-in or opt-out if they so chose No other large scale passive enrollment is scheduled according to the MHL staff 31

MI Health Link Portals

bull Meridian Health Planbull httpwwwmhplancommibull Amerihealthbull httpwwwamerihealthcaritasvipcarepluscomproviderself-service-

toolsindexaspxbull AetnaCoventrybull httpwwwaetnabetterhealthcomMichiganprovidersportalbull Molinabull httpwwwmolinahealthcarecommembersmien-usmemPageshomeaspxbull HAPMidwestbull httpswwwmidwesthealthplancomLoginaspxbull FidelisCentenebull wwwfidelissccommmp 32

MI Health Authorizationsbull We need to watch these authorization that the plans are giving us for the MI

Health program Some plans are assigning a diagnosis for residents in their prior authorizations They are assigning diagnosis that the residents do not even have You need to make sure these are correct diagnosis and if not you need to work with the case managers of the plans to fix the issue The authorization numbers do change

bull Make sure that any resident that is in a MI Health plan that you have a prior authorization All plans are giving different periods authorizing the residents stay in the facility You need to set up a system to make sure you always have a authorization for the period of time you are rendering the service Here is an example of time frame of authorizations

bull Meridian is authorizing 12 monthsbull Aetna is authorizing 3 monthsbull Molina is authorizing 6 monthsbull The authorization numbers need to go on your claims to the payer You need to

put the authorizations in your software and track the dates

33

MI Health Issuesbull We are seeing some issues with MI Health where the resident does not have the correct LOC or it shows

up correct on CHAMPS but ancillary providers such as Dentist and such cannot see it I think we still have some issues with the information crossing between Bridges DHS system CMS and CHAMPS It in return is creating some access of care issues If it is a true LOC issues Facilities with LOC issues need to submit the Medicaid ID numbers to the MSA-MHL-EnrollmentMichigangov box with the subject line Nursing home LOC Issue so they may work to resolve the issues

bull If it becomes an access to care issue email the information to INTEGRATEDCAREmichigangov Remember in these emails only send the Medicaid ID and explain the situation The State will work with the plans to try to fix the process or improve the process

bull We are also seeing with new admission with LOC 015 or 005 that the plans are stating they have 14 days to authorize admission These are resident in the emergency room and possibly be admitted to you for Rehab The hospital will not keep the resident in ER for 14 days and you cannot admit the resident until you have a prior authorization I would recommend when you are told this by the plan that you need to ask to speak to a manager We will have to work through this

bull Ancillary Provider You need to work with your ancillary providers such as Lab Pharmacy X-Ray Physician and such to get the to be credentialed with the plans We are hearing that some of the pharmacies are not participating with the plans this will create issues for you so I would continue to ask these groups to participate

34

LOC 02 dropping MI Health Issuesbull The passive enrollments have occurred in Macomb amp Wayne for

Medicaid dual eligible We are having the same issue we did as in the Southwest MI amp UP with the passive enrollments I am starting to hear from facilities who are checking there CHAMPS member screens that those residents that have opted out (some residents not all) have lost there 02 Make sure you are checking your CHAMPS member screen both for those that were passively enrolled and those that might have lost there 02 Medicaid that opted out

bull Facilities with LOC issues need to submit the Medicaid ID numbers to the (Only MI Health)MSA-MHL-Enrollmentmichigangov box with the subject line Nursing home LOC Issue so they may work to resolve the issues

35

PPA Offset

bull There are no co-pays deductibles or premiums in MI Health Link so there should be no need to offset the PPA with code 25 MI Health Link enrollees can continue to offset their PPA for non-program covered medical expenses (like Vision-Code 27 Dental-Code 28 and Hearing-Code 26) and use the appropriate codes to offset the PPA when billing the health plan for nursing facility services

bull Resident pay PPA when MedicareMedicaid coinsurance

36

LOCDbull Nursing Facility Level of Care Determination (NFLOCD)

bull The MI Health Link health plan will be responsible for conducting the Michigan Medicaid NFLOCD tool for enrollees seeking admission to a nursing facility For existing residents at the time of enrollment the existing NFLOCD will be adopted for capitation payment purposes The health plan will complete a new NFLCOD tool within the first 90 days of enrollment If a nursing facility resident is disenrolled from MI Health Link the nursing facility will be responsible for conducting a new NFLOCD tool in accordance with published Medicaid policy

37

MI Health Issues-New

bull INTEGRATEDCAREmichigangov

bull Email with Insurance Plan issues Case Manager Issues

38

ACOWhat are they

39

Families Receiving Letters for ACO

40

ACO What is It

bull Whats an ACObull Accountable Care Organizations (ACOs) are groups of doctors hospitals

and other health care providers who come together voluntarily to give coordinated high quality care to their Medicare patients

bull The goal of coordinated care is to ensure that patients especially the chronically ill get the right care at the right time while avoiding

unnecessary duplication of services and preventing medical errorsbull When an ACO succeeds both in delivering high-quality care and

spending health care dollars more wisely it will share in the savings it achieves for the Medicare program

41

Payroll Based JournalMandatory on July 1 2016Internet Explorer Version

Internet Explorer v 10 and v 11 will need to operate in compatibility mode

42

43

If you submit data manually should you also submit it through the XML

bull Now you have three options

bull Submit Manually only

bull Submit through the XML only

bull You are able to submit manually and using the XML

44

45

Staffing Submission Frequently Asked Questions

bull ldquoWho are direct care staffrdquo (Who do we submit data for)bull Submission of data for contract staffbull Medical directors and consultantsbull Staff switching roles or tasks throughout the daybull Hours paid vs hours worked ndash Must be verifiablebull Public postingQuality MeasuresFive Starbull Enforcementbull Voluntary submission risks (noneSo register now)

CMS defines

bull 37 job title codes that are required to match employees to the number of hours each direct care function was performed It is important to work with your teams to define the workers that contribute to each job type and how those daily worked hours are recorded and converted to a PBJ submission

bull The PBJ does include some more specific job descriptions than the 671 For example the PBJ system includes job descriptions for RNs with administrative duties and LPNs with administrative duties versus the 671rsquos more general ldquoNurses with Administrative Duties

Page 46

47

PBJ Medical Director Rolebull Physician Leadership

bull Help the facility ensure that patients have appropriate physician coverage and ensure the provision of physician and health care practitioner services and

bull Help the facility develop a process for reviewing physician and health care practitioner credentials

bull Provide specific guidance for physician performance expectations

bull Help the facility ensure that a system is in place for monitoring the performance of health care practitioners and

bull Facilitate feedback to physicians and other health care practitioners on performance and practices

bull Patient Care - Clinical Leadership

bull Participate in administrative decision-making and the development of policies and procedures related to patient care

bull Help develop approve and implement specific clinical practices for the facility to incorporate into its care-related policies and procedures including areas required by laws and regulations

bull Develop procedures and guidance for facility staff regarding contacting practitioners including information gathering and presentation change in condition assessment and when to contact the medical director

bull Review consider andor act upon consultant recommendations as appropriate that affect the facilitys resident care policies and procedures or the care of an individual resident

bull Review respond to and participate in federal state local and other external surveys and inspections and

bull Help review policies and procedures regarding the adequate protection of patients rights advance care planning and other ethical issues48

PBJ Medical Director Rolebull Quality of Care

bull Help the facility establish systems and methods for reviewing the quality and appropriateness of clinical care and other health-related services and provide appropriate feedback and

bull Participate in the facilitys quality improvement process

bull Advise on infection control issues and approve specific infection control policies to be incorporated into facility policies and procedures

bull Help the facility provide a safe and caring environment

bull Help promote employee health and safety and

bull Assist in the development and implementation of employee health policies and programs

bull Education Information and Communication

bull Promote a learning culture within the facility by educating informing and communicating

bull Provide information to help the facility provide care consistent with current standards of practice (defined as approaches to care procedures techniques and treatments that are based on research and or expert consensus and that are contained in current manuals textbooks and or publications or that are accepted adopted or promulgated by recognized organizations or national bodies)

bull Help the facility develop medical information and communication systems with staff patients and families and others

bull Represent the facility to the professional and lay community on medical and patient care issues

bull Maintain knowledge of the changing social regulatory political and economic factors that affect medical and health services of long term care patients and

bull Help establish appropriate relationships with other health care organizations

49

Dietician

bull When the dietary or food services supervisor is other than a registered dietitian the supervisor shall receive routine consultation and technical assistance from a registered dietitian (RD) Consultation time shall not be less than 4 hours every 60 days Additional consultation time may be needed based on the total number of patients incidence of nutrition-related health problems and food service management needs of the facility

50

Pharmacy Consultant

bull At least once per month a licensed pharmacist must perform a drug regimen review (DRR) for each resident The pharmacist must report any irregularities to the attending physician or director of nursing Furthermore these reports must be acted upon

51

What are the names for the Medicare Numberbull OSCAR -Online Survey Certification and Reporting

bull PTAN-PTAN number is assigned by Medicare to authenticate the provider when using the local Medicare Administrative Contractorrsquos (MAC) self-help tools like the IVR internet portal on-line application status etc Provider Transactions Access Number

bull CCN- CMS Certification Number

bull Medicare Number- example 23-

bull All of the above mean the same thing

52

QTSO

bull Once you are logged in the QTSO site bull You will have a state login to the site to access the various site specific

to your facilitybull Installing you will need administrator rights to your network

53

Medicare UpdateWhat are we seeing

54

CMS Final Rule On Returning Credits

httpswwwfederalregistergovarticles201602122016-02789medicare-program-reporting-and-returning-of-overpayments

55

Over Payment Rule

bull Medicare payments for non covered services

bull Medicare payments in excess of the allowable amount for an identified covered service

bull Errors and non reimbursable expenditures in cost reportsbull Duplicate payment

bull Receipt of Medicare payments when another payor had the primary responsibility for payment

56

Questions to MAC

bull Does the Medicare credit balance report change with this overpayment rule

bull No Medicare Credit Balances are still required at the end of each quarter

bull Will that still be the communication to let CMS or the MAC know that we have received an overpayment

bull Submission of Medicare Credit Balance is one form of communicating overpayments to CMS Other methods include submitting a voluntary refund with required claim information or the submission of a standard overpayment form

57

Questions to MAC

bull Will the MAC still deduct from a future RAbull If the recovery of the overpayment includes adjusting a claim then

the overpayment would be netted against future claims payments and reflected on the RA

bull Or will that process change with this new rulebull Process will remain the samebull Will NGS send communication out on thisbull Yes NGS will communicate this once the final rule is communicated

to the MACs by CMS However this could change depending on final CMS instructions

58

Final Rule on Returning Credits

bull Providers will want to immediately update their current policies governing overpayments in order to comply with this new rule which will take effect on March 14 2016

bull Providers and suppliers are required to use reasonable diligence to investigate credible information regarding overpayments through both proactive compliance efforts and reactive investigations

bull If an overpayment is identified then it must be repaid within 60 days An overpayment is identified when a person has or should have through the exercise of reasonable diligence determined that the person received an overpayment and quantified the amount

bull Providers and suppliers have a maximum of 8 months to report and return overpayments ndash up to 6 months to investigate and quantify the overpayment (ie to identify it) and up to 60 days to report and return the overpayment

59

Final Rule on Returning Credits

bull Providers and suppliers are required to report and return all overpayments within a 6-year lookback period

bull The cause and amount of the overpayment is irrelevant for the determination eg it was due to a mistake it was someone elsersquos fault it is a minor amount An overpayment is an overpayment and must be returned

bull Providers and suppliers must make their own determination to which entity to report and return the overpayment ie to the Medicare contractor or using the OIG Self Disclosure Protocol or the CMS Self Referral Disclosure Protocol

60

Final Rule on Returning Credits

bull Providers and suppliers may use the claims adjustment credit balance self-reported refund process or another appropriate process to report and return overpayments At this time there is no standard refund form to use

bull Failure to report and return an overpayment could subject the provider or supplier to False Claims Act liability Civil Monetary Penalties Law liability and exclusion from federal health care programs

61

P S amp R-Accountants will be asking for this information

The location you login into has changed it is now on EIDM EIDM is the acronym for CMS Enterprise Identity Management system which includes Identity Verification Access Management Authorization Assistance Workflow Tools and Identity Lifecycle Management functions

httpswwwcmsgovResearch-Statistics-Data-and-SystemsCMS-Information-TechnologyIACSCMS-Applications-Loginhtml

Go down the page and click on the PSampRSTARThis will take you to the login pagewill look the same as the old P S amp R didChanges Affecting PSampR System Access (Please Read) (posted 01292015)(Updated 5262015)is changingThe system which controls your PSampR user ID (currently IACS)The new system is referred to as EIDMThis will result in a different way to create new accounts or change passwords to existing accountsIf you already have an account in EIDM you may have to use that account for accessing PSampR after the transitionWhen is the change effectiveJune 13 2015What is staying the sameThe internet address for accessing PSampR remains the sameThe PSampR systemfunctionality is NOT changing 62

Medicare Advantage Payorsbull Medicare Advantage payors are pullingdenying payments on admissions if the patient was readmitted within 30 days after discharge The

client believes that the payors systematically denying payments for all readmissions within 30 days They believe this practice denies them due process to address whether the readmissions were justified and not due to a premature discharge of patient The payors seem to want to act like a QIO without having the same accountabilities of the QIO related to determinations of non-payment

bull Heres the QIO process under section 4240 of the QIO Manualbull 4240 - Readmission Review - (Rev 2 07-11-03)bull Readmission review involves admissions to an acute general short-term hospital occurring less than 31 calendar days from the date of

discharge from the same or another acute general short-term hospital (see sect1154(a)(13) and 42 CFR 47671(a)(8)(ii)) Neither the day of discharge nor the day of admission is counted when determining whether a readmission has occurred

bull A Medical Review Proceduresbull Obtain the appropriate medical records for the initial admission and readmission Perform case review on both stays Analyze the cases

specifically to determine whether the patient was prematurely discharged from the first confinement thus causing readmission Perform an analysis of the stay at the first hospital to determine the cause(s) and extent of any problem(s) (eg incomplete or substandard treatment) Consider the information available to the attending physician who discharged the patient from the first confinement Do not base a determination of a premature discharge on information that the physician or provider could not have known or events that could not have been anticipated at the time of discharge

bull Review both the initial admission and the readmission at the same time unless one of them has previously been reviewed In these cases use at a minimum the PRAF case summary of the other admission in addition to the medical record of the case under review

bull C Denialsbull Deny readmissions under the following circumstancesbull If the readmission was medically unnecessarybull If the readmission resulted from a premature discharge from the same hospital orbull If the readmission was a result of circumvention of PPS by the same hospital (see sect4255)bull With the QIO process there is an appeal within the QIO here the hospital is getting no opportunity to challenge the denials

63

Medicare Provider Enrollment Feebull Provider Enrollment Application Fee Amount for CY 2016bull On December 3 CMS issued a notice Provider Enrollment Application

Fee Amount for CY 2016 [CMSndash6066ndashN] Effective January 1 2016 the CY 2016 application fee is $554 for institutional providers that are

bull Initially enrolling in the Medicare or Medicaid program or the Childrens Health Insurance Program (CHIP)

bull Revalidating their Medicare Medicaid or CHIP enrollmentbull Adding a new Medicare practice locationbull This fee is required with any enrollment application submitted from

January 1 through December 31 2016

64

Medicare MAC-Higlas

bull Effective 142016 CMS has implemented a change to begin netting (offsetting) provider money across workloads within a single organization What this means is that any related providers conducting business in two different workloads (example New York and Maine) will have their money applied to any account receivables (AR) with a remaining balance owed to Medicare within both workloads For example Provider ABC is located in New York and is scheduled to receive a payment of $1000 on todays remittance advice Provider XYZ is related to provider ABC but is located in Maine and has ARs with a balance owed of $200 Provider ABCs $1000 payment will have the $200 applied against provider XYZs ARs resulting in a net payment of $800 This will be reflected on the remittance advice by the same PLB code as seen today for offsets for the $200

65

Two Midnight RuleChange January 1 2016 httpswwwcmsgovMedicareMedicare-Fee-for-Service-PaymentHospitalOutpatientPPSHospital-Outpatient-Regulations-and-Notices-ItemsCMS-1633-FChtml

66

Two Midnight Rulebull However effective January 1 2016 CMS will allow exceptions to the

Two-Midnight Benchmark to be determined on a case-by-case basis by the physician responsible for the care of the beneficiary subject to medical review Said differently Part A payment may be appropriate in some circumstances even though there is no expectation by the physician (or qualified ordering practitioner) of a two-midnight stay and one of the two pre-existing categorical exceptions (CMS ldquoinpatient onlyrdquo list and newly initiated mechanical ventilation) does not apply CMS has indicated that this change to the Two Midnight Rule is in response to stakeholder concern and CMSrsquos continued efforts to develop the most appropriate standard for determining Medicare Part A payment

67

Two Midnight Rulebull A new 42 CFR sect4123(a) provides that a patient is considered an

inpatient of a hospitalhellipif formally admitted as an inpatient pursuant to an order for inpatient admission by a physician or other qualified practitionerhellip The physician orders inpatient status when he or she expects the patient to require a stay that crosses at least 2 midnights[10] Stays expected to be shorter than at least two midnights are generally inappropriate for inpatient admission and inpatient payment under Medicare Part A unless the surgical procedure is specified by Medicare as inpatient only under sect41922(n)[11] The physicians expectationhellipshould be based on such complex medical factors as patient history and comorbidities the severity of signs and symptoms current medical needs and the risk of an adverse event[12] The physician order is part of physician certification of the medical necessity of hospital inpatient serviceshellip[13]

68

InPatient Vs Observation Conthellip

bull Physician certification which begins with an order for inpatient admission requires the physician to certify the reasons for the hospitalization the estimated time the patient will remain in the hospital and plans for post-hospital care if appropriate[14] The certification must be completed signed and documented in the medical record prior to discharge[15]

bull A physicians admission order has no presumptive weight and both the admission order and the physician certification will be evaluated in the context of the evidence in the medical record[16] CMS intends to provide additional information about what evidence in the medical record means in future instructions and manual revisions[17]

69

Two Midnight Rulebull Although the new case-by-case exception appears to be inherently

subjective to a certain extent CMS states that the following factors (among others) would be relevant to determining whether a patient requires inpatient admission under the expanded policy

bull The severity of the signs and symptoms exhibited by the patient bull The medical predictability of something adverse happening to the patient

and bull The need for diagnostic studies that appropriately are outpatient services

(that is their performance does not ordinarily require the patient to remain at the hospital for 24 hours or more)

bull CMS also notes that an inpatient admission (and Part A payment) should be ldquorare and unusualrdquo for minor surgical procedures or other treatment that is expected to keep the patient in the hospital ldquofor only a few hoursrdquo or for a period of time that ldquodoes not span at least overnightrdquo (thus a subset of stays not meeting the Two Midnight Benchmark) CMS indicates that such cases will be prioritized for medical review

70

Health Data Insights amp Medicare Plus Blue

RAC (Retrospective Audits)

71

HDI Health Data amp Med Plus Blue

bull httpwwwhealthdatainsightscombull Blue Cross Medicare Advantage Auditsbull Facilities seeing 10 to 15 requests for Medical Recordsbull In January amp Feburarybull Selected Health Data Insights because they were a premier Audit

Vendor for CMS Recovery Audit Contractor (RAC) demonstration Project They are a audit vendor for Humana

bull Providers not sending Medical Record will get technical denial and lose payments

72

Health Data InSight

bull In 2010 they began the Hospital Reviewbull Medicare Advantage encounter datandashCMS oversight of data integrity OIG

2016bull We will review CMSs oversight of MA encounter data validation and assess

the extent to which CMSrsquos Integrated Data Repository contains timely valid and complete MA encounter data In 2012 CMS began collecting from MA organizations a more comprehensive set of encounter data reflecting the items and services provided to MA plan enrollees Prior CMS and OIG audits have indicated vulnerabilities in the accuracy of data reporting by MA organizations Realizing the potential benefits of the MA encounter data for payment and program integrity oversight is contingent upon the datarsquos completeness validity and timeliness (OEI 03-15-00060 expected issue date FY 2017)

73

Pepper Reports

bull httpswwwpepperresourcesorg

bull Program for Evaluating Payment Patterns Electronic Report ( PEPPER)

bull Annually on or about April 18 2016 will be released

bull Pepper Portal httpssecurefiletmforg

74

CGI Technologies and Solutions Inc httpracbcgicomContactInfoaspxst=1

bull Indiana bull Michiganbull Minnesotabull Illinoisbull Kentuckybull Ohiobull Wisconsin CGI Technologies and Solutions Incbull For general and administrative questions regarding client service outreach

quality assurance or project-specific issues contactbull 1877316RACB (7222)bull Email racbcgicom Tamara Tate Tamaratatecmshhsgovbull 4107861288

75

CGI Federal RAC

bull CGI Federal RAC Region Bbull Email racbcgicombull Phone 1-877-316-RACB (7222)bull Mailing Addressbull Send medical records as followsbull Medical records for Indiana Illinois Kentucky Michigan Ohio Wisconsin

Minnesota DME and Home Health CGI Federal Inc Attn RACB Imaging Dept 1001 Lakeside Ave Suite 800 Cleveland OH 44114

bull If submitting paper records please send medical records as follows For Therapy Reviews CGI Federal Inc Attn RACB Imaging 1001 Lakeside Avenue Suite 800 Cleveland OH 44114

76

How to survive RAC Audit

bull National health expenditures totaled $1679 Billion in 2003 bull National health expenditures were 153 of GROSS Domestic Product

(GDP) in 2003 bull Health care cost increasing at +9 per year bull Doomsday predictions of Medicare running out bull Congressional Action

77

RAC Audits

bull Medicare Modernization Act (MMA) of 2003Mandated a three year audit demonstration project 2005-2008

bull Appoint audit contractors to review Medicare billings for proper coding DRG assignment and medical necessity

bull Audits will apply to all health care providers (hospitals physicians homecare dme etc)

bull Audit contractors to be paid on a contingency basis a percentage of overpayments recovered

78

How Did we get here

bull Overpayments collected due to errors in Medically Unnecessary Services ndash 40

bull Incorrectly Coded ndash 35

bull Other ndash 17

bull NoInsufficient Documentation ndash 8

79

Where are we now

bull All RACrsquos completed required provider outreachAccess to Medicare billing data base given to all RAC RAC review methodology

bull Automated Review-Black amp White Issues (current) bull DRG Validation-complex review (current) bull Complex Review for coding errors (current) bull DME Medical Necessity Reviews ndashcomplex review (calendar year

2010) bull Medical Necessity Reviews-complex review (calendar year 2010)

80

RAC Reviews

bull Responsibilities of the Team Leader bull Must learn each insurance provider participating in a RAC or RAC type

program bull What are their operating rulesbull What is their appeal process Time limits

May be different process for each insurance provider bull Develop a response team

Identify who does what when why and alternate bull individual

Build and develop a manual process Review of computerized system

81

Priority Health SCIO Health Analytics

bull httpswwwsciohealthanalyticscomcore-capabilitiespayment-integrityfacility-auditsskilled-nursing-facility-audits

bull Claims for Medicare members treated at Skilled Nursing Facilities are reimbursed based on the patientsrsquo RUG (Resource Utilization Group) score which is determined using the Minimum Data Set (MDS) Using SCIOs robust analytics claims andor providers that merit review are selected for audit SCIOs auditors conduct a detailed review of the complete medical record and associated MDS to determine if the billed RUG score is valid In the event the review determines that an incorrect RUG score was billed SCIOreg provides the valid score reports the reason the change was necessary and calculates the resulting overpayment

82

+ Cheer

Onward and Upward she shall prevail We are here to care for the residents and provide a wonderful

service

13 83

84

References

bull Priority Healthbull Blue Crossbull Medicaidbull Medicare

85

  • Medicare Mange Care amp Medicaid Changes in the New World We Live In
  • Medicaid
  • NEW Medicaid Change MIlogin
  • Blueprint for Health Innovation MI
  • Provider Enrollment Electronic Signature Form Submission Process MSA 15-54
  • Provider Enrollment Electronic Signature Form Submission Process
  • Provider Enrollment Domain Administrator
  • Medicaid Coinsurance Medicare Advantage
  • Slide Number 9
  • Lawsuit DHS Changes on Caregivers
  • TPL Medicaid Change
  • CHAMPS Member Screen
  • LOC dropping off Not Due to MI Health
  • Issues
  • Secure Email Information
  • Medicaid amp Hospice
  • Medicaid
  • Medicaid Medicare Buy In
  • Manage Medicaid
  • Healthy Michigan Residents
  • Healthy Michigan Medicaid Days
  • McLaren Health Plan
  • Manage Medicaid Plans January 1
  • Slide Number 24
  • MI Health Link
  • MI Health Link 2565
  • What are the Names
  • MI Health Dual Eligible
  • MI Health LOC
  • LOC Medicaid
  • Medicaid Redetermination and MHL Enrollment
  • MI Health Link Portals
  • MI Health Authorizations
  • MI Health Issues
  • LOC 02 dropping MI Health Issues
  • PPA Offset
  • LOCD
  • MI Health Issues-New
  • ACO
  • Families Receiving Letters for ACO
  • ACO What is It
  • Payroll Based Journal
  • Slide Number 43
  • If you submit data manually should you also submit it through the XML
  • Staffing Submission Frequently Asked Questions
  • CMS defines
  • Slide Number 47
  • PBJ Medical Director Role
  • PBJ Medical Director Role
  • Dietician
  • Pharmacy Consultant
  • What are the names for the Medicare Number
  • QTSO
  • Medicare Update
  • CMS Final Rule On Returning Credits
  • Over Payment Rule
  • Questions to MAC
  • Questions to MAC
  • Final Rule on Returning Credits
  • Final Rule on Returning Credits
  • Final Rule on Returning Credits
  • Slide Number 62
  • Medicare Advantage Payors
  • Medicare Provider Enrollment Fee
  • Medicare MAC-Higlas
  • Two Midnight Rule
  • Two Midnight Rule
  • Two Midnight Rule
  • InPatient Vs Observation Conthellip
  • Two Midnight Rule
  • Health Data Insights amp Medicare Plus Blue
  • HDI Health Data amp Med Plus Blue
  • Health Data InSight
  • Pepper Reports
  • CGI Technologies and Solutions Inc httpracbcgicomContactInfoaspxst=1
  • CGI Federal RAC
  • How to survive RAC Audit
  • RAC Audits
  • How Did we get here
  • Where are we now
  • RAC Reviews
  • Priority Health SCIO Health Analytics
  • Cheer
  • References
Page 15: Medicare, Mange Care & Medicaid Changes in the New World we live in

Secure Email Information

bull The State of Michigan asked me to remind you when you are communicating with them regarding residents to not send Resident names Birthdates or Social security numbers in those emails What you send is the Medicaid ID and they can look it up Or if it is a billing issue send them the TCN and the Medicaid ID We have been in the practice of emailing DHS Ardene Martin Integrated Health and Provider Support with all the resident name and such

15

Medicaid amp Hospicebull LOC 07 Manage Medicaid Hospice included so plan would pay

provider and not switch to a LOC 16

bull LOC 02 Medicaid (Regular Medicaid) Hospice not included so switch to 16 Hospice and Hospice pays provider

bull LOC 11 Healthy Michigan is included in plan so plan would pay provider and not switch to LOC 16

bull LOC 005 amp 015 MI Health is up in the air waiting for CMS Currently Hospice is now included

bull LOC 16 is Hospice when they switch from Regular Medicaid only and Hospice pays provider

16

Medicaidbull Going forward please make sure that your Champs ID amp NPI on your member screen matches your facility CHAMPS ID

amp NPI for each resident and matches for all new admissions or new approved Medicaid going forward

bull The edit will be turned on soon to stop the payment of these claims if the CHAMPS ID and NPI do not Match your facility on the Medicaid member screen

bull Make sure you are putting the information correct on the 2565 you send in to DHS

bull 1 I attached a 2565 When you fill this out for new people make sure in box 12 a you put your NPI and 12 b you put your CHAMPS ID This will help the DHS case workers assign the person to your facility

bull 2 I would check all your residents CHAMPS member screens and make sure the NPI and CHAMPS ID are your facilities If not you will have to work with the DHS worker to fix this The DHS worker is the only one that can fix this

bull 3 We are having some issues where the DHS case workers will not change this NPI and CHAMPS ID to your facilities You have to get them to change it or you just will not get paid

bull 4 We situations where the resident is in a facility in Kent County (as an example) but the family lives in Livingston County and completes the applications in Livingston County You will have to get the DHS worker in Livingston to fix it not the local DHS worker in Kent County where your facility is

17

Medicaid Medicare Buy Inbull Based on the information from the Office of Personnel Management Federal

Employeersquos employed as of January 1 1983 are eligible for Medicare Part A(see page 5 of attached document) This was also confirmed with our Social Security liaison If the beneficiary did not retire before 1983 he can enroll in Medicare Part B and pay the premium and then he can enroll in Medicare Part A and pay that premium as well or may qualify for Medicare Buy in of Part A

bull If a beneficiary has an SSA document stating they are not eligible for Medicare as they do not have enough work credits the beneficiarybeneficiary representative needs to go to SSA and let them know that while they know they are not eligible for Medicare Part A free or reduced however they are eligible for Medicare Part B and would like to enroll Once the beneficiary enrolls in Medicare Part B (enrollment period January 1st ndash March 31 each year) and pays the premium then the beneficiary is eligible to either pay for Medicare Part A or that beneficiary may qualify for Medicare Part A buy in through Medicaid Once the beneficiary is enrolled in Medicare Part A and Medicare Part B Medicaid will begin to make payments on claims

18

Manage Medicaid Where are we

19

Healthy Michigan Residents

20

Healthy Michigan Medicaid Days

21

McLaren Health Plan

22

Manage Medicaid Plans January 1bull Region 1 ndash Upper Peninsula Health Planbull Region 2 ndash McLaren Health Plan Meridian Health Plan of Michigan Molina Healthcare of Michigan

UnitedHealthcare Community Planbull Region 3 ndash McLaren Health Plan Meridian Health Plan of Michigan Molina Healthcare of Michigan

UnitedHealthcare Community Planbull Region 4 ndash Blue Cross Complete of Michigan McLaren Health Plan Meridian Health Plan of Michigan Molina

Healthcare of Michigan Priority Health Choice UnitedHealthcare Community Planbull Region 5 ndash McLaren Health Plan Meridian Health Plan of Michigan Molina Healthcare of Michigan

UnitedHealthcare Community Planbull Region 6 ndash Blue Cross Complete of Michigan HAP Midwest Health Plan McLaren Health Plan Meridian Health

Plan of Michigan Molina Healthcare of Michigan UnitedHealthcare Community Planbull Region 7 ndash Blue Cross Complete of Michigan McLaren Health Plan Meridian Health Plan UnitedHealthcare

Community Planbull Region 8 ndash Aetna Better Health of Michigan McLaren Health Plan Meridian Health Plan of Michigan Molina

Healthcare of Michigan Priority Health Choice UnitedHealthcare Community Planbull Region 9 ndash Aetna Better Health of Michigan Blue Cross Complete of Michigan McLaren Health Plan Meridian

Health Plan of Michigan Molina Healthcare of Michigan UnitedHealthcare Community Planbull Region 10 ndash Aetna Better Health of Michigan Blue Cross Complete of Michigan Harbor Health Plan McLaren

Health Plan Meridian Health Plan of Michigan Molina Healthcare of Michigan Total Health Care UnitedHealthcare Community Plan 23

24

MI Health LinkWhere are we

25

MI Health Link 2565

bull This notification is being sent to providers of long term care services including nursing facilities county medical care facilities and hospital long term care units to provide clarification on the process involved with the submission of the Facility Admission Form (MSA-2565-C) for an individual enrolled in the MI Health Link program

bull The MI Health Link program covers the custodiallong term nursing facility service benefit When an individual who is enrolled in the MI Health Link program is admitted to a nursing facility for custodiallong term nursing services a disenrollment from the Integrated Care Organization (MI Health Link health plan) is NOT REQUIRED The Facility Admission Form (MSA-2565-C) should NOT be sent to the Michigan Department of Health and Human Services (MDHHS) Enrollment Services Section for a disenrollment to be processed

26

What are the Names

bull Started as Integrated Health

bull Then called MMP (Medicare Medicaid Program)

bull Duals (Also Known as Duals as in Dual Eligible)

bull Now called MI Health Link

bull Total confusion

27

MI Health Dual Eligible28

MI Health LOC

29

LOC Medicaidbull We have the new pilot program which started on March

1 2015 in Southwest Michigan Region 4 Counties Macomb Wayne and the UP You could see these patients they are dual eligible in the Pilot program in counties surrounding the pilot

bull MHL-LOC 005 (All other Facilities) or LOC 015 (County Care) These residents have to call Michigan Enrolls to dis-enroll toll-free at 1-800-975-7630 (TTY 1-888-263-5897) Monday-Friday from 8 AM to 7 PM Once they dis-enroll they will go to a LOC 02 you have to do a new LOCD

30

Medicaid Redetermination and MHL Enrollmentbull At the time of re-determination for Medicaid financial eligibility the MI

Health Link (MHL) program will not be sending beneficiaries information about this program Beneficiaries who previously opted out will not be passively enrolled according to an email from the MHL staff The MHL staff wrote

bull ldquoThere is currently no MI Health Link enrollment letter sent to beneficiaries when eligibility is re-determined A person who becomes eligible for MI Health Link enrollment may opt-in at any time

bull When Medicaid re-determination takes place the beneficiary remains in the same ICO unless that beneficiary lost Medicaid coverage If the enrollee loses Medicaid coverage and later regains it they are not passively enrolled into MI Health Link The beneficiary may choose to opt back in to the program at that time if desiredrdquo

bull MHL staff did state that about 1500 beneficiaries will be passively enrolled effective January 1 2016 These specific individuals were given normal notice of 60 and 30 days in which to opt-in or opt-out if they so chose No other large scale passive enrollment is scheduled according to the MHL staff 31

MI Health Link Portals

bull Meridian Health Planbull httpwwwmhplancommibull Amerihealthbull httpwwwamerihealthcaritasvipcarepluscomproviderself-service-

toolsindexaspxbull AetnaCoventrybull httpwwwaetnabetterhealthcomMichiganprovidersportalbull Molinabull httpwwwmolinahealthcarecommembersmien-usmemPageshomeaspxbull HAPMidwestbull httpswwwmidwesthealthplancomLoginaspxbull FidelisCentenebull wwwfidelissccommmp 32

MI Health Authorizationsbull We need to watch these authorization that the plans are giving us for the MI

Health program Some plans are assigning a diagnosis for residents in their prior authorizations They are assigning diagnosis that the residents do not even have You need to make sure these are correct diagnosis and if not you need to work with the case managers of the plans to fix the issue The authorization numbers do change

bull Make sure that any resident that is in a MI Health plan that you have a prior authorization All plans are giving different periods authorizing the residents stay in the facility You need to set up a system to make sure you always have a authorization for the period of time you are rendering the service Here is an example of time frame of authorizations

bull Meridian is authorizing 12 monthsbull Aetna is authorizing 3 monthsbull Molina is authorizing 6 monthsbull The authorization numbers need to go on your claims to the payer You need to

put the authorizations in your software and track the dates

33

MI Health Issuesbull We are seeing some issues with MI Health where the resident does not have the correct LOC or it shows

up correct on CHAMPS but ancillary providers such as Dentist and such cannot see it I think we still have some issues with the information crossing between Bridges DHS system CMS and CHAMPS It in return is creating some access of care issues If it is a true LOC issues Facilities with LOC issues need to submit the Medicaid ID numbers to the MSA-MHL-EnrollmentMichigangov box with the subject line Nursing home LOC Issue so they may work to resolve the issues

bull If it becomes an access to care issue email the information to INTEGRATEDCAREmichigangov Remember in these emails only send the Medicaid ID and explain the situation The State will work with the plans to try to fix the process or improve the process

bull We are also seeing with new admission with LOC 015 or 005 that the plans are stating they have 14 days to authorize admission These are resident in the emergency room and possibly be admitted to you for Rehab The hospital will not keep the resident in ER for 14 days and you cannot admit the resident until you have a prior authorization I would recommend when you are told this by the plan that you need to ask to speak to a manager We will have to work through this

bull Ancillary Provider You need to work with your ancillary providers such as Lab Pharmacy X-Ray Physician and such to get the to be credentialed with the plans We are hearing that some of the pharmacies are not participating with the plans this will create issues for you so I would continue to ask these groups to participate

34

LOC 02 dropping MI Health Issuesbull The passive enrollments have occurred in Macomb amp Wayne for

Medicaid dual eligible We are having the same issue we did as in the Southwest MI amp UP with the passive enrollments I am starting to hear from facilities who are checking there CHAMPS member screens that those residents that have opted out (some residents not all) have lost there 02 Make sure you are checking your CHAMPS member screen both for those that were passively enrolled and those that might have lost there 02 Medicaid that opted out

bull Facilities with LOC issues need to submit the Medicaid ID numbers to the (Only MI Health)MSA-MHL-Enrollmentmichigangov box with the subject line Nursing home LOC Issue so they may work to resolve the issues

35

PPA Offset

bull There are no co-pays deductibles or premiums in MI Health Link so there should be no need to offset the PPA with code 25 MI Health Link enrollees can continue to offset their PPA for non-program covered medical expenses (like Vision-Code 27 Dental-Code 28 and Hearing-Code 26) and use the appropriate codes to offset the PPA when billing the health plan for nursing facility services

bull Resident pay PPA when MedicareMedicaid coinsurance

36

LOCDbull Nursing Facility Level of Care Determination (NFLOCD)

bull The MI Health Link health plan will be responsible for conducting the Michigan Medicaid NFLOCD tool for enrollees seeking admission to a nursing facility For existing residents at the time of enrollment the existing NFLOCD will be adopted for capitation payment purposes The health plan will complete a new NFLCOD tool within the first 90 days of enrollment If a nursing facility resident is disenrolled from MI Health Link the nursing facility will be responsible for conducting a new NFLOCD tool in accordance with published Medicaid policy

37

MI Health Issues-New

bull INTEGRATEDCAREmichigangov

bull Email with Insurance Plan issues Case Manager Issues

38

ACOWhat are they

39

Families Receiving Letters for ACO

40

ACO What is It

bull Whats an ACObull Accountable Care Organizations (ACOs) are groups of doctors hospitals

and other health care providers who come together voluntarily to give coordinated high quality care to their Medicare patients

bull The goal of coordinated care is to ensure that patients especially the chronically ill get the right care at the right time while avoiding

unnecessary duplication of services and preventing medical errorsbull When an ACO succeeds both in delivering high-quality care and

spending health care dollars more wisely it will share in the savings it achieves for the Medicare program

41

Payroll Based JournalMandatory on July 1 2016Internet Explorer Version

Internet Explorer v 10 and v 11 will need to operate in compatibility mode

42

43

If you submit data manually should you also submit it through the XML

bull Now you have three options

bull Submit Manually only

bull Submit through the XML only

bull You are able to submit manually and using the XML

44

45

Staffing Submission Frequently Asked Questions

bull ldquoWho are direct care staffrdquo (Who do we submit data for)bull Submission of data for contract staffbull Medical directors and consultantsbull Staff switching roles or tasks throughout the daybull Hours paid vs hours worked ndash Must be verifiablebull Public postingQuality MeasuresFive Starbull Enforcementbull Voluntary submission risks (noneSo register now)

CMS defines

bull 37 job title codes that are required to match employees to the number of hours each direct care function was performed It is important to work with your teams to define the workers that contribute to each job type and how those daily worked hours are recorded and converted to a PBJ submission

bull The PBJ does include some more specific job descriptions than the 671 For example the PBJ system includes job descriptions for RNs with administrative duties and LPNs with administrative duties versus the 671rsquos more general ldquoNurses with Administrative Duties

Page 46

47

PBJ Medical Director Rolebull Physician Leadership

bull Help the facility ensure that patients have appropriate physician coverage and ensure the provision of physician and health care practitioner services and

bull Help the facility develop a process for reviewing physician and health care practitioner credentials

bull Provide specific guidance for physician performance expectations

bull Help the facility ensure that a system is in place for monitoring the performance of health care practitioners and

bull Facilitate feedback to physicians and other health care practitioners on performance and practices

bull Patient Care - Clinical Leadership

bull Participate in administrative decision-making and the development of policies and procedures related to patient care

bull Help develop approve and implement specific clinical practices for the facility to incorporate into its care-related policies and procedures including areas required by laws and regulations

bull Develop procedures and guidance for facility staff regarding contacting practitioners including information gathering and presentation change in condition assessment and when to contact the medical director

bull Review consider andor act upon consultant recommendations as appropriate that affect the facilitys resident care policies and procedures or the care of an individual resident

bull Review respond to and participate in federal state local and other external surveys and inspections and

bull Help review policies and procedures regarding the adequate protection of patients rights advance care planning and other ethical issues48

PBJ Medical Director Rolebull Quality of Care

bull Help the facility establish systems and methods for reviewing the quality and appropriateness of clinical care and other health-related services and provide appropriate feedback and

bull Participate in the facilitys quality improvement process

bull Advise on infection control issues and approve specific infection control policies to be incorporated into facility policies and procedures

bull Help the facility provide a safe and caring environment

bull Help promote employee health and safety and

bull Assist in the development and implementation of employee health policies and programs

bull Education Information and Communication

bull Promote a learning culture within the facility by educating informing and communicating

bull Provide information to help the facility provide care consistent with current standards of practice (defined as approaches to care procedures techniques and treatments that are based on research and or expert consensus and that are contained in current manuals textbooks and or publications or that are accepted adopted or promulgated by recognized organizations or national bodies)

bull Help the facility develop medical information and communication systems with staff patients and families and others

bull Represent the facility to the professional and lay community on medical and patient care issues

bull Maintain knowledge of the changing social regulatory political and economic factors that affect medical and health services of long term care patients and

bull Help establish appropriate relationships with other health care organizations

49

Dietician

bull When the dietary or food services supervisor is other than a registered dietitian the supervisor shall receive routine consultation and technical assistance from a registered dietitian (RD) Consultation time shall not be less than 4 hours every 60 days Additional consultation time may be needed based on the total number of patients incidence of nutrition-related health problems and food service management needs of the facility

50

Pharmacy Consultant

bull At least once per month a licensed pharmacist must perform a drug regimen review (DRR) for each resident The pharmacist must report any irregularities to the attending physician or director of nursing Furthermore these reports must be acted upon

51

What are the names for the Medicare Numberbull OSCAR -Online Survey Certification and Reporting

bull PTAN-PTAN number is assigned by Medicare to authenticate the provider when using the local Medicare Administrative Contractorrsquos (MAC) self-help tools like the IVR internet portal on-line application status etc Provider Transactions Access Number

bull CCN- CMS Certification Number

bull Medicare Number- example 23-

bull All of the above mean the same thing

52

QTSO

bull Once you are logged in the QTSO site bull You will have a state login to the site to access the various site specific

to your facilitybull Installing you will need administrator rights to your network

53

Medicare UpdateWhat are we seeing

54

CMS Final Rule On Returning Credits

httpswwwfederalregistergovarticles201602122016-02789medicare-program-reporting-and-returning-of-overpayments

55

Over Payment Rule

bull Medicare payments for non covered services

bull Medicare payments in excess of the allowable amount for an identified covered service

bull Errors and non reimbursable expenditures in cost reportsbull Duplicate payment

bull Receipt of Medicare payments when another payor had the primary responsibility for payment

56

Questions to MAC

bull Does the Medicare credit balance report change with this overpayment rule

bull No Medicare Credit Balances are still required at the end of each quarter

bull Will that still be the communication to let CMS or the MAC know that we have received an overpayment

bull Submission of Medicare Credit Balance is one form of communicating overpayments to CMS Other methods include submitting a voluntary refund with required claim information or the submission of a standard overpayment form

57

Questions to MAC

bull Will the MAC still deduct from a future RAbull If the recovery of the overpayment includes adjusting a claim then

the overpayment would be netted against future claims payments and reflected on the RA

bull Or will that process change with this new rulebull Process will remain the samebull Will NGS send communication out on thisbull Yes NGS will communicate this once the final rule is communicated

to the MACs by CMS However this could change depending on final CMS instructions

58

Final Rule on Returning Credits

bull Providers will want to immediately update their current policies governing overpayments in order to comply with this new rule which will take effect on March 14 2016

bull Providers and suppliers are required to use reasonable diligence to investigate credible information regarding overpayments through both proactive compliance efforts and reactive investigations

bull If an overpayment is identified then it must be repaid within 60 days An overpayment is identified when a person has or should have through the exercise of reasonable diligence determined that the person received an overpayment and quantified the amount

bull Providers and suppliers have a maximum of 8 months to report and return overpayments ndash up to 6 months to investigate and quantify the overpayment (ie to identify it) and up to 60 days to report and return the overpayment

59

Final Rule on Returning Credits

bull Providers and suppliers are required to report and return all overpayments within a 6-year lookback period

bull The cause and amount of the overpayment is irrelevant for the determination eg it was due to a mistake it was someone elsersquos fault it is a minor amount An overpayment is an overpayment and must be returned

bull Providers and suppliers must make their own determination to which entity to report and return the overpayment ie to the Medicare contractor or using the OIG Self Disclosure Protocol or the CMS Self Referral Disclosure Protocol

60

Final Rule on Returning Credits

bull Providers and suppliers may use the claims adjustment credit balance self-reported refund process or another appropriate process to report and return overpayments At this time there is no standard refund form to use

bull Failure to report and return an overpayment could subject the provider or supplier to False Claims Act liability Civil Monetary Penalties Law liability and exclusion from federal health care programs

61

P S amp R-Accountants will be asking for this information

The location you login into has changed it is now on EIDM EIDM is the acronym for CMS Enterprise Identity Management system which includes Identity Verification Access Management Authorization Assistance Workflow Tools and Identity Lifecycle Management functions

httpswwwcmsgovResearch-Statistics-Data-and-SystemsCMS-Information-TechnologyIACSCMS-Applications-Loginhtml

Go down the page and click on the PSampRSTARThis will take you to the login pagewill look the same as the old P S amp R didChanges Affecting PSampR System Access (Please Read) (posted 01292015)(Updated 5262015)is changingThe system which controls your PSampR user ID (currently IACS)The new system is referred to as EIDMThis will result in a different way to create new accounts or change passwords to existing accountsIf you already have an account in EIDM you may have to use that account for accessing PSampR after the transitionWhen is the change effectiveJune 13 2015What is staying the sameThe internet address for accessing PSampR remains the sameThe PSampR systemfunctionality is NOT changing 62

Medicare Advantage Payorsbull Medicare Advantage payors are pullingdenying payments on admissions if the patient was readmitted within 30 days after discharge The

client believes that the payors systematically denying payments for all readmissions within 30 days They believe this practice denies them due process to address whether the readmissions were justified and not due to a premature discharge of patient The payors seem to want to act like a QIO without having the same accountabilities of the QIO related to determinations of non-payment

bull Heres the QIO process under section 4240 of the QIO Manualbull 4240 - Readmission Review - (Rev 2 07-11-03)bull Readmission review involves admissions to an acute general short-term hospital occurring less than 31 calendar days from the date of

discharge from the same or another acute general short-term hospital (see sect1154(a)(13) and 42 CFR 47671(a)(8)(ii)) Neither the day of discharge nor the day of admission is counted when determining whether a readmission has occurred

bull A Medical Review Proceduresbull Obtain the appropriate medical records for the initial admission and readmission Perform case review on both stays Analyze the cases

specifically to determine whether the patient was prematurely discharged from the first confinement thus causing readmission Perform an analysis of the stay at the first hospital to determine the cause(s) and extent of any problem(s) (eg incomplete or substandard treatment) Consider the information available to the attending physician who discharged the patient from the first confinement Do not base a determination of a premature discharge on information that the physician or provider could not have known or events that could not have been anticipated at the time of discharge

bull Review both the initial admission and the readmission at the same time unless one of them has previously been reviewed In these cases use at a minimum the PRAF case summary of the other admission in addition to the medical record of the case under review

bull C Denialsbull Deny readmissions under the following circumstancesbull If the readmission was medically unnecessarybull If the readmission resulted from a premature discharge from the same hospital orbull If the readmission was a result of circumvention of PPS by the same hospital (see sect4255)bull With the QIO process there is an appeal within the QIO here the hospital is getting no opportunity to challenge the denials

63

Medicare Provider Enrollment Feebull Provider Enrollment Application Fee Amount for CY 2016bull On December 3 CMS issued a notice Provider Enrollment Application

Fee Amount for CY 2016 [CMSndash6066ndashN] Effective January 1 2016 the CY 2016 application fee is $554 for institutional providers that are

bull Initially enrolling in the Medicare or Medicaid program or the Childrens Health Insurance Program (CHIP)

bull Revalidating their Medicare Medicaid or CHIP enrollmentbull Adding a new Medicare practice locationbull This fee is required with any enrollment application submitted from

January 1 through December 31 2016

64

Medicare MAC-Higlas

bull Effective 142016 CMS has implemented a change to begin netting (offsetting) provider money across workloads within a single organization What this means is that any related providers conducting business in two different workloads (example New York and Maine) will have their money applied to any account receivables (AR) with a remaining balance owed to Medicare within both workloads For example Provider ABC is located in New York and is scheduled to receive a payment of $1000 on todays remittance advice Provider XYZ is related to provider ABC but is located in Maine and has ARs with a balance owed of $200 Provider ABCs $1000 payment will have the $200 applied against provider XYZs ARs resulting in a net payment of $800 This will be reflected on the remittance advice by the same PLB code as seen today for offsets for the $200

65

Two Midnight RuleChange January 1 2016 httpswwwcmsgovMedicareMedicare-Fee-for-Service-PaymentHospitalOutpatientPPSHospital-Outpatient-Regulations-and-Notices-ItemsCMS-1633-FChtml

66

Two Midnight Rulebull However effective January 1 2016 CMS will allow exceptions to the

Two-Midnight Benchmark to be determined on a case-by-case basis by the physician responsible for the care of the beneficiary subject to medical review Said differently Part A payment may be appropriate in some circumstances even though there is no expectation by the physician (or qualified ordering practitioner) of a two-midnight stay and one of the two pre-existing categorical exceptions (CMS ldquoinpatient onlyrdquo list and newly initiated mechanical ventilation) does not apply CMS has indicated that this change to the Two Midnight Rule is in response to stakeholder concern and CMSrsquos continued efforts to develop the most appropriate standard for determining Medicare Part A payment

67

Two Midnight Rulebull A new 42 CFR sect4123(a) provides that a patient is considered an

inpatient of a hospitalhellipif formally admitted as an inpatient pursuant to an order for inpatient admission by a physician or other qualified practitionerhellip The physician orders inpatient status when he or she expects the patient to require a stay that crosses at least 2 midnights[10] Stays expected to be shorter than at least two midnights are generally inappropriate for inpatient admission and inpatient payment under Medicare Part A unless the surgical procedure is specified by Medicare as inpatient only under sect41922(n)[11] The physicians expectationhellipshould be based on such complex medical factors as patient history and comorbidities the severity of signs and symptoms current medical needs and the risk of an adverse event[12] The physician order is part of physician certification of the medical necessity of hospital inpatient serviceshellip[13]

68

InPatient Vs Observation Conthellip

bull Physician certification which begins with an order for inpatient admission requires the physician to certify the reasons for the hospitalization the estimated time the patient will remain in the hospital and plans for post-hospital care if appropriate[14] The certification must be completed signed and documented in the medical record prior to discharge[15]

bull A physicians admission order has no presumptive weight and both the admission order and the physician certification will be evaluated in the context of the evidence in the medical record[16] CMS intends to provide additional information about what evidence in the medical record means in future instructions and manual revisions[17]

69

Two Midnight Rulebull Although the new case-by-case exception appears to be inherently

subjective to a certain extent CMS states that the following factors (among others) would be relevant to determining whether a patient requires inpatient admission under the expanded policy

bull The severity of the signs and symptoms exhibited by the patient bull The medical predictability of something adverse happening to the patient

and bull The need for diagnostic studies that appropriately are outpatient services

(that is their performance does not ordinarily require the patient to remain at the hospital for 24 hours or more)

bull CMS also notes that an inpatient admission (and Part A payment) should be ldquorare and unusualrdquo for minor surgical procedures or other treatment that is expected to keep the patient in the hospital ldquofor only a few hoursrdquo or for a period of time that ldquodoes not span at least overnightrdquo (thus a subset of stays not meeting the Two Midnight Benchmark) CMS indicates that such cases will be prioritized for medical review

70

Health Data Insights amp Medicare Plus Blue

RAC (Retrospective Audits)

71

HDI Health Data amp Med Plus Blue

bull httpwwwhealthdatainsightscombull Blue Cross Medicare Advantage Auditsbull Facilities seeing 10 to 15 requests for Medical Recordsbull In January amp Feburarybull Selected Health Data Insights because they were a premier Audit

Vendor for CMS Recovery Audit Contractor (RAC) demonstration Project They are a audit vendor for Humana

bull Providers not sending Medical Record will get technical denial and lose payments

72

Health Data InSight

bull In 2010 they began the Hospital Reviewbull Medicare Advantage encounter datandashCMS oversight of data integrity OIG

2016bull We will review CMSs oversight of MA encounter data validation and assess

the extent to which CMSrsquos Integrated Data Repository contains timely valid and complete MA encounter data In 2012 CMS began collecting from MA organizations a more comprehensive set of encounter data reflecting the items and services provided to MA plan enrollees Prior CMS and OIG audits have indicated vulnerabilities in the accuracy of data reporting by MA organizations Realizing the potential benefits of the MA encounter data for payment and program integrity oversight is contingent upon the datarsquos completeness validity and timeliness (OEI 03-15-00060 expected issue date FY 2017)

73

Pepper Reports

bull httpswwwpepperresourcesorg

bull Program for Evaluating Payment Patterns Electronic Report ( PEPPER)

bull Annually on or about April 18 2016 will be released

bull Pepper Portal httpssecurefiletmforg

74

CGI Technologies and Solutions Inc httpracbcgicomContactInfoaspxst=1

bull Indiana bull Michiganbull Minnesotabull Illinoisbull Kentuckybull Ohiobull Wisconsin CGI Technologies and Solutions Incbull For general and administrative questions regarding client service outreach

quality assurance or project-specific issues contactbull 1877316RACB (7222)bull Email racbcgicom Tamara Tate Tamaratatecmshhsgovbull 4107861288

75

CGI Federal RAC

bull CGI Federal RAC Region Bbull Email racbcgicombull Phone 1-877-316-RACB (7222)bull Mailing Addressbull Send medical records as followsbull Medical records for Indiana Illinois Kentucky Michigan Ohio Wisconsin

Minnesota DME and Home Health CGI Federal Inc Attn RACB Imaging Dept 1001 Lakeside Ave Suite 800 Cleveland OH 44114

bull If submitting paper records please send medical records as follows For Therapy Reviews CGI Federal Inc Attn RACB Imaging 1001 Lakeside Avenue Suite 800 Cleveland OH 44114

76

How to survive RAC Audit

bull National health expenditures totaled $1679 Billion in 2003 bull National health expenditures were 153 of GROSS Domestic Product

(GDP) in 2003 bull Health care cost increasing at +9 per year bull Doomsday predictions of Medicare running out bull Congressional Action

77

RAC Audits

bull Medicare Modernization Act (MMA) of 2003Mandated a three year audit demonstration project 2005-2008

bull Appoint audit contractors to review Medicare billings for proper coding DRG assignment and medical necessity

bull Audits will apply to all health care providers (hospitals physicians homecare dme etc)

bull Audit contractors to be paid on a contingency basis a percentage of overpayments recovered

78

How Did we get here

bull Overpayments collected due to errors in Medically Unnecessary Services ndash 40

bull Incorrectly Coded ndash 35

bull Other ndash 17

bull NoInsufficient Documentation ndash 8

79

Where are we now

bull All RACrsquos completed required provider outreachAccess to Medicare billing data base given to all RAC RAC review methodology

bull Automated Review-Black amp White Issues (current) bull DRG Validation-complex review (current) bull Complex Review for coding errors (current) bull DME Medical Necessity Reviews ndashcomplex review (calendar year

2010) bull Medical Necessity Reviews-complex review (calendar year 2010)

80

RAC Reviews

bull Responsibilities of the Team Leader bull Must learn each insurance provider participating in a RAC or RAC type

program bull What are their operating rulesbull What is their appeal process Time limits

May be different process for each insurance provider bull Develop a response team

Identify who does what when why and alternate bull individual

Build and develop a manual process Review of computerized system

81

Priority Health SCIO Health Analytics

bull httpswwwsciohealthanalyticscomcore-capabilitiespayment-integrityfacility-auditsskilled-nursing-facility-audits

bull Claims for Medicare members treated at Skilled Nursing Facilities are reimbursed based on the patientsrsquo RUG (Resource Utilization Group) score which is determined using the Minimum Data Set (MDS) Using SCIOs robust analytics claims andor providers that merit review are selected for audit SCIOs auditors conduct a detailed review of the complete medical record and associated MDS to determine if the billed RUG score is valid In the event the review determines that an incorrect RUG score was billed SCIOreg provides the valid score reports the reason the change was necessary and calculates the resulting overpayment

82

+ Cheer

Onward and Upward she shall prevail We are here to care for the residents and provide a wonderful

service

13 83

84

References

bull Priority Healthbull Blue Crossbull Medicaidbull Medicare

85

  • Medicare Mange Care amp Medicaid Changes in the New World We Live In
  • Medicaid
  • NEW Medicaid Change MIlogin
  • Blueprint for Health Innovation MI
  • Provider Enrollment Electronic Signature Form Submission Process MSA 15-54
  • Provider Enrollment Electronic Signature Form Submission Process
  • Provider Enrollment Domain Administrator
  • Medicaid Coinsurance Medicare Advantage
  • Slide Number 9
  • Lawsuit DHS Changes on Caregivers
  • TPL Medicaid Change
  • CHAMPS Member Screen
  • LOC dropping off Not Due to MI Health
  • Issues
  • Secure Email Information
  • Medicaid amp Hospice
  • Medicaid
  • Medicaid Medicare Buy In
  • Manage Medicaid
  • Healthy Michigan Residents
  • Healthy Michigan Medicaid Days
  • McLaren Health Plan
  • Manage Medicaid Plans January 1
  • Slide Number 24
  • MI Health Link
  • MI Health Link 2565
  • What are the Names
  • MI Health Dual Eligible
  • MI Health LOC
  • LOC Medicaid
  • Medicaid Redetermination and MHL Enrollment
  • MI Health Link Portals
  • MI Health Authorizations
  • MI Health Issues
  • LOC 02 dropping MI Health Issues
  • PPA Offset
  • LOCD
  • MI Health Issues-New
  • ACO
  • Families Receiving Letters for ACO
  • ACO What is It
  • Payroll Based Journal
  • Slide Number 43
  • If you submit data manually should you also submit it through the XML
  • Staffing Submission Frequently Asked Questions
  • CMS defines
  • Slide Number 47
  • PBJ Medical Director Role
  • PBJ Medical Director Role
  • Dietician
  • Pharmacy Consultant
  • What are the names for the Medicare Number
  • QTSO
  • Medicare Update
  • CMS Final Rule On Returning Credits
  • Over Payment Rule
  • Questions to MAC
  • Questions to MAC
  • Final Rule on Returning Credits
  • Final Rule on Returning Credits
  • Final Rule on Returning Credits
  • Slide Number 62
  • Medicare Advantage Payors
  • Medicare Provider Enrollment Fee
  • Medicare MAC-Higlas
  • Two Midnight Rule
  • Two Midnight Rule
  • Two Midnight Rule
  • InPatient Vs Observation Conthellip
  • Two Midnight Rule
  • Health Data Insights amp Medicare Plus Blue
  • HDI Health Data amp Med Plus Blue
  • Health Data InSight
  • Pepper Reports
  • CGI Technologies and Solutions Inc httpracbcgicomContactInfoaspxst=1
  • CGI Federal RAC
  • How to survive RAC Audit
  • RAC Audits
  • How Did we get here
  • Where are we now
  • RAC Reviews
  • Priority Health SCIO Health Analytics
  • Cheer
  • References
Page 16: Medicare, Mange Care & Medicaid Changes in the New World we live in

Medicaid amp Hospicebull LOC 07 Manage Medicaid Hospice included so plan would pay

provider and not switch to a LOC 16

bull LOC 02 Medicaid (Regular Medicaid) Hospice not included so switch to 16 Hospice and Hospice pays provider

bull LOC 11 Healthy Michigan is included in plan so plan would pay provider and not switch to LOC 16

bull LOC 005 amp 015 MI Health is up in the air waiting for CMS Currently Hospice is now included

bull LOC 16 is Hospice when they switch from Regular Medicaid only and Hospice pays provider

16

Medicaidbull Going forward please make sure that your Champs ID amp NPI on your member screen matches your facility CHAMPS ID

amp NPI for each resident and matches for all new admissions or new approved Medicaid going forward

bull The edit will be turned on soon to stop the payment of these claims if the CHAMPS ID and NPI do not Match your facility on the Medicaid member screen

bull Make sure you are putting the information correct on the 2565 you send in to DHS

bull 1 I attached a 2565 When you fill this out for new people make sure in box 12 a you put your NPI and 12 b you put your CHAMPS ID This will help the DHS case workers assign the person to your facility

bull 2 I would check all your residents CHAMPS member screens and make sure the NPI and CHAMPS ID are your facilities If not you will have to work with the DHS worker to fix this The DHS worker is the only one that can fix this

bull 3 We are having some issues where the DHS case workers will not change this NPI and CHAMPS ID to your facilities You have to get them to change it or you just will not get paid

bull 4 We situations where the resident is in a facility in Kent County (as an example) but the family lives in Livingston County and completes the applications in Livingston County You will have to get the DHS worker in Livingston to fix it not the local DHS worker in Kent County where your facility is

17

Medicaid Medicare Buy Inbull Based on the information from the Office of Personnel Management Federal

Employeersquos employed as of January 1 1983 are eligible for Medicare Part A(see page 5 of attached document) This was also confirmed with our Social Security liaison If the beneficiary did not retire before 1983 he can enroll in Medicare Part B and pay the premium and then he can enroll in Medicare Part A and pay that premium as well or may qualify for Medicare Buy in of Part A

bull If a beneficiary has an SSA document stating they are not eligible for Medicare as they do not have enough work credits the beneficiarybeneficiary representative needs to go to SSA and let them know that while they know they are not eligible for Medicare Part A free or reduced however they are eligible for Medicare Part B and would like to enroll Once the beneficiary enrolls in Medicare Part B (enrollment period January 1st ndash March 31 each year) and pays the premium then the beneficiary is eligible to either pay for Medicare Part A or that beneficiary may qualify for Medicare Part A buy in through Medicaid Once the beneficiary is enrolled in Medicare Part A and Medicare Part B Medicaid will begin to make payments on claims

18

Manage Medicaid Where are we

19

Healthy Michigan Residents

20

Healthy Michigan Medicaid Days

21

McLaren Health Plan

22

Manage Medicaid Plans January 1bull Region 1 ndash Upper Peninsula Health Planbull Region 2 ndash McLaren Health Plan Meridian Health Plan of Michigan Molina Healthcare of Michigan

UnitedHealthcare Community Planbull Region 3 ndash McLaren Health Plan Meridian Health Plan of Michigan Molina Healthcare of Michigan

UnitedHealthcare Community Planbull Region 4 ndash Blue Cross Complete of Michigan McLaren Health Plan Meridian Health Plan of Michigan Molina

Healthcare of Michigan Priority Health Choice UnitedHealthcare Community Planbull Region 5 ndash McLaren Health Plan Meridian Health Plan of Michigan Molina Healthcare of Michigan

UnitedHealthcare Community Planbull Region 6 ndash Blue Cross Complete of Michigan HAP Midwest Health Plan McLaren Health Plan Meridian Health

Plan of Michigan Molina Healthcare of Michigan UnitedHealthcare Community Planbull Region 7 ndash Blue Cross Complete of Michigan McLaren Health Plan Meridian Health Plan UnitedHealthcare

Community Planbull Region 8 ndash Aetna Better Health of Michigan McLaren Health Plan Meridian Health Plan of Michigan Molina

Healthcare of Michigan Priority Health Choice UnitedHealthcare Community Planbull Region 9 ndash Aetna Better Health of Michigan Blue Cross Complete of Michigan McLaren Health Plan Meridian

Health Plan of Michigan Molina Healthcare of Michigan UnitedHealthcare Community Planbull Region 10 ndash Aetna Better Health of Michigan Blue Cross Complete of Michigan Harbor Health Plan McLaren

Health Plan Meridian Health Plan of Michigan Molina Healthcare of Michigan Total Health Care UnitedHealthcare Community Plan 23

24

MI Health LinkWhere are we

25

MI Health Link 2565

bull This notification is being sent to providers of long term care services including nursing facilities county medical care facilities and hospital long term care units to provide clarification on the process involved with the submission of the Facility Admission Form (MSA-2565-C) for an individual enrolled in the MI Health Link program

bull The MI Health Link program covers the custodiallong term nursing facility service benefit When an individual who is enrolled in the MI Health Link program is admitted to a nursing facility for custodiallong term nursing services a disenrollment from the Integrated Care Organization (MI Health Link health plan) is NOT REQUIRED The Facility Admission Form (MSA-2565-C) should NOT be sent to the Michigan Department of Health and Human Services (MDHHS) Enrollment Services Section for a disenrollment to be processed

26

What are the Names

bull Started as Integrated Health

bull Then called MMP (Medicare Medicaid Program)

bull Duals (Also Known as Duals as in Dual Eligible)

bull Now called MI Health Link

bull Total confusion

27

MI Health Dual Eligible28

MI Health LOC

29

LOC Medicaidbull We have the new pilot program which started on March

1 2015 in Southwest Michigan Region 4 Counties Macomb Wayne and the UP You could see these patients they are dual eligible in the Pilot program in counties surrounding the pilot

bull MHL-LOC 005 (All other Facilities) or LOC 015 (County Care) These residents have to call Michigan Enrolls to dis-enroll toll-free at 1-800-975-7630 (TTY 1-888-263-5897) Monday-Friday from 8 AM to 7 PM Once they dis-enroll they will go to a LOC 02 you have to do a new LOCD

30

Medicaid Redetermination and MHL Enrollmentbull At the time of re-determination for Medicaid financial eligibility the MI

Health Link (MHL) program will not be sending beneficiaries information about this program Beneficiaries who previously opted out will not be passively enrolled according to an email from the MHL staff The MHL staff wrote

bull ldquoThere is currently no MI Health Link enrollment letter sent to beneficiaries when eligibility is re-determined A person who becomes eligible for MI Health Link enrollment may opt-in at any time

bull When Medicaid re-determination takes place the beneficiary remains in the same ICO unless that beneficiary lost Medicaid coverage If the enrollee loses Medicaid coverage and later regains it they are not passively enrolled into MI Health Link The beneficiary may choose to opt back in to the program at that time if desiredrdquo

bull MHL staff did state that about 1500 beneficiaries will be passively enrolled effective January 1 2016 These specific individuals were given normal notice of 60 and 30 days in which to opt-in or opt-out if they so chose No other large scale passive enrollment is scheduled according to the MHL staff 31

MI Health Link Portals

bull Meridian Health Planbull httpwwwmhplancommibull Amerihealthbull httpwwwamerihealthcaritasvipcarepluscomproviderself-service-

toolsindexaspxbull AetnaCoventrybull httpwwwaetnabetterhealthcomMichiganprovidersportalbull Molinabull httpwwwmolinahealthcarecommembersmien-usmemPageshomeaspxbull HAPMidwestbull httpswwwmidwesthealthplancomLoginaspxbull FidelisCentenebull wwwfidelissccommmp 32

MI Health Authorizationsbull We need to watch these authorization that the plans are giving us for the MI

Health program Some plans are assigning a diagnosis for residents in their prior authorizations They are assigning diagnosis that the residents do not even have You need to make sure these are correct diagnosis and if not you need to work with the case managers of the plans to fix the issue The authorization numbers do change

bull Make sure that any resident that is in a MI Health plan that you have a prior authorization All plans are giving different periods authorizing the residents stay in the facility You need to set up a system to make sure you always have a authorization for the period of time you are rendering the service Here is an example of time frame of authorizations

bull Meridian is authorizing 12 monthsbull Aetna is authorizing 3 monthsbull Molina is authorizing 6 monthsbull The authorization numbers need to go on your claims to the payer You need to

put the authorizations in your software and track the dates

33

MI Health Issuesbull We are seeing some issues with MI Health where the resident does not have the correct LOC or it shows

up correct on CHAMPS but ancillary providers such as Dentist and such cannot see it I think we still have some issues with the information crossing between Bridges DHS system CMS and CHAMPS It in return is creating some access of care issues If it is a true LOC issues Facilities with LOC issues need to submit the Medicaid ID numbers to the MSA-MHL-EnrollmentMichigangov box with the subject line Nursing home LOC Issue so they may work to resolve the issues

bull If it becomes an access to care issue email the information to INTEGRATEDCAREmichigangov Remember in these emails only send the Medicaid ID and explain the situation The State will work with the plans to try to fix the process or improve the process

bull We are also seeing with new admission with LOC 015 or 005 that the plans are stating they have 14 days to authorize admission These are resident in the emergency room and possibly be admitted to you for Rehab The hospital will not keep the resident in ER for 14 days and you cannot admit the resident until you have a prior authorization I would recommend when you are told this by the plan that you need to ask to speak to a manager We will have to work through this

bull Ancillary Provider You need to work with your ancillary providers such as Lab Pharmacy X-Ray Physician and such to get the to be credentialed with the plans We are hearing that some of the pharmacies are not participating with the plans this will create issues for you so I would continue to ask these groups to participate

34

LOC 02 dropping MI Health Issuesbull The passive enrollments have occurred in Macomb amp Wayne for

Medicaid dual eligible We are having the same issue we did as in the Southwest MI amp UP with the passive enrollments I am starting to hear from facilities who are checking there CHAMPS member screens that those residents that have opted out (some residents not all) have lost there 02 Make sure you are checking your CHAMPS member screen both for those that were passively enrolled and those that might have lost there 02 Medicaid that opted out

bull Facilities with LOC issues need to submit the Medicaid ID numbers to the (Only MI Health)MSA-MHL-Enrollmentmichigangov box with the subject line Nursing home LOC Issue so they may work to resolve the issues

35

PPA Offset

bull There are no co-pays deductibles or premiums in MI Health Link so there should be no need to offset the PPA with code 25 MI Health Link enrollees can continue to offset their PPA for non-program covered medical expenses (like Vision-Code 27 Dental-Code 28 and Hearing-Code 26) and use the appropriate codes to offset the PPA when billing the health plan for nursing facility services

bull Resident pay PPA when MedicareMedicaid coinsurance

36

LOCDbull Nursing Facility Level of Care Determination (NFLOCD)

bull The MI Health Link health plan will be responsible for conducting the Michigan Medicaid NFLOCD tool for enrollees seeking admission to a nursing facility For existing residents at the time of enrollment the existing NFLOCD will be adopted for capitation payment purposes The health plan will complete a new NFLCOD tool within the first 90 days of enrollment If a nursing facility resident is disenrolled from MI Health Link the nursing facility will be responsible for conducting a new NFLOCD tool in accordance with published Medicaid policy

37

MI Health Issues-New

bull INTEGRATEDCAREmichigangov

bull Email with Insurance Plan issues Case Manager Issues

38

ACOWhat are they

39

Families Receiving Letters for ACO

40

ACO What is It

bull Whats an ACObull Accountable Care Organizations (ACOs) are groups of doctors hospitals

and other health care providers who come together voluntarily to give coordinated high quality care to their Medicare patients

bull The goal of coordinated care is to ensure that patients especially the chronically ill get the right care at the right time while avoiding

unnecessary duplication of services and preventing medical errorsbull When an ACO succeeds both in delivering high-quality care and

spending health care dollars more wisely it will share in the savings it achieves for the Medicare program

41

Payroll Based JournalMandatory on July 1 2016Internet Explorer Version

Internet Explorer v 10 and v 11 will need to operate in compatibility mode

42

43

If you submit data manually should you also submit it through the XML

bull Now you have three options

bull Submit Manually only

bull Submit through the XML only

bull You are able to submit manually and using the XML

44

45

Staffing Submission Frequently Asked Questions

bull ldquoWho are direct care staffrdquo (Who do we submit data for)bull Submission of data for contract staffbull Medical directors and consultantsbull Staff switching roles or tasks throughout the daybull Hours paid vs hours worked ndash Must be verifiablebull Public postingQuality MeasuresFive Starbull Enforcementbull Voluntary submission risks (noneSo register now)

CMS defines

bull 37 job title codes that are required to match employees to the number of hours each direct care function was performed It is important to work with your teams to define the workers that contribute to each job type and how those daily worked hours are recorded and converted to a PBJ submission

bull The PBJ does include some more specific job descriptions than the 671 For example the PBJ system includes job descriptions for RNs with administrative duties and LPNs with administrative duties versus the 671rsquos more general ldquoNurses with Administrative Duties

Page 46

47

PBJ Medical Director Rolebull Physician Leadership

bull Help the facility ensure that patients have appropriate physician coverage and ensure the provision of physician and health care practitioner services and

bull Help the facility develop a process for reviewing physician and health care practitioner credentials

bull Provide specific guidance for physician performance expectations

bull Help the facility ensure that a system is in place for monitoring the performance of health care practitioners and

bull Facilitate feedback to physicians and other health care practitioners on performance and practices

bull Patient Care - Clinical Leadership

bull Participate in administrative decision-making and the development of policies and procedures related to patient care

bull Help develop approve and implement specific clinical practices for the facility to incorporate into its care-related policies and procedures including areas required by laws and regulations

bull Develop procedures and guidance for facility staff regarding contacting practitioners including information gathering and presentation change in condition assessment and when to contact the medical director

bull Review consider andor act upon consultant recommendations as appropriate that affect the facilitys resident care policies and procedures or the care of an individual resident

bull Review respond to and participate in federal state local and other external surveys and inspections and

bull Help review policies and procedures regarding the adequate protection of patients rights advance care planning and other ethical issues48

PBJ Medical Director Rolebull Quality of Care

bull Help the facility establish systems and methods for reviewing the quality and appropriateness of clinical care and other health-related services and provide appropriate feedback and

bull Participate in the facilitys quality improvement process

bull Advise on infection control issues and approve specific infection control policies to be incorporated into facility policies and procedures

bull Help the facility provide a safe and caring environment

bull Help promote employee health and safety and

bull Assist in the development and implementation of employee health policies and programs

bull Education Information and Communication

bull Promote a learning culture within the facility by educating informing and communicating

bull Provide information to help the facility provide care consistent with current standards of practice (defined as approaches to care procedures techniques and treatments that are based on research and or expert consensus and that are contained in current manuals textbooks and or publications or that are accepted adopted or promulgated by recognized organizations or national bodies)

bull Help the facility develop medical information and communication systems with staff patients and families and others

bull Represent the facility to the professional and lay community on medical and patient care issues

bull Maintain knowledge of the changing social regulatory political and economic factors that affect medical and health services of long term care patients and

bull Help establish appropriate relationships with other health care organizations

49

Dietician

bull When the dietary or food services supervisor is other than a registered dietitian the supervisor shall receive routine consultation and technical assistance from a registered dietitian (RD) Consultation time shall not be less than 4 hours every 60 days Additional consultation time may be needed based on the total number of patients incidence of nutrition-related health problems and food service management needs of the facility

50

Pharmacy Consultant

bull At least once per month a licensed pharmacist must perform a drug regimen review (DRR) for each resident The pharmacist must report any irregularities to the attending physician or director of nursing Furthermore these reports must be acted upon

51

What are the names for the Medicare Numberbull OSCAR -Online Survey Certification and Reporting

bull PTAN-PTAN number is assigned by Medicare to authenticate the provider when using the local Medicare Administrative Contractorrsquos (MAC) self-help tools like the IVR internet portal on-line application status etc Provider Transactions Access Number

bull CCN- CMS Certification Number

bull Medicare Number- example 23-

bull All of the above mean the same thing

52

QTSO

bull Once you are logged in the QTSO site bull You will have a state login to the site to access the various site specific

to your facilitybull Installing you will need administrator rights to your network

53

Medicare UpdateWhat are we seeing

54

CMS Final Rule On Returning Credits

httpswwwfederalregistergovarticles201602122016-02789medicare-program-reporting-and-returning-of-overpayments

55

Over Payment Rule

bull Medicare payments for non covered services

bull Medicare payments in excess of the allowable amount for an identified covered service

bull Errors and non reimbursable expenditures in cost reportsbull Duplicate payment

bull Receipt of Medicare payments when another payor had the primary responsibility for payment

56

Questions to MAC

bull Does the Medicare credit balance report change with this overpayment rule

bull No Medicare Credit Balances are still required at the end of each quarter

bull Will that still be the communication to let CMS or the MAC know that we have received an overpayment

bull Submission of Medicare Credit Balance is one form of communicating overpayments to CMS Other methods include submitting a voluntary refund with required claim information or the submission of a standard overpayment form

57

Questions to MAC

bull Will the MAC still deduct from a future RAbull If the recovery of the overpayment includes adjusting a claim then

the overpayment would be netted against future claims payments and reflected on the RA

bull Or will that process change with this new rulebull Process will remain the samebull Will NGS send communication out on thisbull Yes NGS will communicate this once the final rule is communicated

to the MACs by CMS However this could change depending on final CMS instructions

58

Final Rule on Returning Credits

bull Providers will want to immediately update their current policies governing overpayments in order to comply with this new rule which will take effect on March 14 2016

bull Providers and suppliers are required to use reasonable diligence to investigate credible information regarding overpayments through both proactive compliance efforts and reactive investigations

bull If an overpayment is identified then it must be repaid within 60 days An overpayment is identified when a person has or should have through the exercise of reasonable diligence determined that the person received an overpayment and quantified the amount

bull Providers and suppliers have a maximum of 8 months to report and return overpayments ndash up to 6 months to investigate and quantify the overpayment (ie to identify it) and up to 60 days to report and return the overpayment

59

Final Rule on Returning Credits

bull Providers and suppliers are required to report and return all overpayments within a 6-year lookback period

bull The cause and amount of the overpayment is irrelevant for the determination eg it was due to a mistake it was someone elsersquos fault it is a minor amount An overpayment is an overpayment and must be returned

bull Providers and suppliers must make their own determination to which entity to report and return the overpayment ie to the Medicare contractor or using the OIG Self Disclosure Protocol or the CMS Self Referral Disclosure Protocol

60

Final Rule on Returning Credits

bull Providers and suppliers may use the claims adjustment credit balance self-reported refund process or another appropriate process to report and return overpayments At this time there is no standard refund form to use

bull Failure to report and return an overpayment could subject the provider or supplier to False Claims Act liability Civil Monetary Penalties Law liability and exclusion from federal health care programs

61

P S amp R-Accountants will be asking for this information

The location you login into has changed it is now on EIDM EIDM is the acronym for CMS Enterprise Identity Management system which includes Identity Verification Access Management Authorization Assistance Workflow Tools and Identity Lifecycle Management functions

httpswwwcmsgovResearch-Statistics-Data-and-SystemsCMS-Information-TechnologyIACSCMS-Applications-Loginhtml

Go down the page and click on the PSampRSTARThis will take you to the login pagewill look the same as the old P S amp R didChanges Affecting PSampR System Access (Please Read) (posted 01292015)(Updated 5262015)is changingThe system which controls your PSampR user ID (currently IACS)The new system is referred to as EIDMThis will result in a different way to create new accounts or change passwords to existing accountsIf you already have an account in EIDM you may have to use that account for accessing PSampR after the transitionWhen is the change effectiveJune 13 2015What is staying the sameThe internet address for accessing PSampR remains the sameThe PSampR systemfunctionality is NOT changing 62

Medicare Advantage Payorsbull Medicare Advantage payors are pullingdenying payments on admissions if the patient was readmitted within 30 days after discharge The

client believes that the payors systematically denying payments for all readmissions within 30 days They believe this practice denies them due process to address whether the readmissions were justified and not due to a premature discharge of patient The payors seem to want to act like a QIO without having the same accountabilities of the QIO related to determinations of non-payment

bull Heres the QIO process under section 4240 of the QIO Manualbull 4240 - Readmission Review - (Rev 2 07-11-03)bull Readmission review involves admissions to an acute general short-term hospital occurring less than 31 calendar days from the date of

discharge from the same or another acute general short-term hospital (see sect1154(a)(13) and 42 CFR 47671(a)(8)(ii)) Neither the day of discharge nor the day of admission is counted when determining whether a readmission has occurred

bull A Medical Review Proceduresbull Obtain the appropriate medical records for the initial admission and readmission Perform case review on both stays Analyze the cases

specifically to determine whether the patient was prematurely discharged from the first confinement thus causing readmission Perform an analysis of the stay at the first hospital to determine the cause(s) and extent of any problem(s) (eg incomplete or substandard treatment) Consider the information available to the attending physician who discharged the patient from the first confinement Do not base a determination of a premature discharge on information that the physician or provider could not have known or events that could not have been anticipated at the time of discharge

bull Review both the initial admission and the readmission at the same time unless one of them has previously been reviewed In these cases use at a minimum the PRAF case summary of the other admission in addition to the medical record of the case under review

bull C Denialsbull Deny readmissions under the following circumstancesbull If the readmission was medically unnecessarybull If the readmission resulted from a premature discharge from the same hospital orbull If the readmission was a result of circumvention of PPS by the same hospital (see sect4255)bull With the QIO process there is an appeal within the QIO here the hospital is getting no opportunity to challenge the denials

63

Medicare Provider Enrollment Feebull Provider Enrollment Application Fee Amount for CY 2016bull On December 3 CMS issued a notice Provider Enrollment Application

Fee Amount for CY 2016 [CMSndash6066ndashN] Effective January 1 2016 the CY 2016 application fee is $554 for institutional providers that are

bull Initially enrolling in the Medicare or Medicaid program or the Childrens Health Insurance Program (CHIP)

bull Revalidating their Medicare Medicaid or CHIP enrollmentbull Adding a new Medicare practice locationbull This fee is required with any enrollment application submitted from

January 1 through December 31 2016

64

Medicare MAC-Higlas

bull Effective 142016 CMS has implemented a change to begin netting (offsetting) provider money across workloads within a single organization What this means is that any related providers conducting business in two different workloads (example New York and Maine) will have their money applied to any account receivables (AR) with a remaining balance owed to Medicare within both workloads For example Provider ABC is located in New York and is scheduled to receive a payment of $1000 on todays remittance advice Provider XYZ is related to provider ABC but is located in Maine and has ARs with a balance owed of $200 Provider ABCs $1000 payment will have the $200 applied against provider XYZs ARs resulting in a net payment of $800 This will be reflected on the remittance advice by the same PLB code as seen today for offsets for the $200

65

Two Midnight RuleChange January 1 2016 httpswwwcmsgovMedicareMedicare-Fee-for-Service-PaymentHospitalOutpatientPPSHospital-Outpatient-Regulations-and-Notices-ItemsCMS-1633-FChtml

66

Two Midnight Rulebull However effective January 1 2016 CMS will allow exceptions to the

Two-Midnight Benchmark to be determined on a case-by-case basis by the physician responsible for the care of the beneficiary subject to medical review Said differently Part A payment may be appropriate in some circumstances even though there is no expectation by the physician (or qualified ordering practitioner) of a two-midnight stay and one of the two pre-existing categorical exceptions (CMS ldquoinpatient onlyrdquo list and newly initiated mechanical ventilation) does not apply CMS has indicated that this change to the Two Midnight Rule is in response to stakeholder concern and CMSrsquos continued efforts to develop the most appropriate standard for determining Medicare Part A payment

67

Two Midnight Rulebull A new 42 CFR sect4123(a) provides that a patient is considered an

inpatient of a hospitalhellipif formally admitted as an inpatient pursuant to an order for inpatient admission by a physician or other qualified practitionerhellip The physician orders inpatient status when he or she expects the patient to require a stay that crosses at least 2 midnights[10] Stays expected to be shorter than at least two midnights are generally inappropriate for inpatient admission and inpatient payment under Medicare Part A unless the surgical procedure is specified by Medicare as inpatient only under sect41922(n)[11] The physicians expectationhellipshould be based on such complex medical factors as patient history and comorbidities the severity of signs and symptoms current medical needs and the risk of an adverse event[12] The physician order is part of physician certification of the medical necessity of hospital inpatient serviceshellip[13]

68

InPatient Vs Observation Conthellip

bull Physician certification which begins with an order for inpatient admission requires the physician to certify the reasons for the hospitalization the estimated time the patient will remain in the hospital and plans for post-hospital care if appropriate[14] The certification must be completed signed and documented in the medical record prior to discharge[15]

bull A physicians admission order has no presumptive weight and both the admission order and the physician certification will be evaluated in the context of the evidence in the medical record[16] CMS intends to provide additional information about what evidence in the medical record means in future instructions and manual revisions[17]

69

Two Midnight Rulebull Although the new case-by-case exception appears to be inherently

subjective to a certain extent CMS states that the following factors (among others) would be relevant to determining whether a patient requires inpatient admission under the expanded policy

bull The severity of the signs and symptoms exhibited by the patient bull The medical predictability of something adverse happening to the patient

and bull The need for diagnostic studies that appropriately are outpatient services

(that is their performance does not ordinarily require the patient to remain at the hospital for 24 hours or more)

bull CMS also notes that an inpatient admission (and Part A payment) should be ldquorare and unusualrdquo for minor surgical procedures or other treatment that is expected to keep the patient in the hospital ldquofor only a few hoursrdquo or for a period of time that ldquodoes not span at least overnightrdquo (thus a subset of stays not meeting the Two Midnight Benchmark) CMS indicates that such cases will be prioritized for medical review

70

Health Data Insights amp Medicare Plus Blue

RAC (Retrospective Audits)

71

HDI Health Data amp Med Plus Blue

bull httpwwwhealthdatainsightscombull Blue Cross Medicare Advantage Auditsbull Facilities seeing 10 to 15 requests for Medical Recordsbull In January amp Feburarybull Selected Health Data Insights because they were a premier Audit

Vendor for CMS Recovery Audit Contractor (RAC) demonstration Project They are a audit vendor for Humana

bull Providers not sending Medical Record will get technical denial and lose payments

72

Health Data InSight

bull In 2010 they began the Hospital Reviewbull Medicare Advantage encounter datandashCMS oversight of data integrity OIG

2016bull We will review CMSs oversight of MA encounter data validation and assess

the extent to which CMSrsquos Integrated Data Repository contains timely valid and complete MA encounter data In 2012 CMS began collecting from MA organizations a more comprehensive set of encounter data reflecting the items and services provided to MA plan enrollees Prior CMS and OIG audits have indicated vulnerabilities in the accuracy of data reporting by MA organizations Realizing the potential benefits of the MA encounter data for payment and program integrity oversight is contingent upon the datarsquos completeness validity and timeliness (OEI 03-15-00060 expected issue date FY 2017)

73

Pepper Reports

bull httpswwwpepperresourcesorg

bull Program for Evaluating Payment Patterns Electronic Report ( PEPPER)

bull Annually on or about April 18 2016 will be released

bull Pepper Portal httpssecurefiletmforg

74

CGI Technologies and Solutions Inc httpracbcgicomContactInfoaspxst=1

bull Indiana bull Michiganbull Minnesotabull Illinoisbull Kentuckybull Ohiobull Wisconsin CGI Technologies and Solutions Incbull For general and administrative questions regarding client service outreach

quality assurance or project-specific issues contactbull 1877316RACB (7222)bull Email racbcgicom Tamara Tate Tamaratatecmshhsgovbull 4107861288

75

CGI Federal RAC

bull CGI Federal RAC Region Bbull Email racbcgicombull Phone 1-877-316-RACB (7222)bull Mailing Addressbull Send medical records as followsbull Medical records for Indiana Illinois Kentucky Michigan Ohio Wisconsin

Minnesota DME and Home Health CGI Federal Inc Attn RACB Imaging Dept 1001 Lakeside Ave Suite 800 Cleveland OH 44114

bull If submitting paper records please send medical records as follows For Therapy Reviews CGI Federal Inc Attn RACB Imaging 1001 Lakeside Avenue Suite 800 Cleveland OH 44114

76

How to survive RAC Audit

bull National health expenditures totaled $1679 Billion in 2003 bull National health expenditures were 153 of GROSS Domestic Product

(GDP) in 2003 bull Health care cost increasing at +9 per year bull Doomsday predictions of Medicare running out bull Congressional Action

77

RAC Audits

bull Medicare Modernization Act (MMA) of 2003Mandated a three year audit demonstration project 2005-2008

bull Appoint audit contractors to review Medicare billings for proper coding DRG assignment and medical necessity

bull Audits will apply to all health care providers (hospitals physicians homecare dme etc)

bull Audit contractors to be paid on a contingency basis a percentage of overpayments recovered

78

How Did we get here

bull Overpayments collected due to errors in Medically Unnecessary Services ndash 40

bull Incorrectly Coded ndash 35

bull Other ndash 17

bull NoInsufficient Documentation ndash 8

79

Where are we now

bull All RACrsquos completed required provider outreachAccess to Medicare billing data base given to all RAC RAC review methodology

bull Automated Review-Black amp White Issues (current) bull DRG Validation-complex review (current) bull Complex Review for coding errors (current) bull DME Medical Necessity Reviews ndashcomplex review (calendar year

2010) bull Medical Necessity Reviews-complex review (calendar year 2010)

80

RAC Reviews

bull Responsibilities of the Team Leader bull Must learn each insurance provider participating in a RAC or RAC type

program bull What are their operating rulesbull What is their appeal process Time limits

May be different process for each insurance provider bull Develop a response team

Identify who does what when why and alternate bull individual

Build and develop a manual process Review of computerized system

81

Priority Health SCIO Health Analytics

bull httpswwwsciohealthanalyticscomcore-capabilitiespayment-integrityfacility-auditsskilled-nursing-facility-audits

bull Claims for Medicare members treated at Skilled Nursing Facilities are reimbursed based on the patientsrsquo RUG (Resource Utilization Group) score which is determined using the Minimum Data Set (MDS) Using SCIOs robust analytics claims andor providers that merit review are selected for audit SCIOs auditors conduct a detailed review of the complete medical record and associated MDS to determine if the billed RUG score is valid In the event the review determines that an incorrect RUG score was billed SCIOreg provides the valid score reports the reason the change was necessary and calculates the resulting overpayment

82

+ Cheer

Onward and Upward she shall prevail We are here to care for the residents and provide a wonderful

service

13 83

84

References

bull Priority Healthbull Blue Crossbull Medicaidbull Medicare

85

  • Medicare Mange Care amp Medicaid Changes in the New World We Live In
  • Medicaid
  • NEW Medicaid Change MIlogin
  • Blueprint for Health Innovation MI
  • Provider Enrollment Electronic Signature Form Submission Process MSA 15-54
  • Provider Enrollment Electronic Signature Form Submission Process
  • Provider Enrollment Domain Administrator
  • Medicaid Coinsurance Medicare Advantage
  • Slide Number 9
  • Lawsuit DHS Changes on Caregivers
  • TPL Medicaid Change
  • CHAMPS Member Screen
  • LOC dropping off Not Due to MI Health
  • Issues
  • Secure Email Information
  • Medicaid amp Hospice
  • Medicaid
  • Medicaid Medicare Buy In
  • Manage Medicaid
  • Healthy Michigan Residents
  • Healthy Michigan Medicaid Days
  • McLaren Health Plan
  • Manage Medicaid Plans January 1
  • Slide Number 24
  • MI Health Link
  • MI Health Link 2565
  • What are the Names
  • MI Health Dual Eligible
  • MI Health LOC
  • LOC Medicaid
  • Medicaid Redetermination and MHL Enrollment
  • MI Health Link Portals
  • MI Health Authorizations
  • MI Health Issues
  • LOC 02 dropping MI Health Issues
  • PPA Offset
  • LOCD
  • MI Health Issues-New
  • ACO
  • Families Receiving Letters for ACO
  • ACO What is It
  • Payroll Based Journal
  • Slide Number 43
  • If you submit data manually should you also submit it through the XML
  • Staffing Submission Frequently Asked Questions
  • CMS defines
  • Slide Number 47
  • PBJ Medical Director Role
  • PBJ Medical Director Role
  • Dietician
  • Pharmacy Consultant
  • What are the names for the Medicare Number
  • QTSO
  • Medicare Update
  • CMS Final Rule On Returning Credits
  • Over Payment Rule
  • Questions to MAC
  • Questions to MAC
  • Final Rule on Returning Credits
  • Final Rule on Returning Credits
  • Final Rule on Returning Credits
  • Slide Number 62
  • Medicare Advantage Payors
  • Medicare Provider Enrollment Fee
  • Medicare MAC-Higlas
  • Two Midnight Rule
  • Two Midnight Rule
  • Two Midnight Rule
  • InPatient Vs Observation Conthellip
  • Two Midnight Rule
  • Health Data Insights amp Medicare Plus Blue
  • HDI Health Data amp Med Plus Blue
  • Health Data InSight
  • Pepper Reports
  • CGI Technologies and Solutions Inc httpracbcgicomContactInfoaspxst=1
  • CGI Federal RAC
  • How to survive RAC Audit
  • RAC Audits
  • How Did we get here
  • Where are we now
  • RAC Reviews
  • Priority Health SCIO Health Analytics
  • Cheer
  • References
Page 17: Medicare, Mange Care & Medicaid Changes in the New World we live in

Medicaidbull Going forward please make sure that your Champs ID amp NPI on your member screen matches your facility CHAMPS ID

amp NPI for each resident and matches for all new admissions or new approved Medicaid going forward

bull The edit will be turned on soon to stop the payment of these claims if the CHAMPS ID and NPI do not Match your facility on the Medicaid member screen

bull Make sure you are putting the information correct on the 2565 you send in to DHS

bull 1 I attached a 2565 When you fill this out for new people make sure in box 12 a you put your NPI and 12 b you put your CHAMPS ID This will help the DHS case workers assign the person to your facility

bull 2 I would check all your residents CHAMPS member screens and make sure the NPI and CHAMPS ID are your facilities If not you will have to work with the DHS worker to fix this The DHS worker is the only one that can fix this

bull 3 We are having some issues where the DHS case workers will not change this NPI and CHAMPS ID to your facilities You have to get them to change it or you just will not get paid

bull 4 We situations where the resident is in a facility in Kent County (as an example) but the family lives in Livingston County and completes the applications in Livingston County You will have to get the DHS worker in Livingston to fix it not the local DHS worker in Kent County where your facility is

17

Medicaid Medicare Buy Inbull Based on the information from the Office of Personnel Management Federal

Employeersquos employed as of January 1 1983 are eligible for Medicare Part A(see page 5 of attached document) This was also confirmed with our Social Security liaison If the beneficiary did not retire before 1983 he can enroll in Medicare Part B and pay the premium and then he can enroll in Medicare Part A and pay that premium as well or may qualify for Medicare Buy in of Part A

bull If a beneficiary has an SSA document stating they are not eligible for Medicare as they do not have enough work credits the beneficiarybeneficiary representative needs to go to SSA and let them know that while they know they are not eligible for Medicare Part A free or reduced however they are eligible for Medicare Part B and would like to enroll Once the beneficiary enrolls in Medicare Part B (enrollment period January 1st ndash March 31 each year) and pays the premium then the beneficiary is eligible to either pay for Medicare Part A or that beneficiary may qualify for Medicare Part A buy in through Medicaid Once the beneficiary is enrolled in Medicare Part A and Medicare Part B Medicaid will begin to make payments on claims

18

Manage Medicaid Where are we

19

Healthy Michigan Residents

20

Healthy Michigan Medicaid Days

21

McLaren Health Plan

22

Manage Medicaid Plans January 1bull Region 1 ndash Upper Peninsula Health Planbull Region 2 ndash McLaren Health Plan Meridian Health Plan of Michigan Molina Healthcare of Michigan

UnitedHealthcare Community Planbull Region 3 ndash McLaren Health Plan Meridian Health Plan of Michigan Molina Healthcare of Michigan

UnitedHealthcare Community Planbull Region 4 ndash Blue Cross Complete of Michigan McLaren Health Plan Meridian Health Plan of Michigan Molina

Healthcare of Michigan Priority Health Choice UnitedHealthcare Community Planbull Region 5 ndash McLaren Health Plan Meridian Health Plan of Michigan Molina Healthcare of Michigan

UnitedHealthcare Community Planbull Region 6 ndash Blue Cross Complete of Michigan HAP Midwest Health Plan McLaren Health Plan Meridian Health

Plan of Michigan Molina Healthcare of Michigan UnitedHealthcare Community Planbull Region 7 ndash Blue Cross Complete of Michigan McLaren Health Plan Meridian Health Plan UnitedHealthcare

Community Planbull Region 8 ndash Aetna Better Health of Michigan McLaren Health Plan Meridian Health Plan of Michigan Molina

Healthcare of Michigan Priority Health Choice UnitedHealthcare Community Planbull Region 9 ndash Aetna Better Health of Michigan Blue Cross Complete of Michigan McLaren Health Plan Meridian

Health Plan of Michigan Molina Healthcare of Michigan UnitedHealthcare Community Planbull Region 10 ndash Aetna Better Health of Michigan Blue Cross Complete of Michigan Harbor Health Plan McLaren

Health Plan Meridian Health Plan of Michigan Molina Healthcare of Michigan Total Health Care UnitedHealthcare Community Plan 23

24

MI Health LinkWhere are we

25

MI Health Link 2565

bull This notification is being sent to providers of long term care services including nursing facilities county medical care facilities and hospital long term care units to provide clarification on the process involved with the submission of the Facility Admission Form (MSA-2565-C) for an individual enrolled in the MI Health Link program

bull The MI Health Link program covers the custodiallong term nursing facility service benefit When an individual who is enrolled in the MI Health Link program is admitted to a nursing facility for custodiallong term nursing services a disenrollment from the Integrated Care Organization (MI Health Link health plan) is NOT REQUIRED The Facility Admission Form (MSA-2565-C) should NOT be sent to the Michigan Department of Health and Human Services (MDHHS) Enrollment Services Section for a disenrollment to be processed

26

What are the Names

bull Started as Integrated Health

bull Then called MMP (Medicare Medicaid Program)

bull Duals (Also Known as Duals as in Dual Eligible)

bull Now called MI Health Link

bull Total confusion

27

MI Health Dual Eligible28

MI Health LOC

29

LOC Medicaidbull We have the new pilot program which started on March

1 2015 in Southwest Michigan Region 4 Counties Macomb Wayne and the UP You could see these patients they are dual eligible in the Pilot program in counties surrounding the pilot

bull MHL-LOC 005 (All other Facilities) or LOC 015 (County Care) These residents have to call Michigan Enrolls to dis-enroll toll-free at 1-800-975-7630 (TTY 1-888-263-5897) Monday-Friday from 8 AM to 7 PM Once they dis-enroll they will go to a LOC 02 you have to do a new LOCD

30

Medicaid Redetermination and MHL Enrollmentbull At the time of re-determination for Medicaid financial eligibility the MI

Health Link (MHL) program will not be sending beneficiaries information about this program Beneficiaries who previously opted out will not be passively enrolled according to an email from the MHL staff The MHL staff wrote

bull ldquoThere is currently no MI Health Link enrollment letter sent to beneficiaries when eligibility is re-determined A person who becomes eligible for MI Health Link enrollment may opt-in at any time

bull When Medicaid re-determination takes place the beneficiary remains in the same ICO unless that beneficiary lost Medicaid coverage If the enrollee loses Medicaid coverage and later regains it they are not passively enrolled into MI Health Link The beneficiary may choose to opt back in to the program at that time if desiredrdquo

bull MHL staff did state that about 1500 beneficiaries will be passively enrolled effective January 1 2016 These specific individuals were given normal notice of 60 and 30 days in which to opt-in or opt-out if they so chose No other large scale passive enrollment is scheduled according to the MHL staff 31

MI Health Link Portals

bull Meridian Health Planbull httpwwwmhplancommibull Amerihealthbull httpwwwamerihealthcaritasvipcarepluscomproviderself-service-

toolsindexaspxbull AetnaCoventrybull httpwwwaetnabetterhealthcomMichiganprovidersportalbull Molinabull httpwwwmolinahealthcarecommembersmien-usmemPageshomeaspxbull HAPMidwestbull httpswwwmidwesthealthplancomLoginaspxbull FidelisCentenebull wwwfidelissccommmp 32

MI Health Authorizationsbull We need to watch these authorization that the plans are giving us for the MI

Health program Some plans are assigning a diagnosis for residents in their prior authorizations They are assigning diagnosis that the residents do not even have You need to make sure these are correct diagnosis and if not you need to work with the case managers of the plans to fix the issue The authorization numbers do change

bull Make sure that any resident that is in a MI Health plan that you have a prior authorization All plans are giving different periods authorizing the residents stay in the facility You need to set up a system to make sure you always have a authorization for the period of time you are rendering the service Here is an example of time frame of authorizations

bull Meridian is authorizing 12 monthsbull Aetna is authorizing 3 monthsbull Molina is authorizing 6 monthsbull The authorization numbers need to go on your claims to the payer You need to

put the authorizations in your software and track the dates

33

MI Health Issuesbull We are seeing some issues with MI Health where the resident does not have the correct LOC or it shows

up correct on CHAMPS but ancillary providers such as Dentist and such cannot see it I think we still have some issues with the information crossing between Bridges DHS system CMS and CHAMPS It in return is creating some access of care issues If it is a true LOC issues Facilities with LOC issues need to submit the Medicaid ID numbers to the MSA-MHL-EnrollmentMichigangov box with the subject line Nursing home LOC Issue so they may work to resolve the issues

bull If it becomes an access to care issue email the information to INTEGRATEDCAREmichigangov Remember in these emails only send the Medicaid ID and explain the situation The State will work with the plans to try to fix the process or improve the process

bull We are also seeing with new admission with LOC 015 or 005 that the plans are stating they have 14 days to authorize admission These are resident in the emergency room and possibly be admitted to you for Rehab The hospital will not keep the resident in ER for 14 days and you cannot admit the resident until you have a prior authorization I would recommend when you are told this by the plan that you need to ask to speak to a manager We will have to work through this

bull Ancillary Provider You need to work with your ancillary providers such as Lab Pharmacy X-Ray Physician and such to get the to be credentialed with the plans We are hearing that some of the pharmacies are not participating with the plans this will create issues for you so I would continue to ask these groups to participate

34

LOC 02 dropping MI Health Issuesbull The passive enrollments have occurred in Macomb amp Wayne for

Medicaid dual eligible We are having the same issue we did as in the Southwest MI amp UP with the passive enrollments I am starting to hear from facilities who are checking there CHAMPS member screens that those residents that have opted out (some residents not all) have lost there 02 Make sure you are checking your CHAMPS member screen both for those that were passively enrolled and those that might have lost there 02 Medicaid that opted out

bull Facilities with LOC issues need to submit the Medicaid ID numbers to the (Only MI Health)MSA-MHL-Enrollmentmichigangov box with the subject line Nursing home LOC Issue so they may work to resolve the issues

35

PPA Offset

bull There are no co-pays deductibles or premiums in MI Health Link so there should be no need to offset the PPA with code 25 MI Health Link enrollees can continue to offset their PPA for non-program covered medical expenses (like Vision-Code 27 Dental-Code 28 and Hearing-Code 26) and use the appropriate codes to offset the PPA when billing the health plan for nursing facility services

bull Resident pay PPA when MedicareMedicaid coinsurance

36

LOCDbull Nursing Facility Level of Care Determination (NFLOCD)

bull The MI Health Link health plan will be responsible for conducting the Michigan Medicaid NFLOCD tool for enrollees seeking admission to a nursing facility For existing residents at the time of enrollment the existing NFLOCD will be adopted for capitation payment purposes The health plan will complete a new NFLCOD tool within the first 90 days of enrollment If a nursing facility resident is disenrolled from MI Health Link the nursing facility will be responsible for conducting a new NFLOCD tool in accordance with published Medicaid policy

37

MI Health Issues-New

bull INTEGRATEDCAREmichigangov

bull Email with Insurance Plan issues Case Manager Issues

38

ACOWhat are they

39

Families Receiving Letters for ACO

40

ACO What is It

bull Whats an ACObull Accountable Care Organizations (ACOs) are groups of doctors hospitals

and other health care providers who come together voluntarily to give coordinated high quality care to their Medicare patients

bull The goal of coordinated care is to ensure that patients especially the chronically ill get the right care at the right time while avoiding

unnecessary duplication of services and preventing medical errorsbull When an ACO succeeds both in delivering high-quality care and

spending health care dollars more wisely it will share in the savings it achieves for the Medicare program

41

Payroll Based JournalMandatory on July 1 2016Internet Explorer Version

Internet Explorer v 10 and v 11 will need to operate in compatibility mode

42

43

If you submit data manually should you also submit it through the XML

bull Now you have three options

bull Submit Manually only

bull Submit through the XML only

bull You are able to submit manually and using the XML

44

45

Staffing Submission Frequently Asked Questions

bull ldquoWho are direct care staffrdquo (Who do we submit data for)bull Submission of data for contract staffbull Medical directors and consultantsbull Staff switching roles or tasks throughout the daybull Hours paid vs hours worked ndash Must be verifiablebull Public postingQuality MeasuresFive Starbull Enforcementbull Voluntary submission risks (noneSo register now)

CMS defines

bull 37 job title codes that are required to match employees to the number of hours each direct care function was performed It is important to work with your teams to define the workers that contribute to each job type and how those daily worked hours are recorded and converted to a PBJ submission

bull The PBJ does include some more specific job descriptions than the 671 For example the PBJ system includes job descriptions for RNs with administrative duties and LPNs with administrative duties versus the 671rsquos more general ldquoNurses with Administrative Duties

Page 46

47

PBJ Medical Director Rolebull Physician Leadership

bull Help the facility ensure that patients have appropriate physician coverage and ensure the provision of physician and health care practitioner services and

bull Help the facility develop a process for reviewing physician and health care practitioner credentials

bull Provide specific guidance for physician performance expectations

bull Help the facility ensure that a system is in place for monitoring the performance of health care practitioners and

bull Facilitate feedback to physicians and other health care practitioners on performance and practices

bull Patient Care - Clinical Leadership

bull Participate in administrative decision-making and the development of policies and procedures related to patient care

bull Help develop approve and implement specific clinical practices for the facility to incorporate into its care-related policies and procedures including areas required by laws and regulations

bull Develop procedures and guidance for facility staff regarding contacting practitioners including information gathering and presentation change in condition assessment and when to contact the medical director

bull Review consider andor act upon consultant recommendations as appropriate that affect the facilitys resident care policies and procedures or the care of an individual resident

bull Review respond to and participate in federal state local and other external surveys and inspections and

bull Help review policies and procedures regarding the adequate protection of patients rights advance care planning and other ethical issues48

PBJ Medical Director Rolebull Quality of Care

bull Help the facility establish systems and methods for reviewing the quality and appropriateness of clinical care and other health-related services and provide appropriate feedback and

bull Participate in the facilitys quality improvement process

bull Advise on infection control issues and approve specific infection control policies to be incorporated into facility policies and procedures

bull Help the facility provide a safe and caring environment

bull Help promote employee health and safety and

bull Assist in the development and implementation of employee health policies and programs

bull Education Information and Communication

bull Promote a learning culture within the facility by educating informing and communicating

bull Provide information to help the facility provide care consistent with current standards of practice (defined as approaches to care procedures techniques and treatments that are based on research and or expert consensus and that are contained in current manuals textbooks and or publications or that are accepted adopted or promulgated by recognized organizations or national bodies)

bull Help the facility develop medical information and communication systems with staff patients and families and others

bull Represent the facility to the professional and lay community on medical and patient care issues

bull Maintain knowledge of the changing social regulatory political and economic factors that affect medical and health services of long term care patients and

bull Help establish appropriate relationships with other health care organizations

49

Dietician

bull When the dietary or food services supervisor is other than a registered dietitian the supervisor shall receive routine consultation and technical assistance from a registered dietitian (RD) Consultation time shall not be less than 4 hours every 60 days Additional consultation time may be needed based on the total number of patients incidence of nutrition-related health problems and food service management needs of the facility

50

Pharmacy Consultant

bull At least once per month a licensed pharmacist must perform a drug regimen review (DRR) for each resident The pharmacist must report any irregularities to the attending physician or director of nursing Furthermore these reports must be acted upon

51

What are the names for the Medicare Numberbull OSCAR -Online Survey Certification and Reporting

bull PTAN-PTAN number is assigned by Medicare to authenticate the provider when using the local Medicare Administrative Contractorrsquos (MAC) self-help tools like the IVR internet portal on-line application status etc Provider Transactions Access Number

bull CCN- CMS Certification Number

bull Medicare Number- example 23-

bull All of the above mean the same thing

52

QTSO

bull Once you are logged in the QTSO site bull You will have a state login to the site to access the various site specific

to your facilitybull Installing you will need administrator rights to your network

53

Medicare UpdateWhat are we seeing

54

CMS Final Rule On Returning Credits

httpswwwfederalregistergovarticles201602122016-02789medicare-program-reporting-and-returning-of-overpayments

55

Over Payment Rule

bull Medicare payments for non covered services

bull Medicare payments in excess of the allowable amount for an identified covered service

bull Errors and non reimbursable expenditures in cost reportsbull Duplicate payment

bull Receipt of Medicare payments when another payor had the primary responsibility for payment

56

Questions to MAC

bull Does the Medicare credit balance report change with this overpayment rule

bull No Medicare Credit Balances are still required at the end of each quarter

bull Will that still be the communication to let CMS or the MAC know that we have received an overpayment

bull Submission of Medicare Credit Balance is one form of communicating overpayments to CMS Other methods include submitting a voluntary refund with required claim information or the submission of a standard overpayment form

57

Questions to MAC

bull Will the MAC still deduct from a future RAbull If the recovery of the overpayment includes adjusting a claim then

the overpayment would be netted against future claims payments and reflected on the RA

bull Or will that process change with this new rulebull Process will remain the samebull Will NGS send communication out on thisbull Yes NGS will communicate this once the final rule is communicated

to the MACs by CMS However this could change depending on final CMS instructions

58

Final Rule on Returning Credits

bull Providers will want to immediately update their current policies governing overpayments in order to comply with this new rule which will take effect on March 14 2016

bull Providers and suppliers are required to use reasonable diligence to investigate credible information regarding overpayments through both proactive compliance efforts and reactive investigations

bull If an overpayment is identified then it must be repaid within 60 days An overpayment is identified when a person has or should have through the exercise of reasonable diligence determined that the person received an overpayment and quantified the amount

bull Providers and suppliers have a maximum of 8 months to report and return overpayments ndash up to 6 months to investigate and quantify the overpayment (ie to identify it) and up to 60 days to report and return the overpayment

59

Final Rule on Returning Credits

bull Providers and suppliers are required to report and return all overpayments within a 6-year lookback period

bull The cause and amount of the overpayment is irrelevant for the determination eg it was due to a mistake it was someone elsersquos fault it is a minor amount An overpayment is an overpayment and must be returned

bull Providers and suppliers must make their own determination to which entity to report and return the overpayment ie to the Medicare contractor or using the OIG Self Disclosure Protocol or the CMS Self Referral Disclosure Protocol

60

Final Rule on Returning Credits

bull Providers and suppliers may use the claims adjustment credit balance self-reported refund process or another appropriate process to report and return overpayments At this time there is no standard refund form to use

bull Failure to report and return an overpayment could subject the provider or supplier to False Claims Act liability Civil Monetary Penalties Law liability and exclusion from federal health care programs

61

P S amp R-Accountants will be asking for this information

The location you login into has changed it is now on EIDM EIDM is the acronym for CMS Enterprise Identity Management system which includes Identity Verification Access Management Authorization Assistance Workflow Tools and Identity Lifecycle Management functions

httpswwwcmsgovResearch-Statistics-Data-and-SystemsCMS-Information-TechnologyIACSCMS-Applications-Loginhtml

Go down the page and click on the PSampRSTARThis will take you to the login pagewill look the same as the old P S amp R didChanges Affecting PSampR System Access (Please Read) (posted 01292015)(Updated 5262015)is changingThe system which controls your PSampR user ID (currently IACS)The new system is referred to as EIDMThis will result in a different way to create new accounts or change passwords to existing accountsIf you already have an account in EIDM you may have to use that account for accessing PSampR after the transitionWhen is the change effectiveJune 13 2015What is staying the sameThe internet address for accessing PSampR remains the sameThe PSampR systemfunctionality is NOT changing 62

Medicare Advantage Payorsbull Medicare Advantage payors are pullingdenying payments on admissions if the patient was readmitted within 30 days after discharge The

client believes that the payors systematically denying payments for all readmissions within 30 days They believe this practice denies them due process to address whether the readmissions were justified and not due to a premature discharge of patient The payors seem to want to act like a QIO without having the same accountabilities of the QIO related to determinations of non-payment

bull Heres the QIO process under section 4240 of the QIO Manualbull 4240 - Readmission Review - (Rev 2 07-11-03)bull Readmission review involves admissions to an acute general short-term hospital occurring less than 31 calendar days from the date of

discharge from the same or another acute general short-term hospital (see sect1154(a)(13) and 42 CFR 47671(a)(8)(ii)) Neither the day of discharge nor the day of admission is counted when determining whether a readmission has occurred

bull A Medical Review Proceduresbull Obtain the appropriate medical records for the initial admission and readmission Perform case review on both stays Analyze the cases

specifically to determine whether the patient was prematurely discharged from the first confinement thus causing readmission Perform an analysis of the stay at the first hospital to determine the cause(s) and extent of any problem(s) (eg incomplete or substandard treatment) Consider the information available to the attending physician who discharged the patient from the first confinement Do not base a determination of a premature discharge on information that the physician or provider could not have known or events that could not have been anticipated at the time of discharge

bull Review both the initial admission and the readmission at the same time unless one of them has previously been reviewed In these cases use at a minimum the PRAF case summary of the other admission in addition to the medical record of the case under review

bull C Denialsbull Deny readmissions under the following circumstancesbull If the readmission was medically unnecessarybull If the readmission resulted from a premature discharge from the same hospital orbull If the readmission was a result of circumvention of PPS by the same hospital (see sect4255)bull With the QIO process there is an appeal within the QIO here the hospital is getting no opportunity to challenge the denials

63

Medicare Provider Enrollment Feebull Provider Enrollment Application Fee Amount for CY 2016bull On December 3 CMS issued a notice Provider Enrollment Application

Fee Amount for CY 2016 [CMSndash6066ndashN] Effective January 1 2016 the CY 2016 application fee is $554 for institutional providers that are

bull Initially enrolling in the Medicare or Medicaid program or the Childrens Health Insurance Program (CHIP)

bull Revalidating their Medicare Medicaid or CHIP enrollmentbull Adding a new Medicare practice locationbull This fee is required with any enrollment application submitted from

January 1 through December 31 2016

64

Medicare MAC-Higlas

bull Effective 142016 CMS has implemented a change to begin netting (offsetting) provider money across workloads within a single organization What this means is that any related providers conducting business in two different workloads (example New York and Maine) will have their money applied to any account receivables (AR) with a remaining balance owed to Medicare within both workloads For example Provider ABC is located in New York and is scheduled to receive a payment of $1000 on todays remittance advice Provider XYZ is related to provider ABC but is located in Maine and has ARs with a balance owed of $200 Provider ABCs $1000 payment will have the $200 applied against provider XYZs ARs resulting in a net payment of $800 This will be reflected on the remittance advice by the same PLB code as seen today for offsets for the $200

65

Two Midnight RuleChange January 1 2016 httpswwwcmsgovMedicareMedicare-Fee-for-Service-PaymentHospitalOutpatientPPSHospital-Outpatient-Regulations-and-Notices-ItemsCMS-1633-FChtml

66

Two Midnight Rulebull However effective January 1 2016 CMS will allow exceptions to the

Two-Midnight Benchmark to be determined on a case-by-case basis by the physician responsible for the care of the beneficiary subject to medical review Said differently Part A payment may be appropriate in some circumstances even though there is no expectation by the physician (or qualified ordering practitioner) of a two-midnight stay and one of the two pre-existing categorical exceptions (CMS ldquoinpatient onlyrdquo list and newly initiated mechanical ventilation) does not apply CMS has indicated that this change to the Two Midnight Rule is in response to stakeholder concern and CMSrsquos continued efforts to develop the most appropriate standard for determining Medicare Part A payment

67

Two Midnight Rulebull A new 42 CFR sect4123(a) provides that a patient is considered an

inpatient of a hospitalhellipif formally admitted as an inpatient pursuant to an order for inpatient admission by a physician or other qualified practitionerhellip The physician orders inpatient status when he or she expects the patient to require a stay that crosses at least 2 midnights[10] Stays expected to be shorter than at least two midnights are generally inappropriate for inpatient admission and inpatient payment under Medicare Part A unless the surgical procedure is specified by Medicare as inpatient only under sect41922(n)[11] The physicians expectationhellipshould be based on such complex medical factors as patient history and comorbidities the severity of signs and symptoms current medical needs and the risk of an adverse event[12] The physician order is part of physician certification of the medical necessity of hospital inpatient serviceshellip[13]

68

InPatient Vs Observation Conthellip

bull Physician certification which begins with an order for inpatient admission requires the physician to certify the reasons for the hospitalization the estimated time the patient will remain in the hospital and plans for post-hospital care if appropriate[14] The certification must be completed signed and documented in the medical record prior to discharge[15]

bull A physicians admission order has no presumptive weight and both the admission order and the physician certification will be evaluated in the context of the evidence in the medical record[16] CMS intends to provide additional information about what evidence in the medical record means in future instructions and manual revisions[17]

69

Two Midnight Rulebull Although the new case-by-case exception appears to be inherently

subjective to a certain extent CMS states that the following factors (among others) would be relevant to determining whether a patient requires inpatient admission under the expanded policy

bull The severity of the signs and symptoms exhibited by the patient bull The medical predictability of something adverse happening to the patient

and bull The need for diagnostic studies that appropriately are outpatient services

(that is their performance does not ordinarily require the patient to remain at the hospital for 24 hours or more)

bull CMS also notes that an inpatient admission (and Part A payment) should be ldquorare and unusualrdquo for minor surgical procedures or other treatment that is expected to keep the patient in the hospital ldquofor only a few hoursrdquo or for a period of time that ldquodoes not span at least overnightrdquo (thus a subset of stays not meeting the Two Midnight Benchmark) CMS indicates that such cases will be prioritized for medical review

70

Health Data Insights amp Medicare Plus Blue

RAC (Retrospective Audits)

71

HDI Health Data amp Med Plus Blue

bull httpwwwhealthdatainsightscombull Blue Cross Medicare Advantage Auditsbull Facilities seeing 10 to 15 requests for Medical Recordsbull In January amp Feburarybull Selected Health Data Insights because they were a premier Audit

Vendor for CMS Recovery Audit Contractor (RAC) demonstration Project They are a audit vendor for Humana

bull Providers not sending Medical Record will get technical denial and lose payments

72

Health Data InSight

bull In 2010 they began the Hospital Reviewbull Medicare Advantage encounter datandashCMS oversight of data integrity OIG

2016bull We will review CMSs oversight of MA encounter data validation and assess

the extent to which CMSrsquos Integrated Data Repository contains timely valid and complete MA encounter data In 2012 CMS began collecting from MA organizations a more comprehensive set of encounter data reflecting the items and services provided to MA plan enrollees Prior CMS and OIG audits have indicated vulnerabilities in the accuracy of data reporting by MA organizations Realizing the potential benefits of the MA encounter data for payment and program integrity oversight is contingent upon the datarsquos completeness validity and timeliness (OEI 03-15-00060 expected issue date FY 2017)

73

Pepper Reports

bull httpswwwpepperresourcesorg

bull Program for Evaluating Payment Patterns Electronic Report ( PEPPER)

bull Annually on or about April 18 2016 will be released

bull Pepper Portal httpssecurefiletmforg

74

CGI Technologies and Solutions Inc httpracbcgicomContactInfoaspxst=1

bull Indiana bull Michiganbull Minnesotabull Illinoisbull Kentuckybull Ohiobull Wisconsin CGI Technologies and Solutions Incbull For general and administrative questions regarding client service outreach

quality assurance or project-specific issues contactbull 1877316RACB (7222)bull Email racbcgicom Tamara Tate Tamaratatecmshhsgovbull 4107861288

75

CGI Federal RAC

bull CGI Federal RAC Region Bbull Email racbcgicombull Phone 1-877-316-RACB (7222)bull Mailing Addressbull Send medical records as followsbull Medical records for Indiana Illinois Kentucky Michigan Ohio Wisconsin

Minnesota DME and Home Health CGI Federal Inc Attn RACB Imaging Dept 1001 Lakeside Ave Suite 800 Cleveland OH 44114

bull If submitting paper records please send medical records as follows For Therapy Reviews CGI Federal Inc Attn RACB Imaging 1001 Lakeside Avenue Suite 800 Cleveland OH 44114

76

How to survive RAC Audit

bull National health expenditures totaled $1679 Billion in 2003 bull National health expenditures were 153 of GROSS Domestic Product

(GDP) in 2003 bull Health care cost increasing at +9 per year bull Doomsday predictions of Medicare running out bull Congressional Action

77

RAC Audits

bull Medicare Modernization Act (MMA) of 2003Mandated a three year audit demonstration project 2005-2008

bull Appoint audit contractors to review Medicare billings for proper coding DRG assignment and medical necessity

bull Audits will apply to all health care providers (hospitals physicians homecare dme etc)

bull Audit contractors to be paid on a contingency basis a percentage of overpayments recovered

78

How Did we get here

bull Overpayments collected due to errors in Medically Unnecessary Services ndash 40

bull Incorrectly Coded ndash 35

bull Other ndash 17

bull NoInsufficient Documentation ndash 8

79

Where are we now

bull All RACrsquos completed required provider outreachAccess to Medicare billing data base given to all RAC RAC review methodology

bull Automated Review-Black amp White Issues (current) bull DRG Validation-complex review (current) bull Complex Review for coding errors (current) bull DME Medical Necessity Reviews ndashcomplex review (calendar year

2010) bull Medical Necessity Reviews-complex review (calendar year 2010)

80

RAC Reviews

bull Responsibilities of the Team Leader bull Must learn each insurance provider participating in a RAC or RAC type

program bull What are their operating rulesbull What is their appeal process Time limits

May be different process for each insurance provider bull Develop a response team

Identify who does what when why and alternate bull individual

Build and develop a manual process Review of computerized system

81

Priority Health SCIO Health Analytics

bull httpswwwsciohealthanalyticscomcore-capabilitiespayment-integrityfacility-auditsskilled-nursing-facility-audits

bull Claims for Medicare members treated at Skilled Nursing Facilities are reimbursed based on the patientsrsquo RUG (Resource Utilization Group) score which is determined using the Minimum Data Set (MDS) Using SCIOs robust analytics claims andor providers that merit review are selected for audit SCIOs auditors conduct a detailed review of the complete medical record and associated MDS to determine if the billed RUG score is valid In the event the review determines that an incorrect RUG score was billed SCIOreg provides the valid score reports the reason the change was necessary and calculates the resulting overpayment

82

+ Cheer

Onward and Upward she shall prevail We are here to care for the residents and provide a wonderful

service

13 83

84

References

bull Priority Healthbull Blue Crossbull Medicaidbull Medicare

85

  • Medicare Mange Care amp Medicaid Changes in the New World We Live In
  • Medicaid
  • NEW Medicaid Change MIlogin
  • Blueprint for Health Innovation MI
  • Provider Enrollment Electronic Signature Form Submission Process MSA 15-54
  • Provider Enrollment Electronic Signature Form Submission Process
  • Provider Enrollment Domain Administrator
  • Medicaid Coinsurance Medicare Advantage
  • Slide Number 9
  • Lawsuit DHS Changes on Caregivers
  • TPL Medicaid Change
  • CHAMPS Member Screen
  • LOC dropping off Not Due to MI Health
  • Issues
  • Secure Email Information
  • Medicaid amp Hospice
  • Medicaid
  • Medicaid Medicare Buy In
  • Manage Medicaid
  • Healthy Michigan Residents
  • Healthy Michigan Medicaid Days
  • McLaren Health Plan
  • Manage Medicaid Plans January 1
  • Slide Number 24
  • MI Health Link
  • MI Health Link 2565
  • What are the Names
  • MI Health Dual Eligible
  • MI Health LOC
  • LOC Medicaid
  • Medicaid Redetermination and MHL Enrollment
  • MI Health Link Portals
  • MI Health Authorizations
  • MI Health Issues
  • LOC 02 dropping MI Health Issues
  • PPA Offset
  • LOCD
  • MI Health Issues-New
  • ACO
  • Families Receiving Letters for ACO
  • ACO What is It
  • Payroll Based Journal
  • Slide Number 43
  • If you submit data manually should you also submit it through the XML
  • Staffing Submission Frequently Asked Questions
  • CMS defines
  • Slide Number 47
  • PBJ Medical Director Role
  • PBJ Medical Director Role
  • Dietician
  • Pharmacy Consultant
  • What are the names for the Medicare Number
  • QTSO
  • Medicare Update
  • CMS Final Rule On Returning Credits
  • Over Payment Rule
  • Questions to MAC
  • Questions to MAC
  • Final Rule on Returning Credits
  • Final Rule on Returning Credits
  • Final Rule on Returning Credits
  • Slide Number 62
  • Medicare Advantage Payors
  • Medicare Provider Enrollment Fee
  • Medicare MAC-Higlas
  • Two Midnight Rule
  • Two Midnight Rule
  • Two Midnight Rule
  • InPatient Vs Observation Conthellip
  • Two Midnight Rule
  • Health Data Insights amp Medicare Plus Blue
  • HDI Health Data amp Med Plus Blue
  • Health Data InSight
  • Pepper Reports
  • CGI Technologies and Solutions Inc httpracbcgicomContactInfoaspxst=1
  • CGI Federal RAC
  • How to survive RAC Audit
  • RAC Audits
  • How Did we get here
  • Where are we now
  • RAC Reviews
  • Priority Health SCIO Health Analytics
  • Cheer
  • References
Page 18: Medicare, Mange Care & Medicaid Changes in the New World we live in

Medicaid Medicare Buy Inbull Based on the information from the Office of Personnel Management Federal

Employeersquos employed as of January 1 1983 are eligible for Medicare Part A(see page 5 of attached document) This was also confirmed with our Social Security liaison If the beneficiary did not retire before 1983 he can enroll in Medicare Part B and pay the premium and then he can enroll in Medicare Part A and pay that premium as well or may qualify for Medicare Buy in of Part A

bull If a beneficiary has an SSA document stating they are not eligible for Medicare as they do not have enough work credits the beneficiarybeneficiary representative needs to go to SSA and let them know that while they know they are not eligible for Medicare Part A free or reduced however they are eligible for Medicare Part B and would like to enroll Once the beneficiary enrolls in Medicare Part B (enrollment period January 1st ndash March 31 each year) and pays the premium then the beneficiary is eligible to either pay for Medicare Part A or that beneficiary may qualify for Medicare Part A buy in through Medicaid Once the beneficiary is enrolled in Medicare Part A and Medicare Part B Medicaid will begin to make payments on claims

18

Manage Medicaid Where are we

19

Healthy Michigan Residents

20

Healthy Michigan Medicaid Days

21

McLaren Health Plan

22

Manage Medicaid Plans January 1bull Region 1 ndash Upper Peninsula Health Planbull Region 2 ndash McLaren Health Plan Meridian Health Plan of Michigan Molina Healthcare of Michigan

UnitedHealthcare Community Planbull Region 3 ndash McLaren Health Plan Meridian Health Plan of Michigan Molina Healthcare of Michigan

UnitedHealthcare Community Planbull Region 4 ndash Blue Cross Complete of Michigan McLaren Health Plan Meridian Health Plan of Michigan Molina

Healthcare of Michigan Priority Health Choice UnitedHealthcare Community Planbull Region 5 ndash McLaren Health Plan Meridian Health Plan of Michigan Molina Healthcare of Michigan

UnitedHealthcare Community Planbull Region 6 ndash Blue Cross Complete of Michigan HAP Midwest Health Plan McLaren Health Plan Meridian Health

Plan of Michigan Molina Healthcare of Michigan UnitedHealthcare Community Planbull Region 7 ndash Blue Cross Complete of Michigan McLaren Health Plan Meridian Health Plan UnitedHealthcare

Community Planbull Region 8 ndash Aetna Better Health of Michigan McLaren Health Plan Meridian Health Plan of Michigan Molina

Healthcare of Michigan Priority Health Choice UnitedHealthcare Community Planbull Region 9 ndash Aetna Better Health of Michigan Blue Cross Complete of Michigan McLaren Health Plan Meridian

Health Plan of Michigan Molina Healthcare of Michigan UnitedHealthcare Community Planbull Region 10 ndash Aetna Better Health of Michigan Blue Cross Complete of Michigan Harbor Health Plan McLaren

Health Plan Meridian Health Plan of Michigan Molina Healthcare of Michigan Total Health Care UnitedHealthcare Community Plan 23

24

MI Health LinkWhere are we

25

MI Health Link 2565

bull This notification is being sent to providers of long term care services including nursing facilities county medical care facilities and hospital long term care units to provide clarification on the process involved with the submission of the Facility Admission Form (MSA-2565-C) for an individual enrolled in the MI Health Link program

bull The MI Health Link program covers the custodiallong term nursing facility service benefit When an individual who is enrolled in the MI Health Link program is admitted to a nursing facility for custodiallong term nursing services a disenrollment from the Integrated Care Organization (MI Health Link health plan) is NOT REQUIRED The Facility Admission Form (MSA-2565-C) should NOT be sent to the Michigan Department of Health and Human Services (MDHHS) Enrollment Services Section for a disenrollment to be processed

26

What are the Names

bull Started as Integrated Health

bull Then called MMP (Medicare Medicaid Program)

bull Duals (Also Known as Duals as in Dual Eligible)

bull Now called MI Health Link

bull Total confusion

27

MI Health Dual Eligible28

MI Health LOC

29

LOC Medicaidbull We have the new pilot program which started on March

1 2015 in Southwest Michigan Region 4 Counties Macomb Wayne and the UP You could see these patients they are dual eligible in the Pilot program in counties surrounding the pilot

bull MHL-LOC 005 (All other Facilities) or LOC 015 (County Care) These residents have to call Michigan Enrolls to dis-enroll toll-free at 1-800-975-7630 (TTY 1-888-263-5897) Monday-Friday from 8 AM to 7 PM Once they dis-enroll they will go to a LOC 02 you have to do a new LOCD

30

Medicaid Redetermination and MHL Enrollmentbull At the time of re-determination for Medicaid financial eligibility the MI

Health Link (MHL) program will not be sending beneficiaries information about this program Beneficiaries who previously opted out will not be passively enrolled according to an email from the MHL staff The MHL staff wrote

bull ldquoThere is currently no MI Health Link enrollment letter sent to beneficiaries when eligibility is re-determined A person who becomes eligible for MI Health Link enrollment may opt-in at any time

bull When Medicaid re-determination takes place the beneficiary remains in the same ICO unless that beneficiary lost Medicaid coverage If the enrollee loses Medicaid coverage and later regains it they are not passively enrolled into MI Health Link The beneficiary may choose to opt back in to the program at that time if desiredrdquo

bull MHL staff did state that about 1500 beneficiaries will be passively enrolled effective January 1 2016 These specific individuals were given normal notice of 60 and 30 days in which to opt-in or opt-out if they so chose No other large scale passive enrollment is scheduled according to the MHL staff 31

MI Health Link Portals

bull Meridian Health Planbull httpwwwmhplancommibull Amerihealthbull httpwwwamerihealthcaritasvipcarepluscomproviderself-service-

toolsindexaspxbull AetnaCoventrybull httpwwwaetnabetterhealthcomMichiganprovidersportalbull Molinabull httpwwwmolinahealthcarecommembersmien-usmemPageshomeaspxbull HAPMidwestbull httpswwwmidwesthealthplancomLoginaspxbull FidelisCentenebull wwwfidelissccommmp 32

MI Health Authorizationsbull We need to watch these authorization that the plans are giving us for the MI

Health program Some plans are assigning a diagnosis for residents in their prior authorizations They are assigning diagnosis that the residents do not even have You need to make sure these are correct diagnosis and if not you need to work with the case managers of the plans to fix the issue The authorization numbers do change

bull Make sure that any resident that is in a MI Health plan that you have a prior authorization All plans are giving different periods authorizing the residents stay in the facility You need to set up a system to make sure you always have a authorization for the period of time you are rendering the service Here is an example of time frame of authorizations

bull Meridian is authorizing 12 monthsbull Aetna is authorizing 3 monthsbull Molina is authorizing 6 monthsbull The authorization numbers need to go on your claims to the payer You need to

put the authorizations in your software and track the dates

33

MI Health Issuesbull We are seeing some issues with MI Health where the resident does not have the correct LOC or it shows

up correct on CHAMPS but ancillary providers such as Dentist and such cannot see it I think we still have some issues with the information crossing between Bridges DHS system CMS and CHAMPS It in return is creating some access of care issues If it is a true LOC issues Facilities with LOC issues need to submit the Medicaid ID numbers to the MSA-MHL-EnrollmentMichigangov box with the subject line Nursing home LOC Issue so they may work to resolve the issues

bull If it becomes an access to care issue email the information to INTEGRATEDCAREmichigangov Remember in these emails only send the Medicaid ID and explain the situation The State will work with the plans to try to fix the process or improve the process

bull We are also seeing with new admission with LOC 015 or 005 that the plans are stating they have 14 days to authorize admission These are resident in the emergency room and possibly be admitted to you for Rehab The hospital will not keep the resident in ER for 14 days and you cannot admit the resident until you have a prior authorization I would recommend when you are told this by the plan that you need to ask to speak to a manager We will have to work through this

bull Ancillary Provider You need to work with your ancillary providers such as Lab Pharmacy X-Ray Physician and such to get the to be credentialed with the plans We are hearing that some of the pharmacies are not participating with the plans this will create issues for you so I would continue to ask these groups to participate

34

LOC 02 dropping MI Health Issuesbull The passive enrollments have occurred in Macomb amp Wayne for

Medicaid dual eligible We are having the same issue we did as in the Southwest MI amp UP with the passive enrollments I am starting to hear from facilities who are checking there CHAMPS member screens that those residents that have opted out (some residents not all) have lost there 02 Make sure you are checking your CHAMPS member screen both for those that were passively enrolled and those that might have lost there 02 Medicaid that opted out

bull Facilities with LOC issues need to submit the Medicaid ID numbers to the (Only MI Health)MSA-MHL-Enrollmentmichigangov box with the subject line Nursing home LOC Issue so they may work to resolve the issues

35

PPA Offset

bull There are no co-pays deductibles or premiums in MI Health Link so there should be no need to offset the PPA with code 25 MI Health Link enrollees can continue to offset their PPA for non-program covered medical expenses (like Vision-Code 27 Dental-Code 28 and Hearing-Code 26) and use the appropriate codes to offset the PPA when billing the health plan for nursing facility services

bull Resident pay PPA when MedicareMedicaid coinsurance

36

LOCDbull Nursing Facility Level of Care Determination (NFLOCD)

bull The MI Health Link health plan will be responsible for conducting the Michigan Medicaid NFLOCD tool for enrollees seeking admission to a nursing facility For existing residents at the time of enrollment the existing NFLOCD will be adopted for capitation payment purposes The health plan will complete a new NFLCOD tool within the first 90 days of enrollment If a nursing facility resident is disenrolled from MI Health Link the nursing facility will be responsible for conducting a new NFLOCD tool in accordance with published Medicaid policy

37

MI Health Issues-New

bull INTEGRATEDCAREmichigangov

bull Email with Insurance Plan issues Case Manager Issues

38

ACOWhat are they

39

Families Receiving Letters for ACO

40

ACO What is It

bull Whats an ACObull Accountable Care Organizations (ACOs) are groups of doctors hospitals

and other health care providers who come together voluntarily to give coordinated high quality care to their Medicare patients

bull The goal of coordinated care is to ensure that patients especially the chronically ill get the right care at the right time while avoiding

unnecessary duplication of services and preventing medical errorsbull When an ACO succeeds both in delivering high-quality care and

spending health care dollars more wisely it will share in the savings it achieves for the Medicare program

41

Payroll Based JournalMandatory on July 1 2016Internet Explorer Version

Internet Explorer v 10 and v 11 will need to operate in compatibility mode

42

43

If you submit data manually should you also submit it through the XML

bull Now you have three options

bull Submit Manually only

bull Submit through the XML only

bull You are able to submit manually and using the XML

44

45

Staffing Submission Frequently Asked Questions

bull ldquoWho are direct care staffrdquo (Who do we submit data for)bull Submission of data for contract staffbull Medical directors and consultantsbull Staff switching roles or tasks throughout the daybull Hours paid vs hours worked ndash Must be verifiablebull Public postingQuality MeasuresFive Starbull Enforcementbull Voluntary submission risks (noneSo register now)

CMS defines

bull 37 job title codes that are required to match employees to the number of hours each direct care function was performed It is important to work with your teams to define the workers that contribute to each job type and how those daily worked hours are recorded and converted to a PBJ submission

bull The PBJ does include some more specific job descriptions than the 671 For example the PBJ system includes job descriptions for RNs with administrative duties and LPNs with administrative duties versus the 671rsquos more general ldquoNurses with Administrative Duties

Page 46

47

PBJ Medical Director Rolebull Physician Leadership

bull Help the facility ensure that patients have appropriate physician coverage and ensure the provision of physician and health care practitioner services and

bull Help the facility develop a process for reviewing physician and health care practitioner credentials

bull Provide specific guidance for physician performance expectations

bull Help the facility ensure that a system is in place for monitoring the performance of health care practitioners and

bull Facilitate feedback to physicians and other health care practitioners on performance and practices

bull Patient Care - Clinical Leadership

bull Participate in administrative decision-making and the development of policies and procedures related to patient care

bull Help develop approve and implement specific clinical practices for the facility to incorporate into its care-related policies and procedures including areas required by laws and regulations

bull Develop procedures and guidance for facility staff regarding contacting practitioners including information gathering and presentation change in condition assessment and when to contact the medical director

bull Review consider andor act upon consultant recommendations as appropriate that affect the facilitys resident care policies and procedures or the care of an individual resident

bull Review respond to and participate in federal state local and other external surveys and inspections and

bull Help review policies and procedures regarding the adequate protection of patients rights advance care planning and other ethical issues48

PBJ Medical Director Rolebull Quality of Care

bull Help the facility establish systems and methods for reviewing the quality and appropriateness of clinical care and other health-related services and provide appropriate feedback and

bull Participate in the facilitys quality improvement process

bull Advise on infection control issues and approve specific infection control policies to be incorporated into facility policies and procedures

bull Help the facility provide a safe and caring environment

bull Help promote employee health and safety and

bull Assist in the development and implementation of employee health policies and programs

bull Education Information and Communication

bull Promote a learning culture within the facility by educating informing and communicating

bull Provide information to help the facility provide care consistent with current standards of practice (defined as approaches to care procedures techniques and treatments that are based on research and or expert consensus and that are contained in current manuals textbooks and or publications or that are accepted adopted or promulgated by recognized organizations or national bodies)

bull Help the facility develop medical information and communication systems with staff patients and families and others

bull Represent the facility to the professional and lay community on medical and patient care issues

bull Maintain knowledge of the changing social regulatory political and economic factors that affect medical and health services of long term care patients and

bull Help establish appropriate relationships with other health care organizations

49

Dietician

bull When the dietary or food services supervisor is other than a registered dietitian the supervisor shall receive routine consultation and technical assistance from a registered dietitian (RD) Consultation time shall not be less than 4 hours every 60 days Additional consultation time may be needed based on the total number of patients incidence of nutrition-related health problems and food service management needs of the facility

50

Pharmacy Consultant

bull At least once per month a licensed pharmacist must perform a drug regimen review (DRR) for each resident The pharmacist must report any irregularities to the attending physician or director of nursing Furthermore these reports must be acted upon

51

What are the names for the Medicare Numberbull OSCAR -Online Survey Certification and Reporting

bull PTAN-PTAN number is assigned by Medicare to authenticate the provider when using the local Medicare Administrative Contractorrsquos (MAC) self-help tools like the IVR internet portal on-line application status etc Provider Transactions Access Number

bull CCN- CMS Certification Number

bull Medicare Number- example 23-

bull All of the above mean the same thing

52

QTSO

bull Once you are logged in the QTSO site bull You will have a state login to the site to access the various site specific

to your facilitybull Installing you will need administrator rights to your network

53

Medicare UpdateWhat are we seeing

54

CMS Final Rule On Returning Credits

httpswwwfederalregistergovarticles201602122016-02789medicare-program-reporting-and-returning-of-overpayments

55

Over Payment Rule

bull Medicare payments for non covered services

bull Medicare payments in excess of the allowable amount for an identified covered service

bull Errors and non reimbursable expenditures in cost reportsbull Duplicate payment

bull Receipt of Medicare payments when another payor had the primary responsibility for payment

56

Questions to MAC

bull Does the Medicare credit balance report change with this overpayment rule

bull No Medicare Credit Balances are still required at the end of each quarter

bull Will that still be the communication to let CMS or the MAC know that we have received an overpayment

bull Submission of Medicare Credit Balance is one form of communicating overpayments to CMS Other methods include submitting a voluntary refund with required claim information or the submission of a standard overpayment form

57

Questions to MAC

bull Will the MAC still deduct from a future RAbull If the recovery of the overpayment includes adjusting a claim then

the overpayment would be netted against future claims payments and reflected on the RA

bull Or will that process change with this new rulebull Process will remain the samebull Will NGS send communication out on thisbull Yes NGS will communicate this once the final rule is communicated

to the MACs by CMS However this could change depending on final CMS instructions

58

Final Rule on Returning Credits

bull Providers will want to immediately update their current policies governing overpayments in order to comply with this new rule which will take effect on March 14 2016

bull Providers and suppliers are required to use reasonable diligence to investigate credible information regarding overpayments through both proactive compliance efforts and reactive investigations

bull If an overpayment is identified then it must be repaid within 60 days An overpayment is identified when a person has or should have through the exercise of reasonable diligence determined that the person received an overpayment and quantified the amount

bull Providers and suppliers have a maximum of 8 months to report and return overpayments ndash up to 6 months to investigate and quantify the overpayment (ie to identify it) and up to 60 days to report and return the overpayment

59

Final Rule on Returning Credits

bull Providers and suppliers are required to report and return all overpayments within a 6-year lookback period

bull The cause and amount of the overpayment is irrelevant for the determination eg it was due to a mistake it was someone elsersquos fault it is a minor amount An overpayment is an overpayment and must be returned

bull Providers and suppliers must make their own determination to which entity to report and return the overpayment ie to the Medicare contractor or using the OIG Self Disclosure Protocol or the CMS Self Referral Disclosure Protocol

60

Final Rule on Returning Credits

bull Providers and suppliers may use the claims adjustment credit balance self-reported refund process or another appropriate process to report and return overpayments At this time there is no standard refund form to use

bull Failure to report and return an overpayment could subject the provider or supplier to False Claims Act liability Civil Monetary Penalties Law liability and exclusion from federal health care programs

61

P S amp R-Accountants will be asking for this information

The location you login into has changed it is now on EIDM EIDM is the acronym for CMS Enterprise Identity Management system which includes Identity Verification Access Management Authorization Assistance Workflow Tools and Identity Lifecycle Management functions

httpswwwcmsgovResearch-Statistics-Data-and-SystemsCMS-Information-TechnologyIACSCMS-Applications-Loginhtml

Go down the page and click on the PSampRSTARThis will take you to the login pagewill look the same as the old P S amp R didChanges Affecting PSampR System Access (Please Read) (posted 01292015)(Updated 5262015)is changingThe system which controls your PSampR user ID (currently IACS)The new system is referred to as EIDMThis will result in a different way to create new accounts or change passwords to existing accountsIf you already have an account in EIDM you may have to use that account for accessing PSampR after the transitionWhen is the change effectiveJune 13 2015What is staying the sameThe internet address for accessing PSampR remains the sameThe PSampR systemfunctionality is NOT changing 62

Medicare Advantage Payorsbull Medicare Advantage payors are pullingdenying payments on admissions if the patient was readmitted within 30 days after discharge The

client believes that the payors systematically denying payments for all readmissions within 30 days They believe this practice denies them due process to address whether the readmissions were justified and not due to a premature discharge of patient The payors seem to want to act like a QIO without having the same accountabilities of the QIO related to determinations of non-payment

bull Heres the QIO process under section 4240 of the QIO Manualbull 4240 - Readmission Review - (Rev 2 07-11-03)bull Readmission review involves admissions to an acute general short-term hospital occurring less than 31 calendar days from the date of

discharge from the same or another acute general short-term hospital (see sect1154(a)(13) and 42 CFR 47671(a)(8)(ii)) Neither the day of discharge nor the day of admission is counted when determining whether a readmission has occurred

bull A Medical Review Proceduresbull Obtain the appropriate medical records for the initial admission and readmission Perform case review on both stays Analyze the cases

specifically to determine whether the patient was prematurely discharged from the first confinement thus causing readmission Perform an analysis of the stay at the first hospital to determine the cause(s) and extent of any problem(s) (eg incomplete or substandard treatment) Consider the information available to the attending physician who discharged the patient from the first confinement Do not base a determination of a premature discharge on information that the physician or provider could not have known or events that could not have been anticipated at the time of discharge

bull Review both the initial admission and the readmission at the same time unless one of them has previously been reviewed In these cases use at a minimum the PRAF case summary of the other admission in addition to the medical record of the case under review

bull C Denialsbull Deny readmissions under the following circumstancesbull If the readmission was medically unnecessarybull If the readmission resulted from a premature discharge from the same hospital orbull If the readmission was a result of circumvention of PPS by the same hospital (see sect4255)bull With the QIO process there is an appeal within the QIO here the hospital is getting no opportunity to challenge the denials

63

Medicare Provider Enrollment Feebull Provider Enrollment Application Fee Amount for CY 2016bull On December 3 CMS issued a notice Provider Enrollment Application

Fee Amount for CY 2016 [CMSndash6066ndashN] Effective January 1 2016 the CY 2016 application fee is $554 for institutional providers that are

bull Initially enrolling in the Medicare or Medicaid program or the Childrens Health Insurance Program (CHIP)

bull Revalidating their Medicare Medicaid or CHIP enrollmentbull Adding a new Medicare practice locationbull This fee is required with any enrollment application submitted from

January 1 through December 31 2016

64

Medicare MAC-Higlas

bull Effective 142016 CMS has implemented a change to begin netting (offsetting) provider money across workloads within a single organization What this means is that any related providers conducting business in two different workloads (example New York and Maine) will have their money applied to any account receivables (AR) with a remaining balance owed to Medicare within both workloads For example Provider ABC is located in New York and is scheduled to receive a payment of $1000 on todays remittance advice Provider XYZ is related to provider ABC but is located in Maine and has ARs with a balance owed of $200 Provider ABCs $1000 payment will have the $200 applied against provider XYZs ARs resulting in a net payment of $800 This will be reflected on the remittance advice by the same PLB code as seen today for offsets for the $200

65

Two Midnight RuleChange January 1 2016 httpswwwcmsgovMedicareMedicare-Fee-for-Service-PaymentHospitalOutpatientPPSHospital-Outpatient-Regulations-and-Notices-ItemsCMS-1633-FChtml

66

Two Midnight Rulebull However effective January 1 2016 CMS will allow exceptions to the

Two-Midnight Benchmark to be determined on a case-by-case basis by the physician responsible for the care of the beneficiary subject to medical review Said differently Part A payment may be appropriate in some circumstances even though there is no expectation by the physician (or qualified ordering practitioner) of a two-midnight stay and one of the two pre-existing categorical exceptions (CMS ldquoinpatient onlyrdquo list and newly initiated mechanical ventilation) does not apply CMS has indicated that this change to the Two Midnight Rule is in response to stakeholder concern and CMSrsquos continued efforts to develop the most appropriate standard for determining Medicare Part A payment

67

Two Midnight Rulebull A new 42 CFR sect4123(a) provides that a patient is considered an

inpatient of a hospitalhellipif formally admitted as an inpatient pursuant to an order for inpatient admission by a physician or other qualified practitionerhellip The physician orders inpatient status when he or she expects the patient to require a stay that crosses at least 2 midnights[10] Stays expected to be shorter than at least two midnights are generally inappropriate for inpatient admission and inpatient payment under Medicare Part A unless the surgical procedure is specified by Medicare as inpatient only under sect41922(n)[11] The physicians expectationhellipshould be based on such complex medical factors as patient history and comorbidities the severity of signs and symptoms current medical needs and the risk of an adverse event[12] The physician order is part of physician certification of the medical necessity of hospital inpatient serviceshellip[13]

68

InPatient Vs Observation Conthellip

bull Physician certification which begins with an order for inpatient admission requires the physician to certify the reasons for the hospitalization the estimated time the patient will remain in the hospital and plans for post-hospital care if appropriate[14] The certification must be completed signed and documented in the medical record prior to discharge[15]

bull A physicians admission order has no presumptive weight and both the admission order and the physician certification will be evaluated in the context of the evidence in the medical record[16] CMS intends to provide additional information about what evidence in the medical record means in future instructions and manual revisions[17]

69

Two Midnight Rulebull Although the new case-by-case exception appears to be inherently

subjective to a certain extent CMS states that the following factors (among others) would be relevant to determining whether a patient requires inpatient admission under the expanded policy

bull The severity of the signs and symptoms exhibited by the patient bull The medical predictability of something adverse happening to the patient

and bull The need for diagnostic studies that appropriately are outpatient services

(that is their performance does not ordinarily require the patient to remain at the hospital for 24 hours or more)

bull CMS also notes that an inpatient admission (and Part A payment) should be ldquorare and unusualrdquo for minor surgical procedures or other treatment that is expected to keep the patient in the hospital ldquofor only a few hoursrdquo or for a period of time that ldquodoes not span at least overnightrdquo (thus a subset of stays not meeting the Two Midnight Benchmark) CMS indicates that such cases will be prioritized for medical review

70

Health Data Insights amp Medicare Plus Blue

RAC (Retrospective Audits)

71

HDI Health Data amp Med Plus Blue

bull httpwwwhealthdatainsightscombull Blue Cross Medicare Advantage Auditsbull Facilities seeing 10 to 15 requests for Medical Recordsbull In January amp Feburarybull Selected Health Data Insights because they were a premier Audit

Vendor for CMS Recovery Audit Contractor (RAC) demonstration Project They are a audit vendor for Humana

bull Providers not sending Medical Record will get technical denial and lose payments

72

Health Data InSight

bull In 2010 they began the Hospital Reviewbull Medicare Advantage encounter datandashCMS oversight of data integrity OIG

2016bull We will review CMSs oversight of MA encounter data validation and assess

the extent to which CMSrsquos Integrated Data Repository contains timely valid and complete MA encounter data In 2012 CMS began collecting from MA organizations a more comprehensive set of encounter data reflecting the items and services provided to MA plan enrollees Prior CMS and OIG audits have indicated vulnerabilities in the accuracy of data reporting by MA organizations Realizing the potential benefits of the MA encounter data for payment and program integrity oversight is contingent upon the datarsquos completeness validity and timeliness (OEI 03-15-00060 expected issue date FY 2017)

73

Pepper Reports

bull httpswwwpepperresourcesorg

bull Program for Evaluating Payment Patterns Electronic Report ( PEPPER)

bull Annually on or about April 18 2016 will be released

bull Pepper Portal httpssecurefiletmforg

74

CGI Technologies and Solutions Inc httpracbcgicomContactInfoaspxst=1

bull Indiana bull Michiganbull Minnesotabull Illinoisbull Kentuckybull Ohiobull Wisconsin CGI Technologies and Solutions Incbull For general and administrative questions regarding client service outreach

quality assurance or project-specific issues contactbull 1877316RACB (7222)bull Email racbcgicom Tamara Tate Tamaratatecmshhsgovbull 4107861288

75

CGI Federal RAC

bull CGI Federal RAC Region Bbull Email racbcgicombull Phone 1-877-316-RACB (7222)bull Mailing Addressbull Send medical records as followsbull Medical records for Indiana Illinois Kentucky Michigan Ohio Wisconsin

Minnesota DME and Home Health CGI Federal Inc Attn RACB Imaging Dept 1001 Lakeside Ave Suite 800 Cleveland OH 44114

bull If submitting paper records please send medical records as follows For Therapy Reviews CGI Federal Inc Attn RACB Imaging 1001 Lakeside Avenue Suite 800 Cleveland OH 44114

76

How to survive RAC Audit

bull National health expenditures totaled $1679 Billion in 2003 bull National health expenditures were 153 of GROSS Domestic Product

(GDP) in 2003 bull Health care cost increasing at +9 per year bull Doomsday predictions of Medicare running out bull Congressional Action

77

RAC Audits

bull Medicare Modernization Act (MMA) of 2003Mandated a three year audit demonstration project 2005-2008

bull Appoint audit contractors to review Medicare billings for proper coding DRG assignment and medical necessity

bull Audits will apply to all health care providers (hospitals physicians homecare dme etc)

bull Audit contractors to be paid on a contingency basis a percentage of overpayments recovered

78

How Did we get here

bull Overpayments collected due to errors in Medically Unnecessary Services ndash 40

bull Incorrectly Coded ndash 35

bull Other ndash 17

bull NoInsufficient Documentation ndash 8

79

Where are we now

bull All RACrsquos completed required provider outreachAccess to Medicare billing data base given to all RAC RAC review methodology

bull Automated Review-Black amp White Issues (current) bull DRG Validation-complex review (current) bull Complex Review for coding errors (current) bull DME Medical Necessity Reviews ndashcomplex review (calendar year

2010) bull Medical Necessity Reviews-complex review (calendar year 2010)

80

RAC Reviews

bull Responsibilities of the Team Leader bull Must learn each insurance provider participating in a RAC or RAC type

program bull What are their operating rulesbull What is their appeal process Time limits

May be different process for each insurance provider bull Develop a response team

Identify who does what when why and alternate bull individual

Build and develop a manual process Review of computerized system

81

Priority Health SCIO Health Analytics

bull httpswwwsciohealthanalyticscomcore-capabilitiespayment-integrityfacility-auditsskilled-nursing-facility-audits

bull Claims for Medicare members treated at Skilled Nursing Facilities are reimbursed based on the patientsrsquo RUG (Resource Utilization Group) score which is determined using the Minimum Data Set (MDS) Using SCIOs robust analytics claims andor providers that merit review are selected for audit SCIOs auditors conduct a detailed review of the complete medical record and associated MDS to determine if the billed RUG score is valid In the event the review determines that an incorrect RUG score was billed SCIOreg provides the valid score reports the reason the change was necessary and calculates the resulting overpayment

82

+ Cheer

Onward and Upward she shall prevail We are here to care for the residents and provide a wonderful

service

13 83

84

References

bull Priority Healthbull Blue Crossbull Medicaidbull Medicare

85

  • Medicare Mange Care amp Medicaid Changes in the New World We Live In
  • Medicaid
  • NEW Medicaid Change MIlogin
  • Blueprint for Health Innovation MI
  • Provider Enrollment Electronic Signature Form Submission Process MSA 15-54
  • Provider Enrollment Electronic Signature Form Submission Process
  • Provider Enrollment Domain Administrator
  • Medicaid Coinsurance Medicare Advantage
  • Slide Number 9
  • Lawsuit DHS Changes on Caregivers
  • TPL Medicaid Change
  • CHAMPS Member Screen
  • LOC dropping off Not Due to MI Health
  • Issues
  • Secure Email Information
  • Medicaid amp Hospice
  • Medicaid
  • Medicaid Medicare Buy In
  • Manage Medicaid
  • Healthy Michigan Residents
  • Healthy Michigan Medicaid Days
  • McLaren Health Plan
  • Manage Medicaid Plans January 1
  • Slide Number 24
  • MI Health Link
  • MI Health Link 2565
  • What are the Names
  • MI Health Dual Eligible
  • MI Health LOC
  • LOC Medicaid
  • Medicaid Redetermination and MHL Enrollment
  • MI Health Link Portals
  • MI Health Authorizations
  • MI Health Issues
  • LOC 02 dropping MI Health Issues
  • PPA Offset
  • LOCD
  • MI Health Issues-New
  • ACO
  • Families Receiving Letters for ACO
  • ACO What is It
  • Payroll Based Journal
  • Slide Number 43
  • If you submit data manually should you also submit it through the XML
  • Staffing Submission Frequently Asked Questions
  • CMS defines
  • Slide Number 47
  • PBJ Medical Director Role
  • PBJ Medical Director Role
  • Dietician
  • Pharmacy Consultant
  • What are the names for the Medicare Number
  • QTSO
  • Medicare Update
  • CMS Final Rule On Returning Credits
  • Over Payment Rule
  • Questions to MAC
  • Questions to MAC
  • Final Rule on Returning Credits
  • Final Rule on Returning Credits
  • Final Rule on Returning Credits
  • Slide Number 62
  • Medicare Advantage Payors
  • Medicare Provider Enrollment Fee
  • Medicare MAC-Higlas
  • Two Midnight Rule
  • Two Midnight Rule
  • Two Midnight Rule
  • InPatient Vs Observation Conthellip
  • Two Midnight Rule
  • Health Data Insights amp Medicare Plus Blue
  • HDI Health Data amp Med Plus Blue
  • Health Data InSight
  • Pepper Reports
  • CGI Technologies and Solutions Inc httpracbcgicomContactInfoaspxst=1
  • CGI Federal RAC
  • How to survive RAC Audit
  • RAC Audits
  • How Did we get here
  • Where are we now
  • RAC Reviews
  • Priority Health SCIO Health Analytics
  • Cheer
  • References
Page 19: Medicare, Mange Care & Medicaid Changes in the New World we live in

Manage Medicaid Where are we

19

Healthy Michigan Residents

20

Healthy Michigan Medicaid Days

21

McLaren Health Plan

22

Manage Medicaid Plans January 1bull Region 1 ndash Upper Peninsula Health Planbull Region 2 ndash McLaren Health Plan Meridian Health Plan of Michigan Molina Healthcare of Michigan

UnitedHealthcare Community Planbull Region 3 ndash McLaren Health Plan Meridian Health Plan of Michigan Molina Healthcare of Michigan

UnitedHealthcare Community Planbull Region 4 ndash Blue Cross Complete of Michigan McLaren Health Plan Meridian Health Plan of Michigan Molina

Healthcare of Michigan Priority Health Choice UnitedHealthcare Community Planbull Region 5 ndash McLaren Health Plan Meridian Health Plan of Michigan Molina Healthcare of Michigan

UnitedHealthcare Community Planbull Region 6 ndash Blue Cross Complete of Michigan HAP Midwest Health Plan McLaren Health Plan Meridian Health

Plan of Michigan Molina Healthcare of Michigan UnitedHealthcare Community Planbull Region 7 ndash Blue Cross Complete of Michigan McLaren Health Plan Meridian Health Plan UnitedHealthcare

Community Planbull Region 8 ndash Aetna Better Health of Michigan McLaren Health Plan Meridian Health Plan of Michigan Molina

Healthcare of Michigan Priority Health Choice UnitedHealthcare Community Planbull Region 9 ndash Aetna Better Health of Michigan Blue Cross Complete of Michigan McLaren Health Plan Meridian

Health Plan of Michigan Molina Healthcare of Michigan UnitedHealthcare Community Planbull Region 10 ndash Aetna Better Health of Michigan Blue Cross Complete of Michigan Harbor Health Plan McLaren

Health Plan Meridian Health Plan of Michigan Molina Healthcare of Michigan Total Health Care UnitedHealthcare Community Plan 23

24

MI Health LinkWhere are we

25

MI Health Link 2565

bull This notification is being sent to providers of long term care services including nursing facilities county medical care facilities and hospital long term care units to provide clarification on the process involved with the submission of the Facility Admission Form (MSA-2565-C) for an individual enrolled in the MI Health Link program

bull The MI Health Link program covers the custodiallong term nursing facility service benefit When an individual who is enrolled in the MI Health Link program is admitted to a nursing facility for custodiallong term nursing services a disenrollment from the Integrated Care Organization (MI Health Link health plan) is NOT REQUIRED The Facility Admission Form (MSA-2565-C) should NOT be sent to the Michigan Department of Health and Human Services (MDHHS) Enrollment Services Section for a disenrollment to be processed

26

What are the Names

bull Started as Integrated Health

bull Then called MMP (Medicare Medicaid Program)

bull Duals (Also Known as Duals as in Dual Eligible)

bull Now called MI Health Link

bull Total confusion

27

MI Health Dual Eligible28

MI Health LOC

29

LOC Medicaidbull We have the new pilot program which started on March

1 2015 in Southwest Michigan Region 4 Counties Macomb Wayne and the UP You could see these patients they are dual eligible in the Pilot program in counties surrounding the pilot

bull MHL-LOC 005 (All other Facilities) or LOC 015 (County Care) These residents have to call Michigan Enrolls to dis-enroll toll-free at 1-800-975-7630 (TTY 1-888-263-5897) Monday-Friday from 8 AM to 7 PM Once they dis-enroll they will go to a LOC 02 you have to do a new LOCD

30

Medicaid Redetermination and MHL Enrollmentbull At the time of re-determination for Medicaid financial eligibility the MI

Health Link (MHL) program will not be sending beneficiaries information about this program Beneficiaries who previously opted out will not be passively enrolled according to an email from the MHL staff The MHL staff wrote

bull ldquoThere is currently no MI Health Link enrollment letter sent to beneficiaries when eligibility is re-determined A person who becomes eligible for MI Health Link enrollment may opt-in at any time

bull When Medicaid re-determination takes place the beneficiary remains in the same ICO unless that beneficiary lost Medicaid coverage If the enrollee loses Medicaid coverage and later regains it they are not passively enrolled into MI Health Link The beneficiary may choose to opt back in to the program at that time if desiredrdquo

bull MHL staff did state that about 1500 beneficiaries will be passively enrolled effective January 1 2016 These specific individuals were given normal notice of 60 and 30 days in which to opt-in or opt-out if they so chose No other large scale passive enrollment is scheduled according to the MHL staff 31

MI Health Link Portals

bull Meridian Health Planbull httpwwwmhplancommibull Amerihealthbull httpwwwamerihealthcaritasvipcarepluscomproviderself-service-

toolsindexaspxbull AetnaCoventrybull httpwwwaetnabetterhealthcomMichiganprovidersportalbull Molinabull httpwwwmolinahealthcarecommembersmien-usmemPageshomeaspxbull HAPMidwestbull httpswwwmidwesthealthplancomLoginaspxbull FidelisCentenebull wwwfidelissccommmp 32

MI Health Authorizationsbull We need to watch these authorization that the plans are giving us for the MI

Health program Some plans are assigning a diagnosis for residents in their prior authorizations They are assigning diagnosis that the residents do not even have You need to make sure these are correct diagnosis and if not you need to work with the case managers of the plans to fix the issue The authorization numbers do change

bull Make sure that any resident that is in a MI Health plan that you have a prior authorization All plans are giving different periods authorizing the residents stay in the facility You need to set up a system to make sure you always have a authorization for the period of time you are rendering the service Here is an example of time frame of authorizations

bull Meridian is authorizing 12 monthsbull Aetna is authorizing 3 monthsbull Molina is authorizing 6 monthsbull The authorization numbers need to go on your claims to the payer You need to

put the authorizations in your software and track the dates

33

MI Health Issuesbull We are seeing some issues with MI Health where the resident does not have the correct LOC or it shows

up correct on CHAMPS but ancillary providers such as Dentist and such cannot see it I think we still have some issues with the information crossing between Bridges DHS system CMS and CHAMPS It in return is creating some access of care issues If it is a true LOC issues Facilities with LOC issues need to submit the Medicaid ID numbers to the MSA-MHL-EnrollmentMichigangov box with the subject line Nursing home LOC Issue so they may work to resolve the issues

bull If it becomes an access to care issue email the information to INTEGRATEDCAREmichigangov Remember in these emails only send the Medicaid ID and explain the situation The State will work with the plans to try to fix the process or improve the process

bull We are also seeing with new admission with LOC 015 or 005 that the plans are stating they have 14 days to authorize admission These are resident in the emergency room and possibly be admitted to you for Rehab The hospital will not keep the resident in ER for 14 days and you cannot admit the resident until you have a prior authorization I would recommend when you are told this by the plan that you need to ask to speak to a manager We will have to work through this

bull Ancillary Provider You need to work with your ancillary providers such as Lab Pharmacy X-Ray Physician and such to get the to be credentialed with the plans We are hearing that some of the pharmacies are not participating with the plans this will create issues for you so I would continue to ask these groups to participate

34

LOC 02 dropping MI Health Issuesbull The passive enrollments have occurred in Macomb amp Wayne for

Medicaid dual eligible We are having the same issue we did as in the Southwest MI amp UP with the passive enrollments I am starting to hear from facilities who are checking there CHAMPS member screens that those residents that have opted out (some residents not all) have lost there 02 Make sure you are checking your CHAMPS member screen both for those that were passively enrolled and those that might have lost there 02 Medicaid that opted out

bull Facilities with LOC issues need to submit the Medicaid ID numbers to the (Only MI Health)MSA-MHL-Enrollmentmichigangov box with the subject line Nursing home LOC Issue so they may work to resolve the issues

35

PPA Offset

bull There are no co-pays deductibles or premiums in MI Health Link so there should be no need to offset the PPA with code 25 MI Health Link enrollees can continue to offset their PPA for non-program covered medical expenses (like Vision-Code 27 Dental-Code 28 and Hearing-Code 26) and use the appropriate codes to offset the PPA when billing the health plan for nursing facility services

bull Resident pay PPA when MedicareMedicaid coinsurance

36

LOCDbull Nursing Facility Level of Care Determination (NFLOCD)

bull The MI Health Link health plan will be responsible for conducting the Michigan Medicaid NFLOCD tool for enrollees seeking admission to a nursing facility For existing residents at the time of enrollment the existing NFLOCD will be adopted for capitation payment purposes The health plan will complete a new NFLCOD tool within the first 90 days of enrollment If a nursing facility resident is disenrolled from MI Health Link the nursing facility will be responsible for conducting a new NFLOCD tool in accordance with published Medicaid policy

37

MI Health Issues-New

bull INTEGRATEDCAREmichigangov

bull Email with Insurance Plan issues Case Manager Issues

38

ACOWhat are they

39

Families Receiving Letters for ACO

40

ACO What is It

bull Whats an ACObull Accountable Care Organizations (ACOs) are groups of doctors hospitals

and other health care providers who come together voluntarily to give coordinated high quality care to their Medicare patients

bull The goal of coordinated care is to ensure that patients especially the chronically ill get the right care at the right time while avoiding

unnecessary duplication of services and preventing medical errorsbull When an ACO succeeds both in delivering high-quality care and

spending health care dollars more wisely it will share in the savings it achieves for the Medicare program

41

Payroll Based JournalMandatory on July 1 2016Internet Explorer Version

Internet Explorer v 10 and v 11 will need to operate in compatibility mode

42

43

If you submit data manually should you also submit it through the XML

bull Now you have three options

bull Submit Manually only

bull Submit through the XML only

bull You are able to submit manually and using the XML

44

45

Staffing Submission Frequently Asked Questions

bull ldquoWho are direct care staffrdquo (Who do we submit data for)bull Submission of data for contract staffbull Medical directors and consultantsbull Staff switching roles or tasks throughout the daybull Hours paid vs hours worked ndash Must be verifiablebull Public postingQuality MeasuresFive Starbull Enforcementbull Voluntary submission risks (noneSo register now)

CMS defines

bull 37 job title codes that are required to match employees to the number of hours each direct care function was performed It is important to work with your teams to define the workers that contribute to each job type and how those daily worked hours are recorded and converted to a PBJ submission

bull The PBJ does include some more specific job descriptions than the 671 For example the PBJ system includes job descriptions for RNs with administrative duties and LPNs with administrative duties versus the 671rsquos more general ldquoNurses with Administrative Duties

Page 46

47

PBJ Medical Director Rolebull Physician Leadership

bull Help the facility ensure that patients have appropriate physician coverage and ensure the provision of physician and health care practitioner services and

bull Help the facility develop a process for reviewing physician and health care practitioner credentials

bull Provide specific guidance for physician performance expectations

bull Help the facility ensure that a system is in place for monitoring the performance of health care practitioners and

bull Facilitate feedback to physicians and other health care practitioners on performance and practices

bull Patient Care - Clinical Leadership

bull Participate in administrative decision-making and the development of policies and procedures related to patient care

bull Help develop approve and implement specific clinical practices for the facility to incorporate into its care-related policies and procedures including areas required by laws and regulations

bull Develop procedures and guidance for facility staff regarding contacting practitioners including information gathering and presentation change in condition assessment and when to contact the medical director

bull Review consider andor act upon consultant recommendations as appropriate that affect the facilitys resident care policies and procedures or the care of an individual resident

bull Review respond to and participate in federal state local and other external surveys and inspections and

bull Help review policies and procedures regarding the adequate protection of patients rights advance care planning and other ethical issues48

PBJ Medical Director Rolebull Quality of Care

bull Help the facility establish systems and methods for reviewing the quality and appropriateness of clinical care and other health-related services and provide appropriate feedback and

bull Participate in the facilitys quality improvement process

bull Advise on infection control issues and approve specific infection control policies to be incorporated into facility policies and procedures

bull Help the facility provide a safe and caring environment

bull Help promote employee health and safety and

bull Assist in the development and implementation of employee health policies and programs

bull Education Information and Communication

bull Promote a learning culture within the facility by educating informing and communicating

bull Provide information to help the facility provide care consistent with current standards of practice (defined as approaches to care procedures techniques and treatments that are based on research and or expert consensus and that are contained in current manuals textbooks and or publications or that are accepted adopted or promulgated by recognized organizations or national bodies)

bull Help the facility develop medical information and communication systems with staff patients and families and others

bull Represent the facility to the professional and lay community on medical and patient care issues

bull Maintain knowledge of the changing social regulatory political and economic factors that affect medical and health services of long term care patients and

bull Help establish appropriate relationships with other health care organizations

49

Dietician

bull When the dietary or food services supervisor is other than a registered dietitian the supervisor shall receive routine consultation and technical assistance from a registered dietitian (RD) Consultation time shall not be less than 4 hours every 60 days Additional consultation time may be needed based on the total number of patients incidence of nutrition-related health problems and food service management needs of the facility

50

Pharmacy Consultant

bull At least once per month a licensed pharmacist must perform a drug regimen review (DRR) for each resident The pharmacist must report any irregularities to the attending physician or director of nursing Furthermore these reports must be acted upon

51

What are the names for the Medicare Numberbull OSCAR -Online Survey Certification and Reporting

bull PTAN-PTAN number is assigned by Medicare to authenticate the provider when using the local Medicare Administrative Contractorrsquos (MAC) self-help tools like the IVR internet portal on-line application status etc Provider Transactions Access Number

bull CCN- CMS Certification Number

bull Medicare Number- example 23-

bull All of the above mean the same thing

52

QTSO

bull Once you are logged in the QTSO site bull You will have a state login to the site to access the various site specific

to your facilitybull Installing you will need administrator rights to your network

53

Medicare UpdateWhat are we seeing

54

CMS Final Rule On Returning Credits

httpswwwfederalregistergovarticles201602122016-02789medicare-program-reporting-and-returning-of-overpayments

55

Over Payment Rule

bull Medicare payments for non covered services

bull Medicare payments in excess of the allowable amount for an identified covered service

bull Errors and non reimbursable expenditures in cost reportsbull Duplicate payment

bull Receipt of Medicare payments when another payor had the primary responsibility for payment

56

Questions to MAC

bull Does the Medicare credit balance report change with this overpayment rule

bull No Medicare Credit Balances are still required at the end of each quarter

bull Will that still be the communication to let CMS or the MAC know that we have received an overpayment

bull Submission of Medicare Credit Balance is one form of communicating overpayments to CMS Other methods include submitting a voluntary refund with required claim information or the submission of a standard overpayment form

57

Questions to MAC

bull Will the MAC still deduct from a future RAbull If the recovery of the overpayment includes adjusting a claim then

the overpayment would be netted against future claims payments and reflected on the RA

bull Or will that process change with this new rulebull Process will remain the samebull Will NGS send communication out on thisbull Yes NGS will communicate this once the final rule is communicated

to the MACs by CMS However this could change depending on final CMS instructions

58

Final Rule on Returning Credits

bull Providers will want to immediately update their current policies governing overpayments in order to comply with this new rule which will take effect on March 14 2016

bull Providers and suppliers are required to use reasonable diligence to investigate credible information regarding overpayments through both proactive compliance efforts and reactive investigations

bull If an overpayment is identified then it must be repaid within 60 days An overpayment is identified when a person has or should have through the exercise of reasonable diligence determined that the person received an overpayment and quantified the amount

bull Providers and suppliers have a maximum of 8 months to report and return overpayments ndash up to 6 months to investigate and quantify the overpayment (ie to identify it) and up to 60 days to report and return the overpayment

59

Final Rule on Returning Credits

bull Providers and suppliers are required to report and return all overpayments within a 6-year lookback period

bull The cause and amount of the overpayment is irrelevant for the determination eg it was due to a mistake it was someone elsersquos fault it is a minor amount An overpayment is an overpayment and must be returned

bull Providers and suppliers must make their own determination to which entity to report and return the overpayment ie to the Medicare contractor or using the OIG Self Disclosure Protocol or the CMS Self Referral Disclosure Protocol

60

Final Rule on Returning Credits

bull Providers and suppliers may use the claims adjustment credit balance self-reported refund process or another appropriate process to report and return overpayments At this time there is no standard refund form to use

bull Failure to report and return an overpayment could subject the provider or supplier to False Claims Act liability Civil Monetary Penalties Law liability and exclusion from federal health care programs

61

P S amp R-Accountants will be asking for this information

The location you login into has changed it is now on EIDM EIDM is the acronym for CMS Enterprise Identity Management system which includes Identity Verification Access Management Authorization Assistance Workflow Tools and Identity Lifecycle Management functions

httpswwwcmsgovResearch-Statistics-Data-and-SystemsCMS-Information-TechnologyIACSCMS-Applications-Loginhtml

Go down the page and click on the PSampRSTARThis will take you to the login pagewill look the same as the old P S amp R didChanges Affecting PSampR System Access (Please Read) (posted 01292015)(Updated 5262015)is changingThe system which controls your PSampR user ID (currently IACS)The new system is referred to as EIDMThis will result in a different way to create new accounts or change passwords to existing accountsIf you already have an account in EIDM you may have to use that account for accessing PSampR after the transitionWhen is the change effectiveJune 13 2015What is staying the sameThe internet address for accessing PSampR remains the sameThe PSampR systemfunctionality is NOT changing 62

Medicare Advantage Payorsbull Medicare Advantage payors are pullingdenying payments on admissions if the patient was readmitted within 30 days after discharge The

client believes that the payors systematically denying payments for all readmissions within 30 days They believe this practice denies them due process to address whether the readmissions were justified and not due to a premature discharge of patient The payors seem to want to act like a QIO without having the same accountabilities of the QIO related to determinations of non-payment

bull Heres the QIO process under section 4240 of the QIO Manualbull 4240 - Readmission Review - (Rev 2 07-11-03)bull Readmission review involves admissions to an acute general short-term hospital occurring less than 31 calendar days from the date of

discharge from the same or another acute general short-term hospital (see sect1154(a)(13) and 42 CFR 47671(a)(8)(ii)) Neither the day of discharge nor the day of admission is counted when determining whether a readmission has occurred

bull A Medical Review Proceduresbull Obtain the appropriate medical records for the initial admission and readmission Perform case review on both stays Analyze the cases

specifically to determine whether the patient was prematurely discharged from the first confinement thus causing readmission Perform an analysis of the stay at the first hospital to determine the cause(s) and extent of any problem(s) (eg incomplete or substandard treatment) Consider the information available to the attending physician who discharged the patient from the first confinement Do not base a determination of a premature discharge on information that the physician or provider could not have known or events that could not have been anticipated at the time of discharge

bull Review both the initial admission and the readmission at the same time unless one of them has previously been reviewed In these cases use at a minimum the PRAF case summary of the other admission in addition to the medical record of the case under review

bull C Denialsbull Deny readmissions under the following circumstancesbull If the readmission was medically unnecessarybull If the readmission resulted from a premature discharge from the same hospital orbull If the readmission was a result of circumvention of PPS by the same hospital (see sect4255)bull With the QIO process there is an appeal within the QIO here the hospital is getting no opportunity to challenge the denials

63

Medicare Provider Enrollment Feebull Provider Enrollment Application Fee Amount for CY 2016bull On December 3 CMS issued a notice Provider Enrollment Application

Fee Amount for CY 2016 [CMSndash6066ndashN] Effective January 1 2016 the CY 2016 application fee is $554 for institutional providers that are

bull Initially enrolling in the Medicare or Medicaid program or the Childrens Health Insurance Program (CHIP)

bull Revalidating their Medicare Medicaid or CHIP enrollmentbull Adding a new Medicare practice locationbull This fee is required with any enrollment application submitted from

January 1 through December 31 2016

64

Medicare MAC-Higlas

bull Effective 142016 CMS has implemented a change to begin netting (offsetting) provider money across workloads within a single organization What this means is that any related providers conducting business in two different workloads (example New York and Maine) will have their money applied to any account receivables (AR) with a remaining balance owed to Medicare within both workloads For example Provider ABC is located in New York and is scheduled to receive a payment of $1000 on todays remittance advice Provider XYZ is related to provider ABC but is located in Maine and has ARs with a balance owed of $200 Provider ABCs $1000 payment will have the $200 applied against provider XYZs ARs resulting in a net payment of $800 This will be reflected on the remittance advice by the same PLB code as seen today for offsets for the $200

65

Two Midnight RuleChange January 1 2016 httpswwwcmsgovMedicareMedicare-Fee-for-Service-PaymentHospitalOutpatientPPSHospital-Outpatient-Regulations-and-Notices-ItemsCMS-1633-FChtml

66

Two Midnight Rulebull However effective January 1 2016 CMS will allow exceptions to the

Two-Midnight Benchmark to be determined on a case-by-case basis by the physician responsible for the care of the beneficiary subject to medical review Said differently Part A payment may be appropriate in some circumstances even though there is no expectation by the physician (or qualified ordering practitioner) of a two-midnight stay and one of the two pre-existing categorical exceptions (CMS ldquoinpatient onlyrdquo list and newly initiated mechanical ventilation) does not apply CMS has indicated that this change to the Two Midnight Rule is in response to stakeholder concern and CMSrsquos continued efforts to develop the most appropriate standard for determining Medicare Part A payment

67

Two Midnight Rulebull A new 42 CFR sect4123(a) provides that a patient is considered an

inpatient of a hospitalhellipif formally admitted as an inpatient pursuant to an order for inpatient admission by a physician or other qualified practitionerhellip The physician orders inpatient status when he or she expects the patient to require a stay that crosses at least 2 midnights[10] Stays expected to be shorter than at least two midnights are generally inappropriate for inpatient admission and inpatient payment under Medicare Part A unless the surgical procedure is specified by Medicare as inpatient only under sect41922(n)[11] The physicians expectationhellipshould be based on such complex medical factors as patient history and comorbidities the severity of signs and symptoms current medical needs and the risk of an adverse event[12] The physician order is part of physician certification of the medical necessity of hospital inpatient serviceshellip[13]

68

InPatient Vs Observation Conthellip

bull Physician certification which begins with an order for inpatient admission requires the physician to certify the reasons for the hospitalization the estimated time the patient will remain in the hospital and plans for post-hospital care if appropriate[14] The certification must be completed signed and documented in the medical record prior to discharge[15]

bull A physicians admission order has no presumptive weight and both the admission order and the physician certification will be evaluated in the context of the evidence in the medical record[16] CMS intends to provide additional information about what evidence in the medical record means in future instructions and manual revisions[17]

69

Two Midnight Rulebull Although the new case-by-case exception appears to be inherently

subjective to a certain extent CMS states that the following factors (among others) would be relevant to determining whether a patient requires inpatient admission under the expanded policy

bull The severity of the signs and symptoms exhibited by the patient bull The medical predictability of something adverse happening to the patient

and bull The need for diagnostic studies that appropriately are outpatient services

(that is their performance does not ordinarily require the patient to remain at the hospital for 24 hours or more)

bull CMS also notes that an inpatient admission (and Part A payment) should be ldquorare and unusualrdquo for minor surgical procedures or other treatment that is expected to keep the patient in the hospital ldquofor only a few hoursrdquo or for a period of time that ldquodoes not span at least overnightrdquo (thus a subset of stays not meeting the Two Midnight Benchmark) CMS indicates that such cases will be prioritized for medical review

70

Health Data Insights amp Medicare Plus Blue

RAC (Retrospective Audits)

71

HDI Health Data amp Med Plus Blue

bull httpwwwhealthdatainsightscombull Blue Cross Medicare Advantage Auditsbull Facilities seeing 10 to 15 requests for Medical Recordsbull In January amp Feburarybull Selected Health Data Insights because they were a premier Audit

Vendor for CMS Recovery Audit Contractor (RAC) demonstration Project They are a audit vendor for Humana

bull Providers not sending Medical Record will get technical denial and lose payments

72

Health Data InSight

bull In 2010 they began the Hospital Reviewbull Medicare Advantage encounter datandashCMS oversight of data integrity OIG

2016bull We will review CMSs oversight of MA encounter data validation and assess

the extent to which CMSrsquos Integrated Data Repository contains timely valid and complete MA encounter data In 2012 CMS began collecting from MA organizations a more comprehensive set of encounter data reflecting the items and services provided to MA plan enrollees Prior CMS and OIG audits have indicated vulnerabilities in the accuracy of data reporting by MA organizations Realizing the potential benefits of the MA encounter data for payment and program integrity oversight is contingent upon the datarsquos completeness validity and timeliness (OEI 03-15-00060 expected issue date FY 2017)

73

Pepper Reports

bull httpswwwpepperresourcesorg

bull Program for Evaluating Payment Patterns Electronic Report ( PEPPER)

bull Annually on or about April 18 2016 will be released

bull Pepper Portal httpssecurefiletmforg

74

CGI Technologies and Solutions Inc httpracbcgicomContactInfoaspxst=1

bull Indiana bull Michiganbull Minnesotabull Illinoisbull Kentuckybull Ohiobull Wisconsin CGI Technologies and Solutions Incbull For general and administrative questions regarding client service outreach

quality assurance or project-specific issues contactbull 1877316RACB (7222)bull Email racbcgicom Tamara Tate Tamaratatecmshhsgovbull 4107861288

75

CGI Federal RAC

bull CGI Federal RAC Region Bbull Email racbcgicombull Phone 1-877-316-RACB (7222)bull Mailing Addressbull Send medical records as followsbull Medical records for Indiana Illinois Kentucky Michigan Ohio Wisconsin

Minnesota DME and Home Health CGI Federal Inc Attn RACB Imaging Dept 1001 Lakeside Ave Suite 800 Cleveland OH 44114

bull If submitting paper records please send medical records as follows For Therapy Reviews CGI Federal Inc Attn RACB Imaging 1001 Lakeside Avenue Suite 800 Cleveland OH 44114

76

How to survive RAC Audit

bull National health expenditures totaled $1679 Billion in 2003 bull National health expenditures were 153 of GROSS Domestic Product

(GDP) in 2003 bull Health care cost increasing at +9 per year bull Doomsday predictions of Medicare running out bull Congressional Action

77

RAC Audits

bull Medicare Modernization Act (MMA) of 2003Mandated a three year audit demonstration project 2005-2008

bull Appoint audit contractors to review Medicare billings for proper coding DRG assignment and medical necessity

bull Audits will apply to all health care providers (hospitals physicians homecare dme etc)

bull Audit contractors to be paid on a contingency basis a percentage of overpayments recovered

78

How Did we get here

bull Overpayments collected due to errors in Medically Unnecessary Services ndash 40

bull Incorrectly Coded ndash 35

bull Other ndash 17

bull NoInsufficient Documentation ndash 8

79

Where are we now

bull All RACrsquos completed required provider outreachAccess to Medicare billing data base given to all RAC RAC review methodology

bull Automated Review-Black amp White Issues (current) bull DRG Validation-complex review (current) bull Complex Review for coding errors (current) bull DME Medical Necessity Reviews ndashcomplex review (calendar year

2010) bull Medical Necessity Reviews-complex review (calendar year 2010)

80

RAC Reviews

bull Responsibilities of the Team Leader bull Must learn each insurance provider participating in a RAC or RAC type

program bull What are their operating rulesbull What is their appeal process Time limits

May be different process for each insurance provider bull Develop a response team

Identify who does what when why and alternate bull individual

Build and develop a manual process Review of computerized system

81

Priority Health SCIO Health Analytics

bull httpswwwsciohealthanalyticscomcore-capabilitiespayment-integrityfacility-auditsskilled-nursing-facility-audits

bull Claims for Medicare members treated at Skilled Nursing Facilities are reimbursed based on the patientsrsquo RUG (Resource Utilization Group) score which is determined using the Minimum Data Set (MDS) Using SCIOs robust analytics claims andor providers that merit review are selected for audit SCIOs auditors conduct a detailed review of the complete medical record and associated MDS to determine if the billed RUG score is valid In the event the review determines that an incorrect RUG score was billed SCIOreg provides the valid score reports the reason the change was necessary and calculates the resulting overpayment

82

+ Cheer

Onward and Upward she shall prevail We are here to care for the residents and provide a wonderful

service

13 83

84

References

bull Priority Healthbull Blue Crossbull Medicaidbull Medicare

85

  • Medicare Mange Care amp Medicaid Changes in the New World We Live In
  • Medicaid
  • NEW Medicaid Change MIlogin
  • Blueprint for Health Innovation MI
  • Provider Enrollment Electronic Signature Form Submission Process MSA 15-54
  • Provider Enrollment Electronic Signature Form Submission Process
  • Provider Enrollment Domain Administrator
  • Medicaid Coinsurance Medicare Advantage
  • Slide Number 9
  • Lawsuit DHS Changes on Caregivers
  • TPL Medicaid Change
  • CHAMPS Member Screen
  • LOC dropping off Not Due to MI Health
  • Issues
  • Secure Email Information
  • Medicaid amp Hospice
  • Medicaid
  • Medicaid Medicare Buy In
  • Manage Medicaid
  • Healthy Michigan Residents
  • Healthy Michigan Medicaid Days
  • McLaren Health Plan
  • Manage Medicaid Plans January 1
  • Slide Number 24
  • MI Health Link
  • MI Health Link 2565
  • What are the Names
  • MI Health Dual Eligible
  • MI Health LOC
  • LOC Medicaid
  • Medicaid Redetermination and MHL Enrollment
  • MI Health Link Portals
  • MI Health Authorizations
  • MI Health Issues
  • LOC 02 dropping MI Health Issues
  • PPA Offset
  • LOCD
  • MI Health Issues-New
  • ACO
  • Families Receiving Letters for ACO
  • ACO What is It
  • Payroll Based Journal
  • Slide Number 43
  • If you submit data manually should you also submit it through the XML
  • Staffing Submission Frequently Asked Questions
  • CMS defines
  • Slide Number 47
  • PBJ Medical Director Role
  • PBJ Medical Director Role
  • Dietician
  • Pharmacy Consultant
  • What are the names for the Medicare Number
  • QTSO
  • Medicare Update
  • CMS Final Rule On Returning Credits
  • Over Payment Rule
  • Questions to MAC
  • Questions to MAC
  • Final Rule on Returning Credits
  • Final Rule on Returning Credits
  • Final Rule on Returning Credits
  • Slide Number 62
  • Medicare Advantage Payors
  • Medicare Provider Enrollment Fee
  • Medicare MAC-Higlas
  • Two Midnight Rule
  • Two Midnight Rule
  • Two Midnight Rule
  • InPatient Vs Observation Conthellip
  • Two Midnight Rule
  • Health Data Insights amp Medicare Plus Blue
  • HDI Health Data amp Med Plus Blue
  • Health Data InSight
  • Pepper Reports
  • CGI Technologies and Solutions Inc httpracbcgicomContactInfoaspxst=1
  • CGI Federal RAC
  • How to survive RAC Audit
  • RAC Audits
  • How Did we get here
  • Where are we now
  • RAC Reviews
  • Priority Health SCIO Health Analytics
  • Cheer
  • References
Page 20: Medicare, Mange Care & Medicaid Changes in the New World we live in

Healthy Michigan Residents

20

Healthy Michigan Medicaid Days

21

McLaren Health Plan

22

Manage Medicaid Plans January 1bull Region 1 ndash Upper Peninsula Health Planbull Region 2 ndash McLaren Health Plan Meridian Health Plan of Michigan Molina Healthcare of Michigan

UnitedHealthcare Community Planbull Region 3 ndash McLaren Health Plan Meridian Health Plan of Michigan Molina Healthcare of Michigan

UnitedHealthcare Community Planbull Region 4 ndash Blue Cross Complete of Michigan McLaren Health Plan Meridian Health Plan of Michigan Molina

Healthcare of Michigan Priority Health Choice UnitedHealthcare Community Planbull Region 5 ndash McLaren Health Plan Meridian Health Plan of Michigan Molina Healthcare of Michigan

UnitedHealthcare Community Planbull Region 6 ndash Blue Cross Complete of Michigan HAP Midwest Health Plan McLaren Health Plan Meridian Health

Plan of Michigan Molina Healthcare of Michigan UnitedHealthcare Community Planbull Region 7 ndash Blue Cross Complete of Michigan McLaren Health Plan Meridian Health Plan UnitedHealthcare

Community Planbull Region 8 ndash Aetna Better Health of Michigan McLaren Health Plan Meridian Health Plan of Michigan Molina

Healthcare of Michigan Priority Health Choice UnitedHealthcare Community Planbull Region 9 ndash Aetna Better Health of Michigan Blue Cross Complete of Michigan McLaren Health Plan Meridian

Health Plan of Michigan Molina Healthcare of Michigan UnitedHealthcare Community Planbull Region 10 ndash Aetna Better Health of Michigan Blue Cross Complete of Michigan Harbor Health Plan McLaren

Health Plan Meridian Health Plan of Michigan Molina Healthcare of Michigan Total Health Care UnitedHealthcare Community Plan 23

24

MI Health LinkWhere are we

25

MI Health Link 2565

bull This notification is being sent to providers of long term care services including nursing facilities county medical care facilities and hospital long term care units to provide clarification on the process involved with the submission of the Facility Admission Form (MSA-2565-C) for an individual enrolled in the MI Health Link program

bull The MI Health Link program covers the custodiallong term nursing facility service benefit When an individual who is enrolled in the MI Health Link program is admitted to a nursing facility for custodiallong term nursing services a disenrollment from the Integrated Care Organization (MI Health Link health plan) is NOT REQUIRED The Facility Admission Form (MSA-2565-C) should NOT be sent to the Michigan Department of Health and Human Services (MDHHS) Enrollment Services Section for a disenrollment to be processed

26

What are the Names

bull Started as Integrated Health

bull Then called MMP (Medicare Medicaid Program)

bull Duals (Also Known as Duals as in Dual Eligible)

bull Now called MI Health Link

bull Total confusion

27

MI Health Dual Eligible28

MI Health LOC

29

LOC Medicaidbull We have the new pilot program which started on March

1 2015 in Southwest Michigan Region 4 Counties Macomb Wayne and the UP You could see these patients they are dual eligible in the Pilot program in counties surrounding the pilot

bull MHL-LOC 005 (All other Facilities) or LOC 015 (County Care) These residents have to call Michigan Enrolls to dis-enroll toll-free at 1-800-975-7630 (TTY 1-888-263-5897) Monday-Friday from 8 AM to 7 PM Once they dis-enroll they will go to a LOC 02 you have to do a new LOCD

30

Medicaid Redetermination and MHL Enrollmentbull At the time of re-determination for Medicaid financial eligibility the MI

Health Link (MHL) program will not be sending beneficiaries information about this program Beneficiaries who previously opted out will not be passively enrolled according to an email from the MHL staff The MHL staff wrote

bull ldquoThere is currently no MI Health Link enrollment letter sent to beneficiaries when eligibility is re-determined A person who becomes eligible for MI Health Link enrollment may opt-in at any time

bull When Medicaid re-determination takes place the beneficiary remains in the same ICO unless that beneficiary lost Medicaid coverage If the enrollee loses Medicaid coverage and later regains it they are not passively enrolled into MI Health Link The beneficiary may choose to opt back in to the program at that time if desiredrdquo

bull MHL staff did state that about 1500 beneficiaries will be passively enrolled effective January 1 2016 These specific individuals were given normal notice of 60 and 30 days in which to opt-in or opt-out if they so chose No other large scale passive enrollment is scheduled according to the MHL staff 31

MI Health Link Portals

bull Meridian Health Planbull httpwwwmhplancommibull Amerihealthbull httpwwwamerihealthcaritasvipcarepluscomproviderself-service-

toolsindexaspxbull AetnaCoventrybull httpwwwaetnabetterhealthcomMichiganprovidersportalbull Molinabull httpwwwmolinahealthcarecommembersmien-usmemPageshomeaspxbull HAPMidwestbull httpswwwmidwesthealthplancomLoginaspxbull FidelisCentenebull wwwfidelissccommmp 32

MI Health Authorizationsbull We need to watch these authorization that the plans are giving us for the MI

Health program Some plans are assigning a diagnosis for residents in their prior authorizations They are assigning diagnosis that the residents do not even have You need to make sure these are correct diagnosis and if not you need to work with the case managers of the plans to fix the issue The authorization numbers do change

bull Make sure that any resident that is in a MI Health plan that you have a prior authorization All plans are giving different periods authorizing the residents stay in the facility You need to set up a system to make sure you always have a authorization for the period of time you are rendering the service Here is an example of time frame of authorizations

bull Meridian is authorizing 12 monthsbull Aetna is authorizing 3 monthsbull Molina is authorizing 6 monthsbull The authorization numbers need to go on your claims to the payer You need to

put the authorizations in your software and track the dates

33

MI Health Issuesbull We are seeing some issues with MI Health where the resident does not have the correct LOC or it shows

up correct on CHAMPS but ancillary providers such as Dentist and such cannot see it I think we still have some issues with the information crossing between Bridges DHS system CMS and CHAMPS It in return is creating some access of care issues If it is a true LOC issues Facilities with LOC issues need to submit the Medicaid ID numbers to the MSA-MHL-EnrollmentMichigangov box with the subject line Nursing home LOC Issue so they may work to resolve the issues

bull If it becomes an access to care issue email the information to INTEGRATEDCAREmichigangov Remember in these emails only send the Medicaid ID and explain the situation The State will work with the plans to try to fix the process or improve the process

bull We are also seeing with new admission with LOC 015 or 005 that the plans are stating they have 14 days to authorize admission These are resident in the emergency room and possibly be admitted to you for Rehab The hospital will not keep the resident in ER for 14 days and you cannot admit the resident until you have a prior authorization I would recommend when you are told this by the plan that you need to ask to speak to a manager We will have to work through this

bull Ancillary Provider You need to work with your ancillary providers such as Lab Pharmacy X-Ray Physician and such to get the to be credentialed with the plans We are hearing that some of the pharmacies are not participating with the plans this will create issues for you so I would continue to ask these groups to participate

34

LOC 02 dropping MI Health Issuesbull The passive enrollments have occurred in Macomb amp Wayne for

Medicaid dual eligible We are having the same issue we did as in the Southwest MI amp UP with the passive enrollments I am starting to hear from facilities who are checking there CHAMPS member screens that those residents that have opted out (some residents not all) have lost there 02 Make sure you are checking your CHAMPS member screen both for those that were passively enrolled and those that might have lost there 02 Medicaid that opted out

bull Facilities with LOC issues need to submit the Medicaid ID numbers to the (Only MI Health)MSA-MHL-Enrollmentmichigangov box with the subject line Nursing home LOC Issue so they may work to resolve the issues

35

PPA Offset

bull There are no co-pays deductibles or premiums in MI Health Link so there should be no need to offset the PPA with code 25 MI Health Link enrollees can continue to offset their PPA for non-program covered medical expenses (like Vision-Code 27 Dental-Code 28 and Hearing-Code 26) and use the appropriate codes to offset the PPA when billing the health plan for nursing facility services

bull Resident pay PPA when MedicareMedicaid coinsurance

36

LOCDbull Nursing Facility Level of Care Determination (NFLOCD)

bull The MI Health Link health plan will be responsible for conducting the Michigan Medicaid NFLOCD tool for enrollees seeking admission to a nursing facility For existing residents at the time of enrollment the existing NFLOCD will be adopted for capitation payment purposes The health plan will complete a new NFLCOD tool within the first 90 days of enrollment If a nursing facility resident is disenrolled from MI Health Link the nursing facility will be responsible for conducting a new NFLOCD tool in accordance with published Medicaid policy

37

MI Health Issues-New

bull INTEGRATEDCAREmichigangov

bull Email with Insurance Plan issues Case Manager Issues

38

ACOWhat are they

39

Families Receiving Letters for ACO

40

ACO What is It

bull Whats an ACObull Accountable Care Organizations (ACOs) are groups of doctors hospitals

and other health care providers who come together voluntarily to give coordinated high quality care to their Medicare patients

bull The goal of coordinated care is to ensure that patients especially the chronically ill get the right care at the right time while avoiding

unnecessary duplication of services and preventing medical errorsbull When an ACO succeeds both in delivering high-quality care and

spending health care dollars more wisely it will share in the savings it achieves for the Medicare program

41

Payroll Based JournalMandatory on July 1 2016Internet Explorer Version

Internet Explorer v 10 and v 11 will need to operate in compatibility mode

42

43

If you submit data manually should you also submit it through the XML

bull Now you have three options

bull Submit Manually only

bull Submit through the XML only

bull You are able to submit manually and using the XML

44

45

Staffing Submission Frequently Asked Questions

bull ldquoWho are direct care staffrdquo (Who do we submit data for)bull Submission of data for contract staffbull Medical directors and consultantsbull Staff switching roles or tasks throughout the daybull Hours paid vs hours worked ndash Must be verifiablebull Public postingQuality MeasuresFive Starbull Enforcementbull Voluntary submission risks (noneSo register now)

CMS defines

bull 37 job title codes that are required to match employees to the number of hours each direct care function was performed It is important to work with your teams to define the workers that contribute to each job type and how those daily worked hours are recorded and converted to a PBJ submission

bull The PBJ does include some more specific job descriptions than the 671 For example the PBJ system includes job descriptions for RNs with administrative duties and LPNs with administrative duties versus the 671rsquos more general ldquoNurses with Administrative Duties

Page 46

47

PBJ Medical Director Rolebull Physician Leadership

bull Help the facility ensure that patients have appropriate physician coverage and ensure the provision of physician and health care practitioner services and

bull Help the facility develop a process for reviewing physician and health care practitioner credentials

bull Provide specific guidance for physician performance expectations

bull Help the facility ensure that a system is in place for monitoring the performance of health care practitioners and

bull Facilitate feedback to physicians and other health care practitioners on performance and practices

bull Patient Care - Clinical Leadership

bull Participate in administrative decision-making and the development of policies and procedures related to patient care

bull Help develop approve and implement specific clinical practices for the facility to incorporate into its care-related policies and procedures including areas required by laws and regulations

bull Develop procedures and guidance for facility staff regarding contacting practitioners including information gathering and presentation change in condition assessment and when to contact the medical director

bull Review consider andor act upon consultant recommendations as appropriate that affect the facilitys resident care policies and procedures or the care of an individual resident

bull Review respond to and participate in federal state local and other external surveys and inspections and

bull Help review policies and procedures regarding the adequate protection of patients rights advance care planning and other ethical issues48

PBJ Medical Director Rolebull Quality of Care

bull Help the facility establish systems and methods for reviewing the quality and appropriateness of clinical care and other health-related services and provide appropriate feedback and

bull Participate in the facilitys quality improvement process

bull Advise on infection control issues and approve specific infection control policies to be incorporated into facility policies and procedures

bull Help the facility provide a safe and caring environment

bull Help promote employee health and safety and

bull Assist in the development and implementation of employee health policies and programs

bull Education Information and Communication

bull Promote a learning culture within the facility by educating informing and communicating

bull Provide information to help the facility provide care consistent with current standards of practice (defined as approaches to care procedures techniques and treatments that are based on research and or expert consensus and that are contained in current manuals textbooks and or publications or that are accepted adopted or promulgated by recognized organizations or national bodies)

bull Help the facility develop medical information and communication systems with staff patients and families and others

bull Represent the facility to the professional and lay community on medical and patient care issues

bull Maintain knowledge of the changing social regulatory political and economic factors that affect medical and health services of long term care patients and

bull Help establish appropriate relationships with other health care organizations

49

Dietician

bull When the dietary or food services supervisor is other than a registered dietitian the supervisor shall receive routine consultation and technical assistance from a registered dietitian (RD) Consultation time shall not be less than 4 hours every 60 days Additional consultation time may be needed based on the total number of patients incidence of nutrition-related health problems and food service management needs of the facility

50

Pharmacy Consultant

bull At least once per month a licensed pharmacist must perform a drug regimen review (DRR) for each resident The pharmacist must report any irregularities to the attending physician or director of nursing Furthermore these reports must be acted upon

51

What are the names for the Medicare Numberbull OSCAR -Online Survey Certification and Reporting

bull PTAN-PTAN number is assigned by Medicare to authenticate the provider when using the local Medicare Administrative Contractorrsquos (MAC) self-help tools like the IVR internet portal on-line application status etc Provider Transactions Access Number

bull CCN- CMS Certification Number

bull Medicare Number- example 23-

bull All of the above mean the same thing

52

QTSO

bull Once you are logged in the QTSO site bull You will have a state login to the site to access the various site specific

to your facilitybull Installing you will need administrator rights to your network

53

Medicare UpdateWhat are we seeing

54

CMS Final Rule On Returning Credits

httpswwwfederalregistergovarticles201602122016-02789medicare-program-reporting-and-returning-of-overpayments

55

Over Payment Rule

bull Medicare payments for non covered services

bull Medicare payments in excess of the allowable amount for an identified covered service

bull Errors and non reimbursable expenditures in cost reportsbull Duplicate payment

bull Receipt of Medicare payments when another payor had the primary responsibility for payment

56

Questions to MAC

bull Does the Medicare credit balance report change with this overpayment rule

bull No Medicare Credit Balances are still required at the end of each quarter

bull Will that still be the communication to let CMS or the MAC know that we have received an overpayment

bull Submission of Medicare Credit Balance is one form of communicating overpayments to CMS Other methods include submitting a voluntary refund with required claim information or the submission of a standard overpayment form

57

Questions to MAC

bull Will the MAC still deduct from a future RAbull If the recovery of the overpayment includes adjusting a claim then

the overpayment would be netted against future claims payments and reflected on the RA

bull Or will that process change with this new rulebull Process will remain the samebull Will NGS send communication out on thisbull Yes NGS will communicate this once the final rule is communicated

to the MACs by CMS However this could change depending on final CMS instructions

58

Final Rule on Returning Credits

bull Providers will want to immediately update their current policies governing overpayments in order to comply with this new rule which will take effect on March 14 2016

bull Providers and suppliers are required to use reasonable diligence to investigate credible information regarding overpayments through both proactive compliance efforts and reactive investigations

bull If an overpayment is identified then it must be repaid within 60 days An overpayment is identified when a person has or should have through the exercise of reasonable diligence determined that the person received an overpayment and quantified the amount

bull Providers and suppliers have a maximum of 8 months to report and return overpayments ndash up to 6 months to investigate and quantify the overpayment (ie to identify it) and up to 60 days to report and return the overpayment

59

Final Rule on Returning Credits

bull Providers and suppliers are required to report and return all overpayments within a 6-year lookback period

bull The cause and amount of the overpayment is irrelevant for the determination eg it was due to a mistake it was someone elsersquos fault it is a minor amount An overpayment is an overpayment and must be returned

bull Providers and suppliers must make their own determination to which entity to report and return the overpayment ie to the Medicare contractor or using the OIG Self Disclosure Protocol or the CMS Self Referral Disclosure Protocol

60

Final Rule on Returning Credits

bull Providers and suppliers may use the claims adjustment credit balance self-reported refund process or another appropriate process to report and return overpayments At this time there is no standard refund form to use

bull Failure to report and return an overpayment could subject the provider or supplier to False Claims Act liability Civil Monetary Penalties Law liability and exclusion from federal health care programs

61

P S amp R-Accountants will be asking for this information

The location you login into has changed it is now on EIDM EIDM is the acronym for CMS Enterprise Identity Management system which includes Identity Verification Access Management Authorization Assistance Workflow Tools and Identity Lifecycle Management functions

httpswwwcmsgovResearch-Statistics-Data-and-SystemsCMS-Information-TechnologyIACSCMS-Applications-Loginhtml

Go down the page and click on the PSampRSTARThis will take you to the login pagewill look the same as the old P S amp R didChanges Affecting PSampR System Access (Please Read) (posted 01292015)(Updated 5262015)is changingThe system which controls your PSampR user ID (currently IACS)The new system is referred to as EIDMThis will result in a different way to create new accounts or change passwords to existing accountsIf you already have an account in EIDM you may have to use that account for accessing PSampR after the transitionWhen is the change effectiveJune 13 2015What is staying the sameThe internet address for accessing PSampR remains the sameThe PSampR systemfunctionality is NOT changing 62

Medicare Advantage Payorsbull Medicare Advantage payors are pullingdenying payments on admissions if the patient was readmitted within 30 days after discharge The

client believes that the payors systematically denying payments for all readmissions within 30 days They believe this practice denies them due process to address whether the readmissions were justified and not due to a premature discharge of patient The payors seem to want to act like a QIO without having the same accountabilities of the QIO related to determinations of non-payment

bull Heres the QIO process under section 4240 of the QIO Manualbull 4240 - Readmission Review - (Rev 2 07-11-03)bull Readmission review involves admissions to an acute general short-term hospital occurring less than 31 calendar days from the date of

discharge from the same or another acute general short-term hospital (see sect1154(a)(13) and 42 CFR 47671(a)(8)(ii)) Neither the day of discharge nor the day of admission is counted when determining whether a readmission has occurred

bull A Medical Review Proceduresbull Obtain the appropriate medical records for the initial admission and readmission Perform case review on both stays Analyze the cases

specifically to determine whether the patient was prematurely discharged from the first confinement thus causing readmission Perform an analysis of the stay at the first hospital to determine the cause(s) and extent of any problem(s) (eg incomplete or substandard treatment) Consider the information available to the attending physician who discharged the patient from the first confinement Do not base a determination of a premature discharge on information that the physician or provider could not have known or events that could not have been anticipated at the time of discharge

bull Review both the initial admission and the readmission at the same time unless one of them has previously been reviewed In these cases use at a minimum the PRAF case summary of the other admission in addition to the medical record of the case under review

bull C Denialsbull Deny readmissions under the following circumstancesbull If the readmission was medically unnecessarybull If the readmission resulted from a premature discharge from the same hospital orbull If the readmission was a result of circumvention of PPS by the same hospital (see sect4255)bull With the QIO process there is an appeal within the QIO here the hospital is getting no opportunity to challenge the denials

63

Medicare Provider Enrollment Feebull Provider Enrollment Application Fee Amount for CY 2016bull On December 3 CMS issued a notice Provider Enrollment Application

Fee Amount for CY 2016 [CMSndash6066ndashN] Effective January 1 2016 the CY 2016 application fee is $554 for institutional providers that are

bull Initially enrolling in the Medicare or Medicaid program or the Childrens Health Insurance Program (CHIP)

bull Revalidating their Medicare Medicaid or CHIP enrollmentbull Adding a new Medicare practice locationbull This fee is required with any enrollment application submitted from

January 1 through December 31 2016

64

Medicare MAC-Higlas

bull Effective 142016 CMS has implemented a change to begin netting (offsetting) provider money across workloads within a single organization What this means is that any related providers conducting business in two different workloads (example New York and Maine) will have their money applied to any account receivables (AR) with a remaining balance owed to Medicare within both workloads For example Provider ABC is located in New York and is scheduled to receive a payment of $1000 on todays remittance advice Provider XYZ is related to provider ABC but is located in Maine and has ARs with a balance owed of $200 Provider ABCs $1000 payment will have the $200 applied against provider XYZs ARs resulting in a net payment of $800 This will be reflected on the remittance advice by the same PLB code as seen today for offsets for the $200

65

Two Midnight RuleChange January 1 2016 httpswwwcmsgovMedicareMedicare-Fee-for-Service-PaymentHospitalOutpatientPPSHospital-Outpatient-Regulations-and-Notices-ItemsCMS-1633-FChtml

66

Two Midnight Rulebull However effective January 1 2016 CMS will allow exceptions to the

Two-Midnight Benchmark to be determined on a case-by-case basis by the physician responsible for the care of the beneficiary subject to medical review Said differently Part A payment may be appropriate in some circumstances even though there is no expectation by the physician (or qualified ordering practitioner) of a two-midnight stay and one of the two pre-existing categorical exceptions (CMS ldquoinpatient onlyrdquo list and newly initiated mechanical ventilation) does not apply CMS has indicated that this change to the Two Midnight Rule is in response to stakeholder concern and CMSrsquos continued efforts to develop the most appropriate standard for determining Medicare Part A payment

67

Two Midnight Rulebull A new 42 CFR sect4123(a) provides that a patient is considered an

inpatient of a hospitalhellipif formally admitted as an inpatient pursuant to an order for inpatient admission by a physician or other qualified practitionerhellip The physician orders inpatient status when he or she expects the patient to require a stay that crosses at least 2 midnights[10] Stays expected to be shorter than at least two midnights are generally inappropriate for inpatient admission and inpatient payment under Medicare Part A unless the surgical procedure is specified by Medicare as inpatient only under sect41922(n)[11] The physicians expectationhellipshould be based on such complex medical factors as patient history and comorbidities the severity of signs and symptoms current medical needs and the risk of an adverse event[12] The physician order is part of physician certification of the medical necessity of hospital inpatient serviceshellip[13]

68

InPatient Vs Observation Conthellip

bull Physician certification which begins with an order for inpatient admission requires the physician to certify the reasons for the hospitalization the estimated time the patient will remain in the hospital and plans for post-hospital care if appropriate[14] The certification must be completed signed and documented in the medical record prior to discharge[15]

bull A physicians admission order has no presumptive weight and both the admission order and the physician certification will be evaluated in the context of the evidence in the medical record[16] CMS intends to provide additional information about what evidence in the medical record means in future instructions and manual revisions[17]

69

Two Midnight Rulebull Although the new case-by-case exception appears to be inherently

subjective to a certain extent CMS states that the following factors (among others) would be relevant to determining whether a patient requires inpatient admission under the expanded policy

bull The severity of the signs and symptoms exhibited by the patient bull The medical predictability of something adverse happening to the patient

and bull The need for diagnostic studies that appropriately are outpatient services

(that is their performance does not ordinarily require the patient to remain at the hospital for 24 hours or more)

bull CMS also notes that an inpatient admission (and Part A payment) should be ldquorare and unusualrdquo for minor surgical procedures or other treatment that is expected to keep the patient in the hospital ldquofor only a few hoursrdquo or for a period of time that ldquodoes not span at least overnightrdquo (thus a subset of stays not meeting the Two Midnight Benchmark) CMS indicates that such cases will be prioritized for medical review

70

Health Data Insights amp Medicare Plus Blue

RAC (Retrospective Audits)

71

HDI Health Data amp Med Plus Blue

bull httpwwwhealthdatainsightscombull Blue Cross Medicare Advantage Auditsbull Facilities seeing 10 to 15 requests for Medical Recordsbull In January amp Feburarybull Selected Health Data Insights because they were a premier Audit

Vendor for CMS Recovery Audit Contractor (RAC) demonstration Project They are a audit vendor for Humana

bull Providers not sending Medical Record will get technical denial and lose payments

72

Health Data InSight

bull In 2010 they began the Hospital Reviewbull Medicare Advantage encounter datandashCMS oversight of data integrity OIG

2016bull We will review CMSs oversight of MA encounter data validation and assess

the extent to which CMSrsquos Integrated Data Repository contains timely valid and complete MA encounter data In 2012 CMS began collecting from MA organizations a more comprehensive set of encounter data reflecting the items and services provided to MA plan enrollees Prior CMS and OIG audits have indicated vulnerabilities in the accuracy of data reporting by MA organizations Realizing the potential benefits of the MA encounter data for payment and program integrity oversight is contingent upon the datarsquos completeness validity and timeliness (OEI 03-15-00060 expected issue date FY 2017)

73

Pepper Reports

bull httpswwwpepperresourcesorg

bull Program for Evaluating Payment Patterns Electronic Report ( PEPPER)

bull Annually on or about April 18 2016 will be released

bull Pepper Portal httpssecurefiletmforg

74

CGI Technologies and Solutions Inc httpracbcgicomContactInfoaspxst=1

bull Indiana bull Michiganbull Minnesotabull Illinoisbull Kentuckybull Ohiobull Wisconsin CGI Technologies and Solutions Incbull For general and administrative questions regarding client service outreach

quality assurance or project-specific issues contactbull 1877316RACB (7222)bull Email racbcgicom Tamara Tate Tamaratatecmshhsgovbull 4107861288

75

CGI Federal RAC

bull CGI Federal RAC Region Bbull Email racbcgicombull Phone 1-877-316-RACB (7222)bull Mailing Addressbull Send medical records as followsbull Medical records for Indiana Illinois Kentucky Michigan Ohio Wisconsin

Minnesota DME and Home Health CGI Federal Inc Attn RACB Imaging Dept 1001 Lakeside Ave Suite 800 Cleveland OH 44114

bull If submitting paper records please send medical records as follows For Therapy Reviews CGI Federal Inc Attn RACB Imaging 1001 Lakeside Avenue Suite 800 Cleveland OH 44114

76

How to survive RAC Audit

bull National health expenditures totaled $1679 Billion in 2003 bull National health expenditures were 153 of GROSS Domestic Product

(GDP) in 2003 bull Health care cost increasing at +9 per year bull Doomsday predictions of Medicare running out bull Congressional Action

77

RAC Audits

bull Medicare Modernization Act (MMA) of 2003Mandated a three year audit demonstration project 2005-2008

bull Appoint audit contractors to review Medicare billings for proper coding DRG assignment and medical necessity

bull Audits will apply to all health care providers (hospitals physicians homecare dme etc)

bull Audit contractors to be paid on a contingency basis a percentage of overpayments recovered

78

How Did we get here

bull Overpayments collected due to errors in Medically Unnecessary Services ndash 40

bull Incorrectly Coded ndash 35

bull Other ndash 17

bull NoInsufficient Documentation ndash 8

79

Where are we now

bull All RACrsquos completed required provider outreachAccess to Medicare billing data base given to all RAC RAC review methodology

bull Automated Review-Black amp White Issues (current) bull DRG Validation-complex review (current) bull Complex Review for coding errors (current) bull DME Medical Necessity Reviews ndashcomplex review (calendar year

2010) bull Medical Necessity Reviews-complex review (calendar year 2010)

80

RAC Reviews

bull Responsibilities of the Team Leader bull Must learn each insurance provider participating in a RAC or RAC type

program bull What are their operating rulesbull What is their appeal process Time limits

May be different process for each insurance provider bull Develop a response team

Identify who does what when why and alternate bull individual

Build and develop a manual process Review of computerized system

81

Priority Health SCIO Health Analytics

bull httpswwwsciohealthanalyticscomcore-capabilitiespayment-integrityfacility-auditsskilled-nursing-facility-audits

bull Claims for Medicare members treated at Skilled Nursing Facilities are reimbursed based on the patientsrsquo RUG (Resource Utilization Group) score which is determined using the Minimum Data Set (MDS) Using SCIOs robust analytics claims andor providers that merit review are selected for audit SCIOs auditors conduct a detailed review of the complete medical record and associated MDS to determine if the billed RUG score is valid In the event the review determines that an incorrect RUG score was billed SCIOreg provides the valid score reports the reason the change was necessary and calculates the resulting overpayment

82

+ Cheer

Onward and Upward she shall prevail We are here to care for the residents and provide a wonderful

service

13 83

84

References

bull Priority Healthbull Blue Crossbull Medicaidbull Medicare

85

  • Medicare Mange Care amp Medicaid Changes in the New World We Live In
  • Medicaid
  • NEW Medicaid Change MIlogin
  • Blueprint for Health Innovation MI
  • Provider Enrollment Electronic Signature Form Submission Process MSA 15-54
  • Provider Enrollment Electronic Signature Form Submission Process
  • Provider Enrollment Domain Administrator
  • Medicaid Coinsurance Medicare Advantage
  • Slide Number 9
  • Lawsuit DHS Changes on Caregivers
  • TPL Medicaid Change
  • CHAMPS Member Screen
  • LOC dropping off Not Due to MI Health
  • Issues
  • Secure Email Information
  • Medicaid amp Hospice
  • Medicaid
  • Medicaid Medicare Buy In
  • Manage Medicaid
  • Healthy Michigan Residents
  • Healthy Michigan Medicaid Days
  • McLaren Health Plan
  • Manage Medicaid Plans January 1
  • Slide Number 24
  • MI Health Link
  • MI Health Link 2565
  • What are the Names
  • MI Health Dual Eligible
  • MI Health LOC
  • LOC Medicaid
  • Medicaid Redetermination and MHL Enrollment
  • MI Health Link Portals
  • MI Health Authorizations
  • MI Health Issues
  • LOC 02 dropping MI Health Issues
  • PPA Offset
  • LOCD
  • MI Health Issues-New
  • ACO
  • Families Receiving Letters for ACO
  • ACO What is It
  • Payroll Based Journal
  • Slide Number 43
  • If you submit data manually should you also submit it through the XML
  • Staffing Submission Frequently Asked Questions
  • CMS defines
  • Slide Number 47
  • PBJ Medical Director Role
  • PBJ Medical Director Role
  • Dietician
  • Pharmacy Consultant
  • What are the names for the Medicare Number
  • QTSO
  • Medicare Update
  • CMS Final Rule On Returning Credits
  • Over Payment Rule
  • Questions to MAC
  • Questions to MAC
  • Final Rule on Returning Credits
  • Final Rule on Returning Credits
  • Final Rule on Returning Credits
  • Slide Number 62
  • Medicare Advantage Payors
  • Medicare Provider Enrollment Fee
  • Medicare MAC-Higlas
  • Two Midnight Rule
  • Two Midnight Rule
  • Two Midnight Rule
  • InPatient Vs Observation Conthellip
  • Two Midnight Rule
  • Health Data Insights amp Medicare Plus Blue
  • HDI Health Data amp Med Plus Blue
  • Health Data InSight
  • Pepper Reports
  • CGI Technologies and Solutions Inc httpracbcgicomContactInfoaspxst=1
  • CGI Federal RAC
  • How to survive RAC Audit
  • RAC Audits
  • How Did we get here
  • Where are we now
  • RAC Reviews
  • Priority Health SCIO Health Analytics
  • Cheer
  • References
Page 21: Medicare, Mange Care & Medicaid Changes in the New World we live in

Healthy Michigan Medicaid Days

21

McLaren Health Plan

22

Manage Medicaid Plans January 1bull Region 1 ndash Upper Peninsula Health Planbull Region 2 ndash McLaren Health Plan Meridian Health Plan of Michigan Molina Healthcare of Michigan

UnitedHealthcare Community Planbull Region 3 ndash McLaren Health Plan Meridian Health Plan of Michigan Molina Healthcare of Michigan

UnitedHealthcare Community Planbull Region 4 ndash Blue Cross Complete of Michigan McLaren Health Plan Meridian Health Plan of Michigan Molina

Healthcare of Michigan Priority Health Choice UnitedHealthcare Community Planbull Region 5 ndash McLaren Health Plan Meridian Health Plan of Michigan Molina Healthcare of Michigan

UnitedHealthcare Community Planbull Region 6 ndash Blue Cross Complete of Michigan HAP Midwest Health Plan McLaren Health Plan Meridian Health

Plan of Michigan Molina Healthcare of Michigan UnitedHealthcare Community Planbull Region 7 ndash Blue Cross Complete of Michigan McLaren Health Plan Meridian Health Plan UnitedHealthcare

Community Planbull Region 8 ndash Aetna Better Health of Michigan McLaren Health Plan Meridian Health Plan of Michigan Molina

Healthcare of Michigan Priority Health Choice UnitedHealthcare Community Planbull Region 9 ndash Aetna Better Health of Michigan Blue Cross Complete of Michigan McLaren Health Plan Meridian

Health Plan of Michigan Molina Healthcare of Michigan UnitedHealthcare Community Planbull Region 10 ndash Aetna Better Health of Michigan Blue Cross Complete of Michigan Harbor Health Plan McLaren

Health Plan Meridian Health Plan of Michigan Molina Healthcare of Michigan Total Health Care UnitedHealthcare Community Plan 23

24

MI Health LinkWhere are we

25

MI Health Link 2565

bull This notification is being sent to providers of long term care services including nursing facilities county medical care facilities and hospital long term care units to provide clarification on the process involved with the submission of the Facility Admission Form (MSA-2565-C) for an individual enrolled in the MI Health Link program

bull The MI Health Link program covers the custodiallong term nursing facility service benefit When an individual who is enrolled in the MI Health Link program is admitted to a nursing facility for custodiallong term nursing services a disenrollment from the Integrated Care Organization (MI Health Link health plan) is NOT REQUIRED The Facility Admission Form (MSA-2565-C) should NOT be sent to the Michigan Department of Health and Human Services (MDHHS) Enrollment Services Section for a disenrollment to be processed

26

What are the Names

bull Started as Integrated Health

bull Then called MMP (Medicare Medicaid Program)

bull Duals (Also Known as Duals as in Dual Eligible)

bull Now called MI Health Link

bull Total confusion

27

MI Health Dual Eligible28

MI Health LOC

29

LOC Medicaidbull We have the new pilot program which started on March

1 2015 in Southwest Michigan Region 4 Counties Macomb Wayne and the UP You could see these patients they are dual eligible in the Pilot program in counties surrounding the pilot

bull MHL-LOC 005 (All other Facilities) or LOC 015 (County Care) These residents have to call Michigan Enrolls to dis-enroll toll-free at 1-800-975-7630 (TTY 1-888-263-5897) Monday-Friday from 8 AM to 7 PM Once they dis-enroll they will go to a LOC 02 you have to do a new LOCD

30

Medicaid Redetermination and MHL Enrollmentbull At the time of re-determination for Medicaid financial eligibility the MI

Health Link (MHL) program will not be sending beneficiaries information about this program Beneficiaries who previously opted out will not be passively enrolled according to an email from the MHL staff The MHL staff wrote

bull ldquoThere is currently no MI Health Link enrollment letter sent to beneficiaries when eligibility is re-determined A person who becomes eligible for MI Health Link enrollment may opt-in at any time

bull When Medicaid re-determination takes place the beneficiary remains in the same ICO unless that beneficiary lost Medicaid coverage If the enrollee loses Medicaid coverage and later regains it they are not passively enrolled into MI Health Link The beneficiary may choose to opt back in to the program at that time if desiredrdquo

bull MHL staff did state that about 1500 beneficiaries will be passively enrolled effective January 1 2016 These specific individuals were given normal notice of 60 and 30 days in which to opt-in or opt-out if they so chose No other large scale passive enrollment is scheduled according to the MHL staff 31

MI Health Link Portals

bull Meridian Health Planbull httpwwwmhplancommibull Amerihealthbull httpwwwamerihealthcaritasvipcarepluscomproviderself-service-

toolsindexaspxbull AetnaCoventrybull httpwwwaetnabetterhealthcomMichiganprovidersportalbull Molinabull httpwwwmolinahealthcarecommembersmien-usmemPageshomeaspxbull HAPMidwestbull httpswwwmidwesthealthplancomLoginaspxbull FidelisCentenebull wwwfidelissccommmp 32

MI Health Authorizationsbull We need to watch these authorization that the plans are giving us for the MI

Health program Some plans are assigning a diagnosis for residents in their prior authorizations They are assigning diagnosis that the residents do not even have You need to make sure these are correct diagnosis and if not you need to work with the case managers of the plans to fix the issue The authorization numbers do change

bull Make sure that any resident that is in a MI Health plan that you have a prior authorization All plans are giving different periods authorizing the residents stay in the facility You need to set up a system to make sure you always have a authorization for the period of time you are rendering the service Here is an example of time frame of authorizations

bull Meridian is authorizing 12 monthsbull Aetna is authorizing 3 monthsbull Molina is authorizing 6 monthsbull The authorization numbers need to go on your claims to the payer You need to

put the authorizations in your software and track the dates

33

MI Health Issuesbull We are seeing some issues with MI Health where the resident does not have the correct LOC or it shows

up correct on CHAMPS but ancillary providers such as Dentist and such cannot see it I think we still have some issues with the information crossing between Bridges DHS system CMS and CHAMPS It in return is creating some access of care issues If it is a true LOC issues Facilities with LOC issues need to submit the Medicaid ID numbers to the MSA-MHL-EnrollmentMichigangov box with the subject line Nursing home LOC Issue so they may work to resolve the issues

bull If it becomes an access to care issue email the information to INTEGRATEDCAREmichigangov Remember in these emails only send the Medicaid ID and explain the situation The State will work with the plans to try to fix the process or improve the process

bull We are also seeing with new admission with LOC 015 or 005 that the plans are stating they have 14 days to authorize admission These are resident in the emergency room and possibly be admitted to you for Rehab The hospital will not keep the resident in ER for 14 days and you cannot admit the resident until you have a prior authorization I would recommend when you are told this by the plan that you need to ask to speak to a manager We will have to work through this

bull Ancillary Provider You need to work with your ancillary providers such as Lab Pharmacy X-Ray Physician and such to get the to be credentialed with the plans We are hearing that some of the pharmacies are not participating with the plans this will create issues for you so I would continue to ask these groups to participate

34

LOC 02 dropping MI Health Issuesbull The passive enrollments have occurred in Macomb amp Wayne for

Medicaid dual eligible We are having the same issue we did as in the Southwest MI amp UP with the passive enrollments I am starting to hear from facilities who are checking there CHAMPS member screens that those residents that have opted out (some residents not all) have lost there 02 Make sure you are checking your CHAMPS member screen both for those that were passively enrolled and those that might have lost there 02 Medicaid that opted out

bull Facilities with LOC issues need to submit the Medicaid ID numbers to the (Only MI Health)MSA-MHL-Enrollmentmichigangov box with the subject line Nursing home LOC Issue so they may work to resolve the issues

35

PPA Offset

bull There are no co-pays deductibles or premiums in MI Health Link so there should be no need to offset the PPA with code 25 MI Health Link enrollees can continue to offset their PPA for non-program covered medical expenses (like Vision-Code 27 Dental-Code 28 and Hearing-Code 26) and use the appropriate codes to offset the PPA when billing the health plan for nursing facility services

bull Resident pay PPA when MedicareMedicaid coinsurance

36

LOCDbull Nursing Facility Level of Care Determination (NFLOCD)

bull The MI Health Link health plan will be responsible for conducting the Michigan Medicaid NFLOCD tool for enrollees seeking admission to a nursing facility For existing residents at the time of enrollment the existing NFLOCD will be adopted for capitation payment purposes The health plan will complete a new NFLCOD tool within the first 90 days of enrollment If a nursing facility resident is disenrolled from MI Health Link the nursing facility will be responsible for conducting a new NFLOCD tool in accordance with published Medicaid policy

37

MI Health Issues-New

bull INTEGRATEDCAREmichigangov

bull Email with Insurance Plan issues Case Manager Issues

38

ACOWhat are they

39

Families Receiving Letters for ACO

40

ACO What is It

bull Whats an ACObull Accountable Care Organizations (ACOs) are groups of doctors hospitals

and other health care providers who come together voluntarily to give coordinated high quality care to their Medicare patients

bull The goal of coordinated care is to ensure that patients especially the chronically ill get the right care at the right time while avoiding

unnecessary duplication of services and preventing medical errorsbull When an ACO succeeds both in delivering high-quality care and

spending health care dollars more wisely it will share in the savings it achieves for the Medicare program

41

Payroll Based JournalMandatory on July 1 2016Internet Explorer Version

Internet Explorer v 10 and v 11 will need to operate in compatibility mode

42

43

If you submit data manually should you also submit it through the XML

bull Now you have three options

bull Submit Manually only

bull Submit through the XML only

bull You are able to submit manually and using the XML

44

45

Staffing Submission Frequently Asked Questions

bull ldquoWho are direct care staffrdquo (Who do we submit data for)bull Submission of data for contract staffbull Medical directors and consultantsbull Staff switching roles or tasks throughout the daybull Hours paid vs hours worked ndash Must be verifiablebull Public postingQuality MeasuresFive Starbull Enforcementbull Voluntary submission risks (noneSo register now)

CMS defines

bull 37 job title codes that are required to match employees to the number of hours each direct care function was performed It is important to work with your teams to define the workers that contribute to each job type and how those daily worked hours are recorded and converted to a PBJ submission

bull The PBJ does include some more specific job descriptions than the 671 For example the PBJ system includes job descriptions for RNs with administrative duties and LPNs with administrative duties versus the 671rsquos more general ldquoNurses with Administrative Duties

Page 46

47

PBJ Medical Director Rolebull Physician Leadership

bull Help the facility ensure that patients have appropriate physician coverage and ensure the provision of physician and health care practitioner services and

bull Help the facility develop a process for reviewing physician and health care practitioner credentials

bull Provide specific guidance for physician performance expectations

bull Help the facility ensure that a system is in place for monitoring the performance of health care practitioners and

bull Facilitate feedback to physicians and other health care practitioners on performance and practices

bull Patient Care - Clinical Leadership

bull Participate in administrative decision-making and the development of policies and procedures related to patient care

bull Help develop approve and implement specific clinical practices for the facility to incorporate into its care-related policies and procedures including areas required by laws and regulations

bull Develop procedures and guidance for facility staff regarding contacting practitioners including information gathering and presentation change in condition assessment and when to contact the medical director

bull Review consider andor act upon consultant recommendations as appropriate that affect the facilitys resident care policies and procedures or the care of an individual resident

bull Review respond to and participate in federal state local and other external surveys and inspections and

bull Help review policies and procedures regarding the adequate protection of patients rights advance care planning and other ethical issues48

PBJ Medical Director Rolebull Quality of Care

bull Help the facility establish systems and methods for reviewing the quality and appropriateness of clinical care and other health-related services and provide appropriate feedback and

bull Participate in the facilitys quality improvement process

bull Advise on infection control issues and approve specific infection control policies to be incorporated into facility policies and procedures

bull Help the facility provide a safe and caring environment

bull Help promote employee health and safety and

bull Assist in the development and implementation of employee health policies and programs

bull Education Information and Communication

bull Promote a learning culture within the facility by educating informing and communicating

bull Provide information to help the facility provide care consistent with current standards of practice (defined as approaches to care procedures techniques and treatments that are based on research and or expert consensus and that are contained in current manuals textbooks and or publications or that are accepted adopted or promulgated by recognized organizations or national bodies)

bull Help the facility develop medical information and communication systems with staff patients and families and others

bull Represent the facility to the professional and lay community on medical and patient care issues

bull Maintain knowledge of the changing social regulatory political and economic factors that affect medical and health services of long term care patients and

bull Help establish appropriate relationships with other health care organizations

49

Dietician

bull When the dietary or food services supervisor is other than a registered dietitian the supervisor shall receive routine consultation and technical assistance from a registered dietitian (RD) Consultation time shall not be less than 4 hours every 60 days Additional consultation time may be needed based on the total number of patients incidence of nutrition-related health problems and food service management needs of the facility

50

Pharmacy Consultant

bull At least once per month a licensed pharmacist must perform a drug regimen review (DRR) for each resident The pharmacist must report any irregularities to the attending physician or director of nursing Furthermore these reports must be acted upon

51

What are the names for the Medicare Numberbull OSCAR -Online Survey Certification and Reporting

bull PTAN-PTAN number is assigned by Medicare to authenticate the provider when using the local Medicare Administrative Contractorrsquos (MAC) self-help tools like the IVR internet portal on-line application status etc Provider Transactions Access Number

bull CCN- CMS Certification Number

bull Medicare Number- example 23-

bull All of the above mean the same thing

52

QTSO

bull Once you are logged in the QTSO site bull You will have a state login to the site to access the various site specific

to your facilitybull Installing you will need administrator rights to your network

53

Medicare UpdateWhat are we seeing

54

CMS Final Rule On Returning Credits

httpswwwfederalregistergovarticles201602122016-02789medicare-program-reporting-and-returning-of-overpayments

55

Over Payment Rule

bull Medicare payments for non covered services

bull Medicare payments in excess of the allowable amount for an identified covered service

bull Errors and non reimbursable expenditures in cost reportsbull Duplicate payment

bull Receipt of Medicare payments when another payor had the primary responsibility for payment

56

Questions to MAC

bull Does the Medicare credit balance report change with this overpayment rule

bull No Medicare Credit Balances are still required at the end of each quarter

bull Will that still be the communication to let CMS or the MAC know that we have received an overpayment

bull Submission of Medicare Credit Balance is one form of communicating overpayments to CMS Other methods include submitting a voluntary refund with required claim information or the submission of a standard overpayment form

57

Questions to MAC

bull Will the MAC still deduct from a future RAbull If the recovery of the overpayment includes adjusting a claim then

the overpayment would be netted against future claims payments and reflected on the RA

bull Or will that process change with this new rulebull Process will remain the samebull Will NGS send communication out on thisbull Yes NGS will communicate this once the final rule is communicated

to the MACs by CMS However this could change depending on final CMS instructions

58

Final Rule on Returning Credits

bull Providers will want to immediately update their current policies governing overpayments in order to comply with this new rule which will take effect on March 14 2016

bull Providers and suppliers are required to use reasonable diligence to investigate credible information regarding overpayments through both proactive compliance efforts and reactive investigations

bull If an overpayment is identified then it must be repaid within 60 days An overpayment is identified when a person has or should have through the exercise of reasonable diligence determined that the person received an overpayment and quantified the amount

bull Providers and suppliers have a maximum of 8 months to report and return overpayments ndash up to 6 months to investigate and quantify the overpayment (ie to identify it) and up to 60 days to report and return the overpayment

59

Final Rule on Returning Credits

bull Providers and suppliers are required to report and return all overpayments within a 6-year lookback period

bull The cause and amount of the overpayment is irrelevant for the determination eg it was due to a mistake it was someone elsersquos fault it is a minor amount An overpayment is an overpayment and must be returned

bull Providers and suppliers must make their own determination to which entity to report and return the overpayment ie to the Medicare contractor or using the OIG Self Disclosure Protocol or the CMS Self Referral Disclosure Protocol

60

Final Rule on Returning Credits

bull Providers and suppliers may use the claims adjustment credit balance self-reported refund process or another appropriate process to report and return overpayments At this time there is no standard refund form to use

bull Failure to report and return an overpayment could subject the provider or supplier to False Claims Act liability Civil Monetary Penalties Law liability and exclusion from federal health care programs

61

P S amp R-Accountants will be asking for this information

The location you login into has changed it is now on EIDM EIDM is the acronym for CMS Enterprise Identity Management system which includes Identity Verification Access Management Authorization Assistance Workflow Tools and Identity Lifecycle Management functions

httpswwwcmsgovResearch-Statistics-Data-and-SystemsCMS-Information-TechnologyIACSCMS-Applications-Loginhtml

Go down the page and click on the PSampRSTARThis will take you to the login pagewill look the same as the old P S amp R didChanges Affecting PSampR System Access (Please Read) (posted 01292015)(Updated 5262015)is changingThe system which controls your PSampR user ID (currently IACS)The new system is referred to as EIDMThis will result in a different way to create new accounts or change passwords to existing accountsIf you already have an account in EIDM you may have to use that account for accessing PSampR after the transitionWhen is the change effectiveJune 13 2015What is staying the sameThe internet address for accessing PSampR remains the sameThe PSampR systemfunctionality is NOT changing 62

Medicare Advantage Payorsbull Medicare Advantage payors are pullingdenying payments on admissions if the patient was readmitted within 30 days after discharge The

client believes that the payors systematically denying payments for all readmissions within 30 days They believe this practice denies them due process to address whether the readmissions were justified and not due to a premature discharge of patient The payors seem to want to act like a QIO without having the same accountabilities of the QIO related to determinations of non-payment

bull Heres the QIO process under section 4240 of the QIO Manualbull 4240 - Readmission Review - (Rev 2 07-11-03)bull Readmission review involves admissions to an acute general short-term hospital occurring less than 31 calendar days from the date of

discharge from the same or another acute general short-term hospital (see sect1154(a)(13) and 42 CFR 47671(a)(8)(ii)) Neither the day of discharge nor the day of admission is counted when determining whether a readmission has occurred

bull A Medical Review Proceduresbull Obtain the appropriate medical records for the initial admission and readmission Perform case review on both stays Analyze the cases

specifically to determine whether the patient was prematurely discharged from the first confinement thus causing readmission Perform an analysis of the stay at the first hospital to determine the cause(s) and extent of any problem(s) (eg incomplete or substandard treatment) Consider the information available to the attending physician who discharged the patient from the first confinement Do not base a determination of a premature discharge on information that the physician or provider could not have known or events that could not have been anticipated at the time of discharge

bull Review both the initial admission and the readmission at the same time unless one of them has previously been reviewed In these cases use at a minimum the PRAF case summary of the other admission in addition to the medical record of the case under review

bull C Denialsbull Deny readmissions under the following circumstancesbull If the readmission was medically unnecessarybull If the readmission resulted from a premature discharge from the same hospital orbull If the readmission was a result of circumvention of PPS by the same hospital (see sect4255)bull With the QIO process there is an appeal within the QIO here the hospital is getting no opportunity to challenge the denials

63

Medicare Provider Enrollment Feebull Provider Enrollment Application Fee Amount for CY 2016bull On December 3 CMS issued a notice Provider Enrollment Application

Fee Amount for CY 2016 [CMSndash6066ndashN] Effective January 1 2016 the CY 2016 application fee is $554 for institutional providers that are

bull Initially enrolling in the Medicare or Medicaid program or the Childrens Health Insurance Program (CHIP)

bull Revalidating their Medicare Medicaid or CHIP enrollmentbull Adding a new Medicare practice locationbull This fee is required with any enrollment application submitted from

January 1 through December 31 2016

64

Medicare MAC-Higlas

bull Effective 142016 CMS has implemented a change to begin netting (offsetting) provider money across workloads within a single organization What this means is that any related providers conducting business in two different workloads (example New York and Maine) will have their money applied to any account receivables (AR) with a remaining balance owed to Medicare within both workloads For example Provider ABC is located in New York and is scheduled to receive a payment of $1000 on todays remittance advice Provider XYZ is related to provider ABC but is located in Maine and has ARs with a balance owed of $200 Provider ABCs $1000 payment will have the $200 applied against provider XYZs ARs resulting in a net payment of $800 This will be reflected on the remittance advice by the same PLB code as seen today for offsets for the $200

65

Two Midnight RuleChange January 1 2016 httpswwwcmsgovMedicareMedicare-Fee-for-Service-PaymentHospitalOutpatientPPSHospital-Outpatient-Regulations-and-Notices-ItemsCMS-1633-FChtml

66

Two Midnight Rulebull However effective January 1 2016 CMS will allow exceptions to the

Two-Midnight Benchmark to be determined on a case-by-case basis by the physician responsible for the care of the beneficiary subject to medical review Said differently Part A payment may be appropriate in some circumstances even though there is no expectation by the physician (or qualified ordering practitioner) of a two-midnight stay and one of the two pre-existing categorical exceptions (CMS ldquoinpatient onlyrdquo list and newly initiated mechanical ventilation) does not apply CMS has indicated that this change to the Two Midnight Rule is in response to stakeholder concern and CMSrsquos continued efforts to develop the most appropriate standard for determining Medicare Part A payment

67

Two Midnight Rulebull A new 42 CFR sect4123(a) provides that a patient is considered an

inpatient of a hospitalhellipif formally admitted as an inpatient pursuant to an order for inpatient admission by a physician or other qualified practitionerhellip The physician orders inpatient status when he or she expects the patient to require a stay that crosses at least 2 midnights[10] Stays expected to be shorter than at least two midnights are generally inappropriate for inpatient admission and inpatient payment under Medicare Part A unless the surgical procedure is specified by Medicare as inpatient only under sect41922(n)[11] The physicians expectationhellipshould be based on such complex medical factors as patient history and comorbidities the severity of signs and symptoms current medical needs and the risk of an adverse event[12] The physician order is part of physician certification of the medical necessity of hospital inpatient serviceshellip[13]

68

InPatient Vs Observation Conthellip

bull Physician certification which begins with an order for inpatient admission requires the physician to certify the reasons for the hospitalization the estimated time the patient will remain in the hospital and plans for post-hospital care if appropriate[14] The certification must be completed signed and documented in the medical record prior to discharge[15]

bull A physicians admission order has no presumptive weight and both the admission order and the physician certification will be evaluated in the context of the evidence in the medical record[16] CMS intends to provide additional information about what evidence in the medical record means in future instructions and manual revisions[17]

69

Two Midnight Rulebull Although the new case-by-case exception appears to be inherently

subjective to a certain extent CMS states that the following factors (among others) would be relevant to determining whether a patient requires inpatient admission under the expanded policy

bull The severity of the signs and symptoms exhibited by the patient bull The medical predictability of something adverse happening to the patient

and bull The need for diagnostic studies that appropriately are outpatient services

(that is their performance does not ordinarily require the patient to remain at the hospital for 24 hours or more)

bull CMS also notes that an inpatient admission (and Part A payment) should be ldquorare and unusualrdquo for minor surgical procedures or other treatment that is expected to keep the patient in the hospital ldquofor only a few hoursrdquo or for a period of time that ldquodoes not span at least overnightrdquo (thus a subset of stays not meeting the Two Midnight Benchmark) CMS indicates that such cases will be prioritized for medical review

70

Health Data Insights amp Medicare Plus Blue

RAC (Retrospective Audits)

71

HDI Health Data amp Med Plus Blue

bull httpwwwhealthdatainsightscombull Blue Cross Medicare Advantage Auditsbull Facilities seeing 10 to 15 requests for Medical Recordsbull In January amp Feburarybull Selected Health Data Insights because they were a premier Audit

Vendor for CMS Recovery Audit Contractor (RAC) demonstration Project They are a audit vendor for Humana

bull Providers not sending Medical Record will get technical denial and lose payments

72

Health Data InSight

bull In 2010 they began the Hospital Reviewbull Medicare Advantage encounter datandashCMS oversight of data integrity OIG

2016bull We will review CMSs oversight of MA encounter data validation and assess

the extent to which CMSrsquos Integrated Data Repository contains timely valid and complete MA encounter data In 2012 CMS began collecting from MA organizations a more comprehensive set of encounter data reflecting the items and services provided to MA plan enrollees Prior CMS and OIG audits have indicated vulnerabilities in the accuracy of data reporting by MA organizations Realizing the potential benefits of the MA encounter data for payment and program integrity oversight is contingent upon the datarsquos completeness validity and timeliness (OEI 03-15-00060 expected issue date FY 2017)

73

Pepper Reports

bull httpswwwpepperresourcesorg

bull Program for Evaluating Payment Patterns Electronic Report ( PEPPER)

bull Annually on or about April 18 2016 will be released

bull Pepper Portal httpssecurefiletmforg

74

CGI Technologies and Solutions Inc httpracbcgicomContactInfoaspxst=1

bull Indiana bull Michiganbull Minnesotabull Illinoisbull Kentuckybull Ohiobull Wisconsin CGI Technologies and Solutions Incbull For general and administrative questions regarding client service outreach

quality assurance or project-specific issues contactbull 1877316RACB (7222)bull Email racbcgicom Tamara Tate Tamaratatecmshhsgovbull 4107861288

75

CGI Federal RAC

bull CGI Federal RAC Region Bbull Email racbcgicombull Phone 1-877-316-RACB (7222)bull Mailing Addressbull Send medical records as followsbull Medical records for Indiana Illinois Kentucky Michigan Ohio Wisconsin

Minnesota DME and Home Health CGI Federal Inc Attn RACB Imaging Dept 1001 Lakeside Ave Suite 800 Cleveland OH 44114

bull If submitting paper records please send medical records as follows For Therapy Reviews CGI Federal Inc Attn RACB Imaging 1001 Lakeside Avenue Suite 800 Cleveland OH 44114

76

How to survive RAC Audit

bull National health expenditures totaled $1679 Billion in 2003 bull National health expenditures were 153 of GROSS Domestic Product

(GDP) in 2003 bull Health care cost increasing at +9 per year bull Doomsday predictions of Medicare running out bull Congressional Action

77

RAC Audits

bull Medicare Modernization Act (MMA) of 2003Mandated a three year audit demonstration project 2005-2008

bull Appoint audit contractors to review Medicare billings for proper coding DRG assignment and medical necessity

bull Audits will apply to all health care providers (hospitals physicians homecare dme etc)

bull Audit contractors to be paid on a contingency basis a percentage of overpayments recovered

78

How Did we get here

bull Overpayments collected due to errors in Medically Unnecessary Services ndash 40

bull Incorrectly Coded ndash 35

bull Other ndash 17

bull NoInsufficient Documentation ndash 8

79

Where are we now

bull All RACrsquos completed required provider outreachAccess to Medicare billing data base given to all RAC RAC review methodology

bull Automated Review-Black amp White Issues (current) bull DRG Validation-complex review (current) bull Complex Review for coding errors (current) bull DME Medical Necessity Reviews ndashcomplex review (calendar year

2010) bull Medical Necessity Reviews-complex review (calendar year 2010)

80

RAC Reviews

bull Responsibilities of the Team Leader bull Must learn each insurance provider participating in a RAC or RAC type

program bull What are their operating rulesbull What is their appeal process Time limits

May be different process for each insurance provider bull Develop a response team

Identify who does what when why and alternate bull individual

Build and develop a manual process Review of computerized system

81

Priority Health SCIO Health Analytics

bull httpswwwsciohealthanalyticscomcore-capabilitiespayment-integrityfacility-auditsskilled-nursing-facility-audits

bull Claims for Medicare members treated at Skilled Nursing Facilities are reimbursed based on the patientsrsquo RUG (Resource Utilization Group) score which is determined using the Minimum Data Set (MDS) Using SCIOs robust analytics claims andor providers that merit review are selected for audit SCIOs auditors conduct a detailed review of the complete medical record and associated MDS to determine if the billed RUG score is valid In the event the review determines that an incorrect RUG score was billed SCIOreg provides the valid score reports the reason the change was necessary and calculates the resulting overpayment

82

+ Cheer

Onward and Upward she shall prevail We are here to care for the residents and provide a wonderful

service

13 83

84

References

bull Priority Healthbull Blue Crossbull Medicaidbull Medicare

85

  • Medicare Mange Care amp Medicaid Changes in the New World We Live In
  • Medicaid
  • NEW Medicaid Change MIlogin
  • Blueprint for Health Innovation MI
  • Provider Enrollment Electronic Signature Form Submission Process MSA 15-54
  • Provider Enrollment Electronic Signature Form Submission Process
  • Provider Enrollment Domain Administrator
  • Medicaid Coinsurance Medicare Advantage
  • Slide Number 9
  • Lawsuit DHS Changes on Caregivers
  • TPL Medicaid Change
  • CHAMPS Member Screen
  • LOC dropping off Not Due to MI Health
  • Issues
  • Secure Email Information
  • Medicaid amp Hospice
  • Medicaid
  • Medicaid Medicare Buy In
  • Manage Medicaid
  • Healthy Michigan Residents
  • Healthy Michigan Medicaid Days
  • McLaren Health Plan
  • Manage Medicaid Plans January 1
  • Slide Number 24
  • MI Health Link
  • MI Health Link 2565
  • What are the Names
  • MI Health Dual Eligible
  • MI Health LOC
  • LOC Medicaid
  • Medicaid Redetermination and MHL Enrollment
  • MI Health Link Portals
  • MI Health Authorizations
  • MI Health Issues
  • LOC 02 dropping MI Health Issues
  • PPA Offset
  • LOCD
  • MI Health Issues-New
  • ACO
  • Families Receiving Letters for ACO
  • ACO What is It
  • Payroll Based Journal
  • Slide Number 43
  • If you submit data manually should you also submit it through the XML
  • Staffing Submission Frequently Asked Questions
  • CMS defines
  • Slide Number 47
  • PBJ Medical Director Role
  • PBJ Medical Director Role
  • Dietician
  • Pharmacy Consultant
  • What are the names for the Medicare Number
  • QTSO
  • Medicare Update
  • CMS Final Rule On Returning Credits
  • Over Payment Rule
  • Questions to MAC
  • Questions to MAC
  • Final Rule on Returning Credits
  • Final Rule on Returning Credits
  • Final Rule on Returning Credits
  • Slide Number 62
  • Medicare Advantage Payors
  • Medicare Provider Enrollment Fee
  • Medicare MAC-Higlas
  • Two Midnight Rule
  • Two Midnight Rule
  • Two Midnight Rule
  • InPatient Vs Observation Conthellip
  • Two Midnight Rule
  • Health Data Insights amp Medicare Plus Blue
  • HDI Health Data amp Med Plus Blue
  • Health Data InSight
  • Pepper Reports
  • CGI Technologies and Solutions Inc httpracbcgicomContactInfoaspxst=1
  • CGI Federal RAC
  • How to survive RAC Audit
  • RAC Audits
  • How Did we get here
  • Where are we now
  • RAC Reviews
  • Priority Health SCIO Health Analytics
  • Cheer
  • References
Page 22: Medicare, Mange Care & Medicaid Changes in the New World we live in

McLaren Health Plan

22

Manage Medicaid Plans January 1bull Region 1 ndash Upper Peninsula Health Planbull Region 2 ndash McLaren Health Plan Meridian Health Plan of Michigan Molina Healthcare of Michigan

UnitedHealthcare Community Planbull Region 3 ndash McLaren Health Plan Meridian Health Plan of Michigan Molina Healthcare of Michigan

UnitedHealthcare Community Planbull Region 4 ndash Blue Cross Complete of Michigan McLaren Health Plan Meridian Health Plan of Michigan Molina

Healthcare of Michigan Priority Health Choice UnitedHealthcare Community Planbull Region 5 ndash McLaren Health Plan Meridian Health Plan of Michigan Molina Healthcare of Michigan

UnitedHealthcare Community Planbull Region 6 ndash Blue Cross Complete of Michigan HAP Midwest Health Plan McLaren Health Plan Meridian Health

Plan of Michigan Molina Healthcare of Michigan UnitedHealthcare Community Planbull Region 7 ndash Blue Cross Complete of Michigan McLaren Health Plan Meridian Health Plan UnitedHealthcare

Community Planbull Region 8 ndash Aetna Better Health of Michigan McLaren Health Plan Meridian Health Plan of Michigan Molina

Healthcare of Michigan Priority Health Choice UnitedHealthcare Community Planbull Region 9 ndash Aetna Better Health of Michigan Blue Cross Complete of Michigan McLaren Health Plan Meridian

Health Plan of Michigan Molina Healthcare of Michigan UnitedHealthcare Community Planbull Region 10 ndash Aetna Better Health of Michigan Blue Cross Complete of Michigan Harbor Health Plan McLaren

Health Plan Meridian Health Plan of Michigan Molina Healthcare of Michigan Total Health Care UnitedHealthcare Community Plan 23

24

MI Health LinkWhere are we

25

MI Health Link 2565

bull This notification is being sent to providers of long term care services including nursing facilities county medical care facilities and hospital long term care units to provide clarification on the process involved with the submission of the Facility Admission Form (MSA-2565-C) for an individual enrolled in the MI Health Link program

bull The MI Health Link program covers the custodiallong term nursing facility service benefit When an individual who is enrolled in the MI Health Link program is admitted to a nursing facility for custodiallong term nursing services a disenrollment from the Integrated Care Organization (MI Health Link health plan) is NOT REQUIRED The Facility Admission Form (MSA-2565-C) should NOT be sent to the Michigan Department of Health and Human Services (MDHHS) Enrollment Services Section for a disenrollment to be processed

26

What are the Names

bull Started as Integrated Health

bull Then called MMP (Medicare Medicaid Program)

bull Duals (Also Known as Duals as in Dual Eligible)

bull Now called MI Health Link

bull Total confusion

27

MI Health Dual Eligible28

MI Health LOC

29

LOC Medicaidbull We have the new pilot program which started on March

1 2015 in Southwest Michigan Region 4 Counties Macomb Wayne and the UP You could see these patients they are dual eligible in the Pilot program in counties surrounding the pilot

bull MHL-LOC 005 (All other Facilities) or LOC 015 (County Care) These residents have to call Michigan Enrolls to dis-enroll toll-free at 1-800-975-7630 (TTY 1-888-263-5897) Monday-Friday from 8 AM to 7 PM Once they dis-enroll they will go to a LOC 02 you have to do a new LOCD

30

Medicaid Redetermination and MHL Enrollmentbull At the time of re-determination for Medicaid financial eligibility the MI

Health Link (MHL) program will not be sending beneficiaries information about this program Beneficiaries who previously opted out will not be passively enrolled according to an email from the MHL staff The MHL staff wrote

bull ldquoThere is currently no MI Health Link enrollment letter sent to beneficiaries when eligibility is re-determined A person who becomes eligible for MI Health Link enrollment may opt-in at any time

bull When Medicaid re-determination takes place the beneficiary remains in the same ICO unless that beneficiary lost Medicaid coverage If the enrollee loses Medicaid coverage and later regains it they are not passively enrolled into MI Health Link The beneficiary may choose to opt back in to the program at that time if desiredrdquo

bull MHL staff did state that about 1500 beneficiaries will be passively enrolled effective January 1 2016 These specific individuals were given normal notice of 60 and 30 days in which to opt-in or opt-out if they so chose No other large scale passive enrollment is scheduled according to the MHL staff 31

MI Health Link Portals

bull Meridian Health Planbull httpwwwmhplancommibull Amerihealthbull httpwwwamerihealthcaritasvipcarepluscomproviderself-service-

toolsindexaspxbull AetnaCoventrybull httpwwwaetnabetterhealthcomMichiganprovidersportalbull Molinabull httpwwwmolinahealthcarecommembersmien-usmemPageshomeaspxbull HAPMidwestbull httpswwwmidwesthealthplancomLoginaspxbull FidelisCentenebull wwwfidelissccommmp 32

MI Health Authorizationsbull We need to watch these authorization that the plans are giving us for the MI

Health program Some plans are assigning a diagnosis for residents in their prior authorizations They are assigning diagnosis that the residents do not even have You need to make sure these are correct diagnosis and if not you need to work with the case managers of the plans to fix the issue The authorization numbers do change

bull Make sure that any resident that is in a MI Health plan that you have a prior authorization All plans are giving different periods authorizing the residents stay in the facility You need to set up a system to make sure you always have a authorization for the period of time you are rendering the service Here is an example of time frame of authorizations

bull Meridian is authorizing 12 monthsbull Aetna is authorizing 3 monthsbull Molina is authorizing 6 monthsbull The authorization numbers need to go on your claims to the payer You need to

put the authorizations in your software and track the dates

33

MI Health Issuesbull We are seeing some issues with MI Health where the resident does not have the correct LOC or it shows

up correct on CHAMPS but ancillary providers such as Dentist and such cannot see it I think we still have some issues with the information crossing between Bridges DHS system CMS and CHAMPS It in return is creating some access of care issues If it is a true LOC issues Facilities with LOC issues need to submit the Medicaid ID numbers to the MSA-MHL-EnrollmentMichigangov box with the subject line Nursing home LOC Issue so they may work to resolve the issues

bull If it becomes an access to care issue email the information to INTEGRATEDCAREmichigangov Remember in these emails only send the Medicaid ID and explain the situation The State will work with the plans to try to fix the process or improve the process

bull We are also seeing with new admission with LOC 015 or 005 that the plans are stating they have 14 days to authorize admission These are resident in the emergency room and possibly be admitted to you for Rehab The hospital will not keep the resident in ER for 14 days and you cannot admit the resident until you have a prior authorization I would recommend when you are told this by the plan that you need to ask to speak to a manager We will have to work through this

bull Ancillary Provider You need to work with your ancillary providers such as Lab Pharmacy X-Ray Physician and such to get the to be credentialed with the plans We are hearing that some of the pharmacies are not participating with the plans this will create issues for you so I would continue to ask these groups to participate

34

LOC 02 dropping MI Health Issuesbull The passive enrollments have occurred in Macomb amp Wayne for

Medicaid dual eligible We are having the same issue we did as in the Southwest MI amp UP with the passive enrollments I am starting to hear from facilities who are checking there CHAMPS member screens that those residents that have opted out (some residents not all) have lost there 02 Make sure you are checking your CHAMPS member screen both for those that were passively enrolled and those that might have lost there 02 Medicaid that opted out

bull Facilities with LOC issues need to submit the Medicaid ID numbers to the (Only MI Health)MSA-MHL-Enrollmentmichigangov box with the subject line Nursing home LOC Issue so they may work to resolve the issues

35

PPA Offset

bull There are no co-pays deductibles or premiums in MI Health Link so there should be no need to offset the PPA with code 25 MI Health Link enrollees can continue to offset their PPA for non-program covered medical expenses (like Vision-Code 27 Dental-Code 28 and Hearing-Code 26) and use the appropriate codes to offset the PPA when billing the health plan for nursing facility services

bull Resident pay PPA when MedicareMedicaid coinsurance

36

LOCDbull Nursing Facility Level of Care Determination (NFLOCD)

bull The MI Health Link health plan will be responsible for conducting the Michigan Medicaid NFLOCD tool for enrollees seeking admission to a nursing facility For existing residents at the time of enrollment the existing NFLOCD will be adopted for capitation payment purposes The health plan will complete a new NFLCOD tool within the first 90 days of enrollment If a nursing facility resident is disenrolled from MI Health Link the nursing facility will be responsible for conducting a new NFLOCD tool in accordance with published Medicaid policy

37

MI Health Issues-New

bull INTEGRATEDCAREmichigangov

bull Email with Insurance Plan issues Case Manager Issues

38

ACOWhat are they

39

Families Receiving Letters for ACO

40

ACO What is It

bull Whats an ACObull Accountable Care Organizations (ACOs) are groups of doctors hospitals

and other health care providers who come together voluntarily to give coordinated high quality care to their Medicare patients

bull The goal of coordinated care is to ensure that patients especially the chronically ill get the right care at the right time while avoiding

unnecessary duplication of services and preventing medical errorsbull When an ACO succeeds both in delivering high-quality care and

spending health care dollars more wisely it will share in the savings it achieves for the Medicare program

41

Payroll Based JournalMandatory on July 1 2016Internet Explorer Version

Internet Explorer v 10 and v 11 will need to operate in compatibility mode

42

43

If you submit data manually should you also submit it through the XML

bull Now you have three options

bull Submit Manually only

bull Submit through the XML only

bull You are able to submit manually and using the XML

44

45

Staffing Submission Frequently Asked Questions

bull ldquoWho are direct care staffrdquo (Who do we submit data for)bull Submission of data for contract staffbull Medical directors and consultantsbull Staff switching roles or tasks throughout the daybull Hours paid vs hours worked ndash Must be verifiablebull Public postingQuality MeasuresFive Starbull Enforcementbull Voluntary submission risks (noneSo register now)

CMS defines

bull 37 job title codes that are required to match employees to the number of hours each direct care function was performed It is important to work with your teams to define the workers that contribute to each job type and how those daily worked hours are recorded and converted to a PBJ submission

bull The PBJ does include some more specific job descriptions than the 671 For example the PBJ system includes job descriptions for RNs with administrative duties and LPNs with administrative duties versus the 671rsquos more general ldquoNurses with Administrative Duties

Page 46

47

PBJ Medical Director Rolebull Physician Leadership

bull Help the facility ensure that patients have appropriate physician coverage and ensure the provision of physician and health care practitioner services and

bull Help the facility develop a process for reviewing physician and health care practitioner credentials

bull Provide specific guidance for physician performance expectations

bull Help the facility ensure that a system is in place for monitoring the performance of health care practitioners and

bull Facilitate feedback to physicians and other health care practitioners on performance and practices

bull Patient Care - Clinical Leadership

bull Participate in administrative decision-making and the development of policies and procedures related to patient care

bull Help develop approve and implement specific clinical practices for the facility to incorporate into its care-related policies and procedures including areas required by laws and regulations

bull Develop procedures and guidance for facility staff regarding contacting practitioners including information gathering and presentation change in condition assessment and when to contact the medical director

bull Review consider andor act upon consultant recommendations as appropriate that affect the facilitys resident care policies and procedures or the care of an individual resident

bull Review respond to and participate in federal state local and other external surveys and inspections and

bull Help review policies and procedures regarding the adequate protection of patients rights advance care planning and other ethical issues48

PBJ Medical Director Rolebull Quality of Care

bull Help the facility establish systems and methods for reviewing the quality and appropriateness of clinical care and other health-related services and provide appropriate feedback and

bull Participate in the facilitys quality improvement process

bull Advise on infection control issues and approve specific infection control policies to be incorporated into facility policies and procedures

bull Help the facility provide a safe and caring environment

bull Help promote employee health and safety and

bull Assist in the development and implementation of employee health policies and programs

bull Education Information and Communication

bull Promote a learning culture within the facility by educating informing and communicating

bull Provide information to help the facility provide care consistent with current standards of practice (defined as approaches to care procedures techniques and treatments that are based on research and or expert consensus and that are contained in current manuals textbooks and or publications or that are accepted adopted or promulgated by recognized organizations or national bodies)

bull Help the facility develop medical information and communication systems with staff patients and families and others

bull Represent the facility to the professional and lay community on medical and patient care issues

bull Maintain knowledge of the changing social regulatory political and economic factors that affect medical and health services of long term care patients and

bull Help establish appropriate relationships with other health care organizations

49

Dietician

bull When the dietary or food services supervisor is other than a registered dietitian the supervisor shall receive routine consultation and technical assistance from a registered dietitian (RD) Consultation time shall not be less than 4 hours every 60 days Additional consultation time may be needed based on the total number of patients incidence of nutrition-related health problems and food service management needs of the facility

50

Pharmacy Consultant

bull At least once per month a licensed pharmacist must perform a drug regimen review (DRR) for each resident The pharmacist must report any irregularities to the attending physician or director of nursing Furthermore these reports must be acted upon

51

What are the names for the Medicare Numberbull OSCAR -Online Survey Certification and Reporting

bull PTAN-PTAN number is assigned by Medicare to authenticate the provider when using the local Medicare Administrative Contractorrsquos (MAC) self-help tools like the IVR internet portal on-line application status etc Provider Transactions Access Number

bull CCN- CMS Certification Number

bull Medicare Number- example 23-

bull All of the above mean the same thing

52

QTSO

bull Once you are logged in the QTSO site bull You will have a state login to the site to access the various site specific

to your facilitybull Installing you will need administrator rights to your network

53

Medicare UpdateWhat are we seeing

54

CMS Final Rule On Returning Credits

httpswwwfederalregistergovarticles201602122016-02789medicare-program-reporting-and-returning-of-overpayments

55

Over Payment Rule

bull Medicare payments for non covered services

bull Medicare payments in excess of the allowable amount for an identified covered service

bull Errors and non reimbursable expenditures in cost reportsbull Duplicate payment

bull Receipt of Medicare payments when another payor had the primary responsibility for payment

56

Questions to MAC

bull Does the Medicare credit balance report change with this overpayment rule

bull No Medicare Credit Balances are still required at the end of each quarter

bull Will that still be the communication to let CMS or the MAC know that we have received an overpayment

bull Submission of Medicare Credit Balance is one form of communicating overpayments to CMS Other methods include submitting a voluntary refund with required claim information or the submission of a standard overpayment form

57

Questions to MAC

bull Will the MAC still deduct from a future RAbull If the recovery of the overpayment includes adjusting a claim then

the overpayment would be netted against future claims payments and reflected on the RA

bull Or will that process change with this new rulebull Process will remain the samebull Will NGS send communication out on thisbull Yes NGS will communicate this once the final rule is communicated

to the MACs by CMS However this could change depending on final CMS instructions

58

Final Rule on Returning Credits

bull Providers will want to immediately update their current policies governing overpayments in order to comply with this new rule which will take effect on March 14 2016

bull Providers and suppliers are required to use reasonable diligence to investigate credible information regarding overpayments through both proactive compliance efforts and reactive investigations

bull If an overpayment is identified then it must be repaid within 60 days An overpayment is identified when a person has or should have through the exercise of reasonable diligence determined that the person received an overpayment and quantified the amount

bull Providers and suppliers have a maximum of 8 months to report and return overpayments ndash up to 6 months to investigate and quantify the overpayment (ie to identify it) and up to 60 days to report and return the overpayment

59

Final Rule on Returning Credits

bull Providers and suppliers are required to report and return all overpayments within a 6-year lookback period

bull The cause and amount of the overpayment is irrelevant for the determination eg it was due to a mistake it was someone elsersquos fault it is a minor amount An overpayment is an overpayment and must be returned

bull Providers and suppliers must make their own determination to which entity to report and return the overpayment ie to the Medicare contractor or using the OIG Self Disclosure Protocol or the CMS Self Referral Disclosure Protocol

60

Final Rule on Returning Credits

bull Providers and suppliers may use the claims adjustment credit balance self-reported refund process or another appropriate process to report and return overpayments At this time there is no standard refund form to use

bull Failure to report and return an overpayment could subject the provider or supplier to False Claims Act liability Civil Monetary Penalties Law liability and exclusion from federal health care programs

61

P S amp R-Accountants will be asking for this information

The location you login into has changed it is now on EIDM EIDM is the acronym for CMS Enterprise Identity Management system which includes Identity Verification Access Management Authorization Assistance Workflow Tools and Identity Lifecycle Management functions

httpswwwcmsgovResearch-Statistics-Data-and-SystemsCMS-Information-TechnologyIACSCMS-Applications-Loginhtml

Go down the page and click on the PSampRSTARThis will take you to the login pagewill look the same as the old P S amp R didChanges Affecting PSampR System Access (Please Read) (posted 01292015)(Updated 5262015)is changingThe system which controls your PSampR user ID (currently IACS)The new system is referred to as EIDMThis will result in a different way to create new accounts or change passwords to existing accountsIf you already have an account in EIDM you may have to use that account for accessing PSampR after the transitionWhen is the change effectiveJune 13 2015What is staying the sameThe internet address for accessing PSampR remains the sameThe PSampR systemfunctionality is NOT changing 62

Medicare Advantage Payorsbull Medicare Advantage payors are pullingdenying payments on admissions if the patient was readmitted within 30 days after discharge The

client believes that the payors systematically denying payments for all readmissions within 30 days They believe this practice denies them due process to address whether the readmissions were justified and not due to a premature discharge of patient The payors seem to want to act like a QIO without having the same accountabilities of the QIO related to determinations of non-payment

bull Heres the QIO process under section 4240 of the QIO Manualbull 4240 - Readmission Review - (Rev 2 07-11-03)bull Readmission review involves admissions to an acute general short-term hospital occurring less than 31 calendar days from the date of

discharge from the same or another acute general short-term hospital (see sect1154(a)(13) and 42 CFR 47671(a)(8)(ii)) Neither the day of discharge nor the day of admission is counted when determining whether a readmission has occurred

bull A Medical Review Proceduresbull Obtain the appropriate medical records for the initial admission and readmission Perform case review on both stays Analyze the cases

specifically to determine whether the patient was prematurely discharged from the first confinement thus causing readmission Perform an analysis of the stay at the first hospital to determine the cause(s) and extent of any problem(s) (eg incomplete or substandard treatment) Consider the information available to the attending physician who discharged the patient from the first confinement Do not base a determination of a premature discharge on information that the physician or provider could not have known or events that could not have been anticipated at the time of discharge

bull Review both the initial admission and the readmission at the same time unless one of them has previously been reviewed In these cases use at a minimum the PRAF case summary of the other admission in addition to the medical record of the case under review

bull C Denialsbull Deny readmissions under the following circumstancesbull If the readmission was medically unnecessarybull If the readmission resulted from a premature discharge from the same hospital orbull If the readmission was a result of circumvention of PPS by the same hospital (see sect4255)bull With the QIO process there is an appeal within the QIO here the hospital is getting no opportunity to challenge the denials

63

Medicare Provider Enrollment Feebull Provider Enrollment Application Fee Amount for CY 2016bull On December 3 CMS issued a notice Provider Enrollment Application

Fee Amount for CY 2016 [CMSndash6066ndashN] Effective January 1 2016 the CY 2016 application fee is $554 for institutional providers that are

bull Initially enrolling in the Medicare or Medicaid program or the Childrens Health Insurance Program (CHIP)

bull Revalidating their Medicare Medicaid or CHIP enrollmentbull Adding a new Medicare practice locationbull This fee is required with any enrollment application submitted from

January 1 through December 31 2016

64

Medicare MAC-Higlas

bull Effective 142016 CMS has implemented a change to begin netting (offsetting) provider money across workloads within a single organization What this means is that any related providers conducting business in two different workloads (example New York and Maine) will have their money applied to any account receivables (AR) with a remaining balance owed to Medicare within both workloads For example Provider ABC is located in New York and is scheduled to receive a payment of $1000 on todays remittance advice Provider XYZ is related to provider ABC but is located in Maine and has ARs with a balance owed of $200 Provider ABCs $1000 payment will have the $200 applied against provider XYZs ARs resulting in a net payment of $800 This will be reflected on the remittance advice by the same PLB code as seen today for offsets for the $200

65

Two Midnight RuleChange January 1 2016 httpswwwcmsgovMedicareMedicare-Fee-for-Service-PaymentHospitalOutpatientPPSHospital-Outpatient-Regulations-and-Notices-ItemsCMS-1633-FChtml

66

Two Midnight Rulebull However effective January 1 2016 CMS will allow exceptions to the

Two-Midnight Benchmark to be determined on a case-by-case basis by the physician responsible for the care of the beneficiary subject to medical review Said differently Part A payment may be appropriate in some circumstances even though there is no expectation by the physician (or qualified ordering practitioner) of a two-midnight stay and one of the two pre-existing categorical exceptions (CMS ldquoinpatient onlyrdquo list and newly initiated mechanical ventilation) does not apply CMS has indicated that this change to the Two Midnight Rule is in response to stakeholder concern and CMSrsquos continued efforts to develop the most appropriate standard for determining Medicare Part A payment

67

Two Midnight Rulebull A new 42 CFR sect4123(a) provides that a patient is considered an

inpatient of a hospitalhellipif formally admitted as an inpatient pursuant to an order for inpatient admission by a physician or other qualified practitionerhellip The physician orders inpatient status when he or she expects the patient to require a stay that crosses at least 2 midnights[10] Stays expected to be shorter than at least two midnights are generally inappropriate for inpatient admission and inpatient payment under Medicare Part A unless the surgical procedure is specified by Medicare as inpatient only under sect41922(n)[11] The physicians expectationhellipshould be based on such complex medical factors as patient history and comorbidities the severity of signs and symptoms current medical needs and the risk of an adverse event[12] The physician order is part of physician certification of the medical necessity of hospital inpatient serviceshellip[13]

68

InPatient Vs Observation Conthellip

bull Physician certification which begins with an order for inpatient admission requires the physician to certify the reasons for the hospitalization the estimated time the patient will remain in the hospital and plans for post-hospital care if appropriate[14] The certification must be completed signed and documented in the medical record prior to discharge[15]

bull A physicians admission order has no presumptive weight and both the admission order and the physician certification will be evaluated in the context of the evidence in the medical record[16] CMS intends to provide additional information about what evidence in the medical record means in future instructions and manual revisions[17]

69

Two Midnight Rulebull Although the new case-by-case exception appears to be inherently

subjective to a certain extent CMS states that the following factors (among others) would be relevant to determining whether a patient requires inpatient admission under the expanded policy

bull The severity of the signs and symptoms exhibited by the patient bull The medical predictability of something adverse happening to the patient

and bull The need for diagnostic studies that appropriately are outpatient services

(that is their performance does not ordinarily require the patient to remain at the hospital for 24 hours or more)

bull CMS also notes that an inpatient admission (and Part A payment) should be ldquorare and unusualrdquo for minor surgical procedures or other treatment that is expected to keep the patient in the hospital ldquofor only a few hoursrdquo or for a period of time that ldquodoes not span at least overnightrdquo (thus a subset of stays not meeting the Two Midnight Benchmark) CMS indicates that such cases will be prioritized for medical review

70

Health Data Insights amp Medicare Plus Blue

RAC (Retrospective Audits)

71

HDI Health Data amp Med Plus Blue

bull httpwwwhealthdatainsightscombull Blue Cross Medicare Advantage Auditsbull Facilities seeing 10 to 15 requests for Medical Recordsbull In January amp Feburarybull Selected Health Data Insights because they were a premier Audit

Vendor for CMS Recovery Audit Contractor (RAC) demonstration Project They are a audit vendor for Humana

bull Providers not sending Medical Record will get technical denial and lose payments

72

Health Data InSight

bull In 2010 they began the Hospital Reviewbull Medicare Advantage encounter datandashCMS oversight of data integrity OIG

2016bull We will review CMSs oversight of MA encounter data validation and assess

the extent to which CMSrsquos Integrated Data Repository contains timely valid and complete MA encounter data In 2012 CMS began collecting from MA organizations a more comprehensive set of encounter data reflecting the items and services provided to MA plan enrollees Prior CMS and OIG audits have indicated vulnerabilities in the accuracy of data reporting by MA organizations Realizing the potential benefits of the MA encounter data for payment and program integrity oversight is contingent upon the datarsquos completeness validity and timeliness (OEI 03-15-00060 expected issue date FY 2017)

73

Pepper Reports

bull httpswwwpepperresourcesorg

bull Program for Evaluating Payment Patterns Electronic Report ( PEPPER)

bull Annually on or about April 18 2016 will be released

bull Pepper Portal httpssecurefiletmforg

74

CGI Technologies and Solutions Inc httpracbcgicomContactInfoaspxst=1

bull Indiana bull Michiganbull Minnesotabull Illinoisbull Kentuckybull Ohiobull Wisconsin CGI Technologies and Solutions Incbull For general and administrative questions regarding client service outreach

quality assurance or project-specific issues contactbull 1877316RACB (7222)bull Email racbcgicom Tamara Tate Tamaratatecmshhsgovbull 4107861288

75

CGI Federal RAC

bull CGI Federal RAC Region Bbull Email racbcgicombull Phone 1-877-316-RACB (7222)bull Mailing Addressbull Send medical records as followsbull Medical records for Indiana Illinois Kentucky Michigan Ohio Wisconsin

Minnesota DME and Home Health CGI Federal Inc Attn RACB Imaging Dept 1001 Lakeside Ave Suite 800 Cleveland OH 44114

bull If submitting paper records please send medical records as follows For Therapy Reviews CGI Federal Inc Attn RACB Imaging 1001 Lakeside Avenue Suite 800 Cleveland OH 44114

76

How to survive RAC Audit

bull National health expenditures totaled $1679 Billion in 2003 bull National health expenditures were 153 of GROSS Domestic Product

(GDP) in 2003 bull Health care cost increasing at +9 per year bull Doomsday predictions of Medicare running out bull Congressional Action

77

RAC Audits

bull Medicare Modernization Act (MMA) of 2003Mandated a three year audit demonstration project 2005-2008

bull Appoint audit contractors to review Medicare billings for proper coding DRG assignment and medical necessity

bull Audits will apply to all health care providers (hospitals physicians homecare dme etc)

bull Audit contractors to be paid on a contingency basis a percentage of overpayments recovered

78

How Did we get here

bull Overpayments collected due to errors in Medically Unnecessary Services ndash 40

bull Incorrectly Coded ndash 35

bull Other ndash 17

bull NoInsufficient Documentation ndash 8

79

Where are we now

bull All RACrsquos completed required provider outreachAccess to Medicare billing data base given to all RAC RAC review methodology

bull Automated Review-Black amp White Issues (current) bull DRG Validation-complex review (current) bull Complex Review for coding errors (current) bull DME Medical Necessity Reviews ndashcomplex review (calendar year

2010) bull Medical Necessity Reviews-complex review (calendar year 2010)

80

RAC Reviews

bull Responsibilities of the Team Leader bull Must learn each insurance provider participating in a RAC or RAC type

program bull What are their operating rulesbull What is their appeal process Time limits

May be different process for each insurance provider bull Develop a response team

Identify who does what when why and alternate bull individual

Build and develop a manual process Review of computerized system

81

Priority Health SCIO Health Analytics

bull httpswwwsciohealthanalyticscomcore-capabilitiespayment-integrityfacility-auditsskilled-nursing-facility-audits

bull Claims for Medicare members treated at Skilled Nursing Facilities are reimbursed based on the patientsrsquo RUG (Resource Utilization Group) score which is determined using the Minimum Data Set (MDS) Using SCIOs robust analytics claims andor providers that merit review are selected for audit SCIOs auditors conduct a detailed review of the complete medical record and associated MDS to determine if the billed RUG score is valid In the event the review determines that an incorrect RUG score was billed SCIOreg provides the valid score reports the reason the change was necessary and calculates the resulting overpayment

82

+ Cheer

Onward and Upward she shall prevail We are here to care for the residents and provide a wonderful

service

13 83

84

References

bull Priority Healthbull Blue Crossbull Medicaidbull Medicare

85

  • Medicare Mange Care amp Medicaid Changes in the New World We Live In
  • Medicaid
  • NEW Medicaid Change MIlogin
  • Blueprint for Health Innovation MI
  • Provider Enrollment Electronic Signature Form Submission Process MSA 15-54
  • Provider Enrollment Electronic Signature Form Submission Process
  • Provider Enrollment Domain Administrator
  • Medicaid Coinsurance Medicare Advantage
  • Slide Number 9
  • Lawsuit DHS Changes on Caregivers
  • TPL Medicaid Change
  • CHAMPS Member Screen
  • LOC dropping off Not Due to MI Health
  • Issues
  • Secure Email Information
  • Medicaid amp Hospice
  • Medicaid
  • Medicaid Medicare Buy In
  • Manage Medicaid
  • Healthy Michigan Residents
  • Healthy Michigan Medicaid Days
  • McLaren Health Plan
  • Manage Medicaid Plans January 1
  • Slide Number 24
  • MI Health Link
  • MI Health Link 2565
  • What are the Names
  • MI Health Dual Eligible
  • MI Health LOC
  • LOC Medicaid
  • Medicaid Redetermination and MHL Enrollment
  • MI Health Link Portals
  • MI Health Authorizations
  • MI Health Issues
  • LOC 02 dropping MI Health Issues
  • PPA Offset
  • LOCD
  • MI Health Issues-New
  • ACO
  • Families Receiving Letters for ACO
  • ACO What is It
  • Payroll Based Journal
  • Slide Number 43
  • If you submit data manually should you also submit it through the XML
  • Staffing Submission Frequently Asked Questions
  • CMS defines
  • Slide Number 47
  • PBJ Medical Director Role
  • PBJ Medical Director Role
  • Dietician
  • Pharmacy Consultant
  • What are the names for the Medicare Number
  • QTSO
  • Medicare Update
  • CMS Final Rule On Returning Credits
  • Over Payment Rule
  • Questions to MAC
  • Questions to MAC
  • Final Rule on Returning Credits
  • Final Rule on Returning Credits
  • Final Rule on Returning Credits
  • Slide Number 62
  • Medicare Advantage Payors
  • Medicare Provider Enrollment Fee
  • Medicare MAC-Higlas
  • Two Midnight Rule
  • Two Midnight Rule
  • Two Midnight Rule
  • InPatient Vs Observation Conthellip
  • Two Midnight Rule
  • Health Data Insights amp Medicare Plus Blue
  • HDI Health Data amp Med Plus Blue
  • Health Data InSight
  • Pepper Reports
  • CGI Technologies and Solutions Inc httpracbcgicomContactInfoaspxst=1
  • CGI Federal RAC
  • How to survive RAC Audit
  • RAC Audits
  • How Did we get here
  • Where are we now
  • RAC Reviews
  • Priority Health SCIO Health Analytics
  • Cheer
  • References
Page 23: Medicare, Mange Care & Medicaid Changes in the New World we live in

Manage Medicaid Plans January 1bull Region 1 ndash Upper Peninsula Health Planbull Region 2 ndash McLaren Health Plan Meridian Health Plan of Michigan Molina Healthcare of Michigan

UnitedHealthcare Community Planbull Region 3 ndash McLaren Health Plan Meridian Health Plan of Michigan Molina Healthcare of Michigan

UnitedHealthcare Community Planbull Region 4 ndash Blue Cross Complete of Michigan McLaren Health Plan Meridian Health Plan of Michigan Molina

Healthcare of Michigan Priority Health Choice UnitedHealthcare Community Planbull Region 5 ndash McLaren Health Plan Meridian Health Plan of Michigan Molina Healthcare of Michigan

UnitedHealthcare Community Planbull Region 6 ndash Blue Cross Complete of Michigan HAP Midwest Health Plan McLaren Health Plan Meridian Health

Plan of Michigan Molina Healthcare of Michigan UnitedHealthcare Community Planbull Region 7 ndash Blue Cross Complete of Michigan McLaren Health Plan Meridian Health Plan UnitedHealthcare

Community Planbull Region 8 ndash Aetna Better Health of Michigan McLaren Health Plan Meridian Health Plan of Michigan Molina

Healthcare of Michigan Priority Health Choice UnitedHealthcare Community Planbull Region 9 ndash Aetna Better Health of Michigan Blue Cross Complete of Michigan McLaren Health Plan Meridian

Health Plan of Michigan Molina Healthcare of Michigan UnitedHealthcare Community Planbull Region 10 ndash Aetna Better Health of Michigan Blue Cross Complete of Michigan Harbor Health Plan McLaren

Health Plan Meridian Health Plan of Michigan Molina Healthcare of Michigan Total Health Care UnitedHealthcare Community Plan 23

24

MI Health LinkWhere are we

25

MI Health Link 2565

bull This notification is being sent to providers of long term care services including nursing facilities county medical care facilities and hospital long term care units to provide clarification on the process involved with the submission of the Facility Admission Form (MSA-2565-C) for an individual enrolled in the MI Health Link program

bull The MI Health Link program covers the custodiallong term nursing facility service benefit When an individual who is enrolled in the MI Health Link program is admitted to a nursing facility for custodiallong term nursing services a disenrollment from the Integrated Care Organization (MI Health Link health plan) is NOT REQUIRED The Facility Admission Form (MSA-2565-C) should NOT be sent to the Michigan Department of Health and Human Services (MDHHS) Enrollment Services Section for a disenrollment to be processed

26

What are the Names

bull Started as Integrated Health

bull Then called MMP (Medicare Medicaid Program)

bull Duals (Also Known as Duals as in Dual Eligible)

bull Now called MI Health Link

bull Total confusion

27

MI Health Dual Eligible28

MI Health LOC

29

LOC Medicaidbull We have the new pilot program which started on March

1 2015 in Southwest Michigan Region 4 Counties Macomb Wayne and the UP You could see these patients they are dual eligible in the Pilot program in counties surrounding the pilot

bull MHL-LOC 005 (All other Facilities) or LOC 015 (County Care) These residents have to call Michigan Enrolls to dis-enroll toll-free at 1-800-975-7630 (TTY 1-888-263-5897) Monday-Friday from 8 AM to 7 PM Once they dis-enroll they will go to a LOC 02 you have to do a new LOCD

30

Medicaid Redetermination and MHL Enrollmentbull At the time of re-determination for Medicaid financial eligibility the MI

Health Link (MHL) program will not be sending beneficiaries information about this program Beneficiaries who previously opted out will not be passively enrolled according to an email from the MHL staff The MHL staff wrote

bull ldquoThere is currently no MI Health Link enrollment letter sent to beneficiaries when eligibility is re-determined A person who becomes eligible for MI Health Link enrollment may opt-in at any time

bull When Medicaid re-determination takes place the beneficiary remains in the same ICO unless that beneficiary lost Medicaid coverage If the enrollee loses Medicaid coverage and later regains it they are not passively enrolled into MI Health Link The beneficiary may choose to opt back in to the program at that time if desiredrdquo

bull MHL staff did state that about 1500 beneficiaries will be passively enrolled effective January 1 2016 These specific individuals were given normal notice of 60 and 30 days in which to opt-in or opt-out if they so chose No other large scale passive enrollment is scheduled according to the MHL staff 31

MI Health Link Portals

bull Meridian Health Planbull httpwwwmhplancommibull Amerihealthbull httpwwwamerihealthcaritasvipcarepluscomproviderself-service-

toolsindexaspxbull AetnaCoventrybull httpwwwaetnabetterhealthcomMichiganprovidersportalbull Molinabull httpwwwmolinahealthcarecommembersmien-usmemPageshomeaspxbull HAPMidwestbull httpswwwmidwesthealthplancomLoginaspxbull FidelisCentenebull wwwfidelissccommmp 32

MI Health Authorizationsbull We need to watch these authorization that the plans are giving us for the MI

Health program Some plans are assigning a diagnosis for residents in their prior authorizations They are assigning diagnosis that the residents do not even have You need to make sure these are correct diagnosis and if not you need to work with the case managers of the plans to fix the issue The authorization numbers do change

bull Make sure that any resident that is in a MI Health plan that you have a prior authorization All plans are giving different periods authorizing the residents stay in the facility You need to set up a system to make sure you always have a authorization for the period of time you are rendering the service Here is an example of time frame of authorizations

bull Meridian is authorizing 12 monthsbull Aetna is authorizing 3 monthsbull Molina is authorizing 6 monthsbull The authorization numbers need to go on your claims to the payer You need to

put the authorizations in your software and track the dates

33

MI Health Issuesbull We are seeing some issues with MI Health where the resident does not have the correct LOC or it shows

up correct on CHAMPS but ancillary providers such as Dentist and such cannot see it I think we still have some issues with the information crossing between Bridges DHS system CMS and CHAMPS It in return is creating some access of care issues If it is a true LOC issues Facilities with LOC issues need to submit the Medicaid ID numbers to the MSA-MHL-EnrollmentMichigangov box with the subject line Nursing home LOC Issue so they may work to resolve the issues

bull If it becomes an access to care issue email the information to INTEGRATEDCAREmichigangov Remember in these emails only send the Medicaid ID and explain the situation The State will work with the plans to try to fix the process or improve the process

bull We are also seeing with new admission with LOC 015 or 005 that the plans are stating they have 14 days to authorize admission These are resident in the emergency room and possibly be admitted to you for Rehab The hospital will not keep the resident in ER for 14 days and you cannot admit the resident until you have a prior authorization I would recommend when you are told this by the plan that you need to ask to speak to a manager We will have to work through this

bull Ancillary Provider You need to work with your ancillary providers such as Lab Pharmacy X-Ray Physician and such to get the to be credentialed with the plans We are hearing that some of the pharmacies are not participating with the plans this will create issues for you so I would continue to ask these groups to participate

34

LOC 02 dropping MI Health Issuesbull The passive enrollments have occurred in Macomb amp Wayne for

Medicaid dual eligible We are having the same issue we did as in the Southwest MI amp UP with the passive enrollments I am starting to hear from facilities who are checking there CHAMPS member screens that those residents that have opted out (some residents not all) have lost there 02 Make sure you are checking your CHAMPS member screen both for those that were passively enrolled and those that might have lost there 02 Medicaid that opted out

bull Facilities with LOC issues need to submit the Medicaid ID numbers to the (Only MI Health)MSA-MHL-Enrollmentmichigangov box with the subject line Nursing home LOC Issue so they may work to resolve the issues

35

PPA Offset

bull There are no co-pays deductibles or premiums in MI Health Link so there should be no need to offset the PPA with code 25 MI Health Link enrollees can continue to offset their PPA for non-program covered medical expenses (like Vision-Code 27 Dental-Code 28 and Hearing-Code 26) and use the appropriate codes to offset the PPA when billing the health plan for nursing facility services

bull Resident pay PPA when MedicareMedicaid coinsurance

36

LOCDbull Nursing Facility Level of Care Determination (NFLOCD)

bull The MI Health Link health plan will be responsible for conducting the Michigan Medicaid NFLOCD tool for enrollees seeking admission to a nursing facility For existing residents at the time of enrollment the existing NFLOCD will be adopted for capitation payment purposes The health plan will complete a new NFLCOD tool within the first 90 days of enrollment If a nursing facility resident is disenrolled from MI Health Link the nursing facility will be responsible for conducting a new NFLOCD tool in accordance with published Medicaid policy

37

MI Health Issues-New

bull INTEGRATEDCAREmichigangov

bull Email with Insurance Plan issues Case Manager Issues

38

ACOWhat are they

39

Families Receiving Letters for ACO

40

ACO What is It

bull Whats an ACObull Accountable Care Organizations (ACOs) are groups of doctors hospitals

and other health care providers who come together voluntarily to give coordinated high quality care to their Medicare patients

bull The goal of coordinated care is to ensure that patients especially the chronically ill get the right care at the right time while avoiding

unnecessary duplication of services and preventing medical errorsbull When an ACO succeeds both in delivering high-quality care and

spending health care dollars more wisely it will share in the savings it achieves for the Medicare program

41

Payroll Based JournalMandatory on July 1 2016Internet Explorer Version

Internet Explorer v 10 and v 11 will need to operate in compatibility mode

42

43

If you submit data manually should you also submit it through the XML

bull Now you have three options

bull Submit Manually only

bull Submit through the XML only

bull You are able to submit manually and using the XML

44

45

Staffing Submission Frequently Asked Questions

bull ldquoWho are direct care staffrdquo (Who do we submit data for)bull Submission of data for contract staffbull Medical directors and consultantsbull Staff switching roles or tasks throughout the daybull Hours paid vs hours worked ndash Must be verifiablebull Public postingQuality MeasuresFive Starbull Enforcementbull Voluntary submission risks (noneSo register now)

CMS defines

bull 37 job title codes that are required to match employees to the number of hours each direct care function was performed It is important to work with your teams to define the workers that contribute to each job type and how those daily worked hours are recorded and converted to a PBJ submission

bull The PBJ does include some more specific job descriptions than the 671 For example the PBJ system includes job descriptions for RNs with administrative duties and LPNs with administrative duties versus the 671rsquos more general ldquoNurses with Administrative Duties

Page 46

47

PBJ Medical Director Rolebull Physician Leadership

bull Help the facility ensure that patients have appropriate physician coverage and ensure the provision of physician and health care practitioner services and

bull Help the facility develop a process for reviewing physician and health care practitioner credentials

bull Provide specific guidance for physician performance expectations

bull Help the facility ensure that a system is in place for monitoring the performance of health care practitioners and

bull Facilitate feedback to physicians and other health care practitioners on performance and practices

bull Patient Care - Clinical Leadership

bull Participate in administrative decision-making and the development of policies and procedures related to patient care

bull Help develop approve and implement specific clinical practices for the facility to incorporate into its care-related policies and procedures including areas required by laws and regulations

bull Develop procedures and guidance for facility staff regarding contacting practitioners including information gathering and presentation change in condition assessment and when to contact the medical director

bull Review consider andor act upon consultant recommendations as appropriate that affect the facilitys resident care policies and procedures or the care of an individual resident

bull Review respond to and participate in federal state local and other external surveys and inspections and

bull Help review policies and procedures regarding the adequate protection of patients rights advance care planning and other ethical issues48

PBJ Medical Director Rolebull Quality of Care

bull Help the facility establish systems and methods for reviewing the quality and appropriateness of clinical care and other health-related services and provide appropriate feedback and

bull Participate in the facilitys quality improvement process

bull Advise on infection control issues and approve specific infection control policies to be incorporated into facility policies and procedures

bull Help the facility provide a safe and caring environment

bull Help promote employee health and safety and

bull Assist in the development and implementation of employee health policies and programs

bull Education Information and Communication

bull Promote a learning culture within the facility by educating informing and communicating

bull Provide information to help the facility provide care consistent with current standards of practice (defined as approaches to care procedures techniques and treatments that are based on research and or expert consensus and that are contained in current manuals textbooks and or publications or that are accepted adopted or promulgated by recognized organizations or national bodies)

bull Help the facility develop medical information and communication systems with staff patients and families and others

bull Represent the facility to the professional and lay community on medical and patient care issues

bull Maintain knowledge of the changing social regulatory political and economic factors that affect medical and health services of long term care patients and

bull Help establish appropriate relationships with other health care organizations

49

Dietician

bull When the dietary or food services supervisor is other than a registered dietitian the supervisor shall receive routine consultation and technical assistance from a registered dietitian (RD) Consultation time shall not be less than 4 hours every 60 days Additional consultation time may be needed based on the total number of patients incidence of nutrition-related health problems and food service management needs of the facility

50

Pharmacy Consultant

bull At least once per month a licensed pharmacist must perform a drug regimen review (DRR) for each resident The pharmacist must report any irregularities to the attending physician or director of nursing Furthermore these reports must be acted upon

51

What are the names for the Medicare Numberbull OSCAR -Online Survey Certification and Reporting

bull PTAN-PTAN number is assigned by Medicare to authenticate the provider when using the local Medicare Administrative Contractorrsquos (MAC) self-help tools like the IVR internet portal on-line application status etc Provider Transactions Access Number

bull CCN- CMS Certification Number

bull Medicare Number- example 23-

bull All of the above mean the same thing

52

QTSO

bull Once you are logged in the QTSO site bull You will have a state login to the site to access the various site specific

to your facilitybull Installing you will need administrator rights to your network

53

Medicare UpdateWhat are we seeing

54

CMS Final Rule On Returning Credits

httpswwwfederalregistergovarticles201602122016-02789medicare-program-reporting-and-returning-of-overpayments

55

Over Payment Rule

bull Medicare payments for non covered services

bull Medicare payments in excess of the allowable amount for an identified covered service

bull Errors and non reimbursable expenditures in cost reportsbull Duplicate payment

bull Receipt of Medicare payments when another payor had the primary responsibility for payment

56

Questions to MAC

bull Does the Medicare credit balance report change with this overpayment rule

bull No Medicare Credit Balances are still required at the end of each quarter

bull Will that still be the communication to let CMS or the MAC know that we have received an overpayment

bull Submission of Medicare Credit Balance is one form of communicating overpayments to CMS Other methods include submitting a voluntary refund with required claim information or the submission of a standard overpayment form

57

Questions to MAC

bull Will the MAC still deduct from a future RAbull If the recovery of the overpayment includes adjusting a claim then

the overpayment would be netted against future claims payments and reflected on the RA

bull Or will that process change with this new rulebull Process will remain the samebull Will NGS send communication out on thisbull Yes NGS will communicate this once the final rule is communicated

to the MACs by CMS However this could change depending on final CMS instructions

58

Final Rule on Returning Credits

bull Providers will want to immediately update their current policies governing overpayments in order to comply with this new rule which will take effect on March 14 2016

bull Providers and suppliers are required to use reasonable diligence to investigate credible information regarding overpayments through both proactive compliance efforts and reactive investigations

bull If an overpayment is identified then it must be repaid within 60 days An overpayment is identified when a person has or should have through the exercise of reasonable diligence determined that the person received an overpayment and quantified the amount

bull Providers and suppliers have a maximum of 8 months to report and return overpayments ndash up to 6 months to investigate and quantify the overpayment (ie to identify it) and up to 60 days to report and return the overpayment

59

Final Rule on Returning Credits

bull Providers and suppliers are required to report and return all overpayments within a 6-year lookback period

bull The cause and amount of the overpayment is irrelevant for the determination eg it was due to a mistake it was someone elsersquos fault it is a minor amount An overpayment is an overpayment and must be returned

bull Providers and suppliers must make their own determination to which entity to report and return the overpayment ie to the Medicare contractor or using the OIG Self Disclosure Protocol or the CMS Self Referral Disclosure Protocol

60

Final Rule on Returning Credits

bull Providers and suppliers may use the claims adjustment credit balance self-reported refund process or another appropriate process to report and return overpayments At this time there is no standard refund form to use

bull Failure to report and return an overpayment could subject the provider or supplier to False Claims Act liability Civil Monetary Penalties Law liability and exclusion from federal health care programs

61

P S amp R-Accountants will be asking for this information

The location you login into has changed it is now on EIDM EIDM is the acronym for CMS Enterprise Identity Management system which includes Identity Verification Access Management Authorization Assistance Workflow Tools and Identity Lifecycle Management functions

httpswwwcmsgovResearch-Statistics-Data-and-SystemsCMS-Information-TechnologyIACSCMS-Applications-Loginhtml

Go down the page and click on the PSampRSTARThis will take you to the login pagewill look the same as the old P S amp R didChanges Affecting PSampR System Access (Please Read) (posted 01292015)(Updated 5262015)is changingThe system which controls your PSampR user ID (currently IACS)The new system is referred to as EIDMThis will result in a different way to create new accounts or change passwords to existing accountsIf you already have an account in EIDM you may have to use that account for accessing PSampR after the transitionWhen is the change effectiveJune 13 2015What is staying the sameThe internet address for accessing PSampR remains the sameThe PSampR systemfunctionality is NOT changing 62

Medicare Advantage Payorsbull Medicare Advantage payors are pullingdenying payments on admissions if the patient was readmitted within 30 days after discharge The

client believes that the payors systematically denying payments for all readmissions within 30 days They believe this practice denies them due process to address whether the readmissions were justified and not due to a premature discharge of patient The payors seem to want to act like a QIO without having the same accountabilities of the QIO related to determinations of non-payment

bull Heres the QIO process under section 4240 of the QIO Manualbull 4240 - Readmission Review - (Rev 2 07-11-03)bull Readmission review involves admissions to an acute general short-term hospital occurring less than 31 calendar days from the date of

discharge from the same or another acute general short-term hospital (see sect1154(a)(13) and 42 CFR 47671(a)(8)(ii)) Neither the day of discharge nor the day of admission is counted when determining whether a readmission has occurred

bull A Medical Review Proceduresbull Obtain the appropriate medical records for the initial admission and readmission Perform case review on both stays Analyze the cases

specifically to determine whether the patient was prematurely discharged from the first confinement thus causing readmission Perform an analysis of the stay at the first hospital to determine the cause(s) and extent of any problem(s) (eg incomplete or substandard treatment) Consider the information available to the attending physician who discharged the patient from the first confinement Do not base a determination of a premature discharge on information that the physician or provider could not have known or events that could not have been anticipated at the time of discharge

bull Review both the initial admission and the readmission at the same time unless one of them has previously been reviewed In these cases use at a minimum the PRAF case summary of the other admission in addition to the medical record of the case under review

bull C Denialsbull Deny readmissions under the following circumstancesbull If the readmission was medically unnecessarybull If the readmission resulted from a premature discharge from the same hospital orbull If the readmission was a result of circumvention of PPS by the same hospital (see sect4255)bull With the QIO process there is an appeal within the QIO here the hospital is getting no opportunity to challenge the denials

63

Medicare Provider Enrollment Feebull Provider Enrollment Application Fee Amount for CY 2016bull On December 3 CMS issued a notice Provider Enrollment Application

Fee Amount for CY 2016 [CMSndash6066ndashN] Effective January 1 2016 the CY 2016 application fee is $554 for institutional providers that are

bull Initially enrolling in the Medicare or Medicaid program or the Childrens Health Insurance Program (CHIP)

bull Revalidating their Medicare Medicaid or CHIP enrollmentbull Adding a new Medicare practice locationbull This fee is required with any enrollment application submitted from

January 1 through December 31 2016

64

Medicare MAC-Higlas

bull Effective 142016 CMS has implemented a change to begin netting (offsetting) provider money across workloads within a single organization What this means is that any related providers conducting business in two different workloads (example New York and Maine) will have their money applied to any account receivables (AR) with a remaining balance owed to Medicare within both workloads For example Provider ABC is located in New York and is scheduled to receive a payment of $1000 on todays remittance advice Provider XYZ is related to provider ABC but is located in Maine and has ARs with a balance owed of $200 Provider ABCs $1000 payment will have the $200 applied against provider XYZs ARs resulting in a net payment of $800 This will be reflected on the remittance advice by the same PLB code as seen today for offsets for the $200

65

Two Midnight RuleChange January 1 2016 httpswwwcmsgovMedicareMedicare-Fee-for-Service-PaymentHospitalOutpatientPPSHospital-Outpatient-Regulations-and-Notices-ItemsCMS-1633-FChtml

66

Two Midnight Rulebull However effective January 1 2016 CMS will allow exceptions to the

Two-Midnight Benchmark to be determined on a case-by-case basis by the physician responsible for the care of the beneficiary subject to medical review Said differently Part A payment may be appropriate in some circumstances even though there is no expectation by the physician (or qualified ordering practitioner) of a two-midnight stay and one of the two pre-existing categorical exceptions (CMS ldquoinpatient onlyrdquo list and newly initiated mechanical ventilation) does not apply CMS has indicated that this change to the Two Midnight Rule is in response to stakeholder concern and CMSrsquos continued efforts to develop the most appropriate standard for determining Medicare Part A payment

67

Two Midnight Rulebull A new 42 CFR sect4123(a) provides that a patient is considered an

inpatient of a hospitalhellipif formally admitted as an inpatient pursuant to an order for inpatient admission by a physician or other qualified practitionerhellip The physician orders inpatient status when he or she expects the patient to require a stay that crosses at least 2 midnights[10] Stays expected to be shorter than at least two midnights are generally inappropriate for inpatient admission and inpatient payment under Medicare Part A unless the surgical procedure is specified by Medicare as inpatient only under sect41922(n)[11] The physicians expectationhellipshould be based on such complex medical factors as patient history and comorbidities the severity of signs and symptoms current medical needs and the risk of an adverse event[12] The physician order is part of physician certification of the medical necessity of hospital inpatient serviceshellip[13]

68

InPatient Vs Observation Conthellip

bull Physician certification which begins with an order for inpatient admission requires the physician to certify the reasons for the hospitalization the estimated time the patient will remain in the hospital and plans for post-hospital care if appropriate[14] The certification must be completed signed and documented in the medical record prior to discharge[15]

bull A physicians admission order has no presumptive weight and both the admission order and the physician certification will be evaluated in the context of the evidence in the medical record[16] CMS intends to provide additional information about what evidence in the medical record means in future instructions and manual revisions[17]

69

Two Midnight Rulebull Although the new case-by-case exception appears to be inherently

subjective to a certain extent CMS states that the following factors (among others) would be relevant to determining whether a patient requires inpatient admission under the expanded policy

bull The severity of the signs and symptoms exhibited by the patient bull The medical predictability of something adverse happening to the patient

and bull The need for diagnostic studies that appropriately are outpatient services

(that is their performance does not ordinarily require the patient to remain at the hospital for 24 hours or more)

bull CMS also notes that an inpatient admission (and Part A payment) should be ldquorare and unusualrdquo for minor surgical procedures or other treatment that is expected to keep the patient in the hospital ldquofor only a few hoursrdquo or for a period of time that ldquodoes not span at least overnightrdquo (thus a subset of stays not meeting the Two Midnight Benchmark) CMS indicates that such cases will be prioritized for medical review

70

Health Data Insights amp Medicare Plus Blue

RAC (Retrospective Audits)

71

HDI Health Data amp Med Plus Blue

bull httpwwwhealthdatainsightscombull Blue Cross Medicare Advantage Auditsbull Facilities seeing 10 to 15 requests for Medical Recordsbull In January amp Feburarybull Selected Health Data Insights because they were a premier Audit

Vendor for CMS Recovery Audit Contractor (RAC) demonstration Project They are a audit vendor for Humana

bull Providers not sending Medical Record will get technical denial and lose payments

72

Health Data InSight

bull In 2010 they began the Hospital Reviewbull Medicare Advantage encounter datandashCMS oversight of data integrity OIG

2016bull We will review CMSs oversight of MA encounter data validation and assess

the extent to which CMSrsquos Integrated Data Repository contains timely valid and complete MA encounter data In 2012 CMS began collecting from MA organizations a more comprehensive set of encounter data reflecting the items and services provided to MA plan enrollees Prior CMS and OIG audits have indicated vulnerabilities in the accuracy of data reporting by MA organizations Realizing the potential benefits of the MA encounter data for payment and program integrity oversight is contingent upon the datarsquos completeness validity and timeliness (OEI 03-15-00060 expected issue date FY 2017)

73

Pepper Reports

bull httpswwwpepperresourcesorg

bull Program for Evaluating Payment Patterns Electronic Report ( PEPPER)

bull Annually on or about April 18 2016 will be released

bull Pepper Portal httpssecurefiletmforg

74

CGI Technologies and Solutions Inc httpracbcgicomContactInfoaspxst=1

bull Indiana bull Michiganbull Minnesotabull Illinoisbull Kentuckybull Ohiobull Wisconsin CGI Technologies and Solutions Incbull For general and administrative questions regarding client service outreach

quality assurance or project-specific issues contactbull 1877316RACB (7222)bull Email racbcgicom Tamara Tate Tamaratatecmshhsgovbull 4107861288

75

CGI Federal RAC

bull CGI Federal RAC Region Bbull Email racbcgicombull Phone 1-877-316-RACB (7222)bull Mailing Addressbull Send medical records as followsbull Medical records for Indiana Illinois Kentucky Michigan Ohio Wisconsin

Minnesota DME and Home Health CGI Federal Inc Attn RACB Imaging Dept 1001 Lakeside Ave Suite 800 Cleveland OH 44114

bull If submitting paper records please send medical records as follows For Therapy Reviews CGI Federal Inc Attn RACB Imaging 1001 Lakeside Avenue Suite 800 Cleveland OH 44114

76

How to survive RAC Audit

bull National health expenditures totaled $1679 Billion in 2003 bull National health expenditures were 153 of GROSS Domestic Product

(GDP) in 2003 bull Health care cost increasing at +9 per year bull Doomsday predictions of Medicare running out bull Congressional Action

77

RAC Audits

bull Medicare Modernization Act (MMA) of 2003Mandated a three year audit demonstration project 2005-2008

bull Appoint audit contractors to review Medicare billings for proper coding DRG assignment and medical necessity

bull Audits will apply to all health care providers (hospitals physicians homecare dme etc)

bull Audit contractors to be paid on a contingency basis a percentage of overpayments recovered

78

How Did we get here

bull Overpayments collected due to errors in Medically Unnecessary Services ndash 40

bull Incorrectly Coded ndash 35

bull Other ndash 17

bull NoInsufficient Documentation ndash 8

79

Where are we now

bull All RACrsquos completed required provider outreachAccess to Medicare billing data base given to all RAC RAC review methodology

bull Automated Review-Black amp White Issues (current) bull DRG Validation-complex review (current) bull Complex Review for coding errors (current) bull DME Medical Necessity Reviews ndashcomplex review (calendar year

2010) bull Medical Necessity Reviews-complex review (calendar year 2010)

80

RAC Reviews

bull Responsibilities of the Team Leader bull Must learn each insurance provider participating in a RAC or RAC type

program bull What are their operating rulesbull What is their appeal process Time limits

May be different process for each insurance provider bull Develop a response team

Identify who does what when why and alternate bull individual

Build and develop a manual process Review of computerized system

81

Priority Health SCIO Health Analytics

bull httpswwwsciohealthanalyticscomcore-capabilitiespayment-integrityfacility-auditsskilled-nursing-facility-audits

bull Claims for Medicare members treated at Skilled Nursing Facilities are reimbursed based on the patientsrsquo RUG (Resource Utilization Group) score which is determined using the Minimum Data Set (MDS) Using SCIOs robust analytics claims andor providers that merit review are selected for audit SCIOs auditors conduct a detailed review of the complete medical record and associated MDS to determine if the billed RUG score is valid In the event the review determines that an incorrect RUG score was billed SCIOreg provides the valid score reports the reason the change was necessary and calculates the resulting overpayment

82

+ Cheer

Onward and Upward she shall prevail We are here to care for the residents and provide a wonderful

service

13 83

84

References

bull Priority Healthbull Blue Crossbull Medicaidbull Medicare

85

  • Medicare Mange Care amp Medicaid Changes in the New World We Live In
  • Medicaid
  • NEW Medicaid Change MIlogin
  • Blueprint for Health Innovation MI
  • Provider Enrollment Electronic Signature Form Submission Process MSA 15-54
  • Provider Enrollment Electronic Signature Form Submission Process
  • Provider Enrollment Domain Administrator
  • Medicaid Coinsurance Medicare Advantage
  • Slide Number 9
  • Lawsuit DHS Changes on Caregivers
  • TPL Medicaid Change
  • CHAMPS Member Screen
  • LOC dropping off Not Due to MI Health
  • Issues
  • Secure Email Information
  • Medicaid amp Hospice
  • Medicaid
  • Medicaid Medicare Buy In
  • Manage Medicaid
  • Healthy Michigan Residents
  • Healthy Michigan Medicaid Days
  • McLaren Health Plan
  • Manage Medicaid Plans January 1
  • Slide Number 24
  • MI Health Link
  • MI Health Link 2565
  • What are the Names
  • MI Health Dual Eligible
  • MI Health LOC
  • LOC Medicaid
  • Medicaid Redetermination and MHL Enrollment
  • MI Health Link Portals
  • MI Health Authorizations
  • MI Health Issues
  • LOC 02 dropping MI Health Issues
  • PPA Offset
  • LOCD
  • MI Health Issues-New
  • ACO
  • Families Receiving Letters for ACO
  • ACO What is It
  • Payroll Based Journal
  • Slide Number 43
  • If you submit data manually should you also submit it through the XML
  • Staffing Submission Frequently Asked Questions
  • CMS defines
  • Slide Number 47
  • PBJ Medical Director Role
  • PBJ Medical Director Role
  • Dietician
  • Pharmacy Consultant
  • What are the names for the Medicare Number
  • QTSO
  • Medicare Update
  • CMS Final Rule On Returning Credits
  • Over Payment Rule
  • Questions to MAC
  • Questions to MAC
  • Final Rule on Returning Credits
  • Final Rule on Returning Credits
  • Final Rule on Returning Credits
  • Slide Number 62
  • Medicare Advantage Payors
  • Medicare Provider Enrollment Fee
  • Medicare MAC-Higlas
  • Two Midnight Rule
  • Two Midnight Rule
  • Two Midnight Rule
  • InPatient Vs Observation Conthellip
  • Two Midnight Rule
  • Health Data Insights amp Medicare Plus Blue
  • HDI Health Data amp Med Plus Blue
  • Health Data InSight
  • Pepper Reports
  • CGI Technologies and Solutions Inc httpracbcgicomContactInfoaspxst=1
  • CGI Federal RAC
  • How to survive RAC Audit
  • RAC Audits
  • How Did we get here
  • Where are we now
  • RAC Reviews
  • Priority Health SCIO Health Analytics
  • Cheer
  • References
Page 24: Medicare, Mange Care & Medicaid Changes in the New World we live in

24

MI Health LinkWhere are we

25

MI Health Link 2565

bull This notification is being sent to providers of long term care services including nursing facilities county medical care facilities and hospital long term care units to provide clarification on the process involved with the submission of the Facility Admission Form (MSA-2565-C) for an individual enrolled in the MI Health Link program

bull The MI Health Link program covers the custodiallong term nursing facility service benefit When an individual who is enrolled in the MI Health Link program is admitted to a nursing facility for custodiallong term nursing services a disenrollment from the Integrated Care Organization (MI Health Link health plan) is NOT REQUIRED The Facility Admission Form (MSA-2565-C) should NOT be sent to the Michigan Department of Health and Human Services (MDHHS) Enrollment Services Section for a disenrollment to be processed

26

What are the Names

bull Started as Integrated Health

bull Then called MMP (Medicare Medicaid Program)

bull Duals (Also Known as Duals as in Dual Eligible)

bull Now called MI Health Link

bull Total confusion

27

MI Health Dual Eligible28

MI Health LOC

29

LOC Medicaidbull We have the new pilot program which started on March

1 2015 in Southwest Michigan Region 4 Counties Macomb Wayne and the UP You could see these patients they are dual eligible in the Pilot program in counties surrounding the pilot

bull MHL-LOC 005 (All other Facilities) or LOC 015 (County Care) These residents have to call Michigan Enrolls to dis-enroll toll-free at 1-800-975-7630 (TTY 1-888-263-5897) Monday-Friday from 8 AM to 7 PM Once they dis-enroll they will go to a LOC 02 you have to do a new LOCD

30

Medicaid Redetermination and MHL Enrollmentbull At the time of re-determination for Medicaid financial eligibility the MI

Health Link (MHL) program will not be sending beneficiaries information about this program Beneficiaries who previously opted out will not be passively enrolled according to an email from the MHL staff The MHL staff wrote

bull ldquoThere is currently no MI Health Link enrollment letter sent to beneficiaries when eligibility is re-determined A person who becomes eligible for MI Health Link enrollment may opt-in at any time

bull When Medicaid re-determination takes place the beneficiary remains in the same ICO unless that beneficiary lost Medicaid coverage If the enrollee loses Medicaid coverage and later regains it they are not passively enrolled into MI Health Link The beneficiary may choose to opt back in to the program at that time if desiredrdquo

bull MHL staff did state that about 1500 beneficiaries will be passively enrolled effective January 1 2016 These specific individuals were given normal notice of 60 and 30 days in which to opt-in or opt-out if they so chose No other large scale passive enrollment is scheduled according to the MHL staff 31

MI Health Link Portals

bull Meridian Health Planbull httpwwwmhplancommibull Amerihealthbull httpwwwamerihealthcaritasvipcarepluscomproviderself-service-

toolsindexaspxbull AetnaCoventrybull httpwwwaetnabetterhealthcomMichiganprovidersportalbull Molinabull httpwwwmolinahealthcarecommembersmien-usmemPageshomeaspxbull HAPMidwestbull httpswwwmidwesthealthplancomLoginaspxbull FidelisCentenebull wwwfidelissccommmp 32

MI Health Authorizationsbull We need to watch these authorization that the plans are giving us for the MI

Health program Some plans are assigning a diagnosis for residents in their prior authorizations They are assigning diagnosis that the residents do not even have You need to make sure these are correct diagnosis and if not you need to work with the case managers of the plans to fix the issue The authorization numbers do change

bull Make sure that any resident that is in a MI Health plan that you have a prior authorization All plans are giving different periods authorizing the residents stay in the facility You need to set up a system to make sure you always have a authorization for the period of time you are rendering the service Here is an example of time frame of authorizations

bull Meridian is authorizing 12 monthsbull Aetna is authorizing 3 monthsbull Molina is authorizing 6 monthsbull The authorization numbers need to go on your claims to the payer You need to

put the authorizations in your software and track the dates

33

MI Health Issuesbull We are seeing some issues with MI Health where the resident does not have the correct LOC or it shows

up correct on CHAMPS but ancillary providers such as Dentist and such cannot see it I think we still have some issues with the information crossing between Bridges DHS system CMS and CHAMPS It in return is creating some access of care issues If it is a true LOC issues Facilities with LOC issues need to submit the Medicaid ID numbers to the MSA-MHL-EnrollmentMichigangov box with the subject line Nursing home LOC Issue so they may work to resolve the issues

bull If it becomes an access to care issue email the information to INTEGRATEDCAREmichigangov Remember in these emails only send the Medicaid ID and explain the situation The State will work with the plans to try to fix the process or improve the process

bull We are also seeing with new admission with LOC 015 or 005 that the plans are stating they have 14 days to authorize admission These are resident in the emergency room and possibly be admitted to you for Rehab The hospital will not keep the resident in ER for 14 days and you cannot admit the resident until you have a prior authorization I would recommend when you are told this by the plan that you need to ask to speak to a manager We will have to work through this

bull Ancillary Provider You need to work with your ancillary providers such as Lab Pharmacy X-Ray Physician and such to get the to be credentialed with the plans We are hearing that some of the pharmacies are not participating with the plans this will create issues for you so I would continue to ask these groups to participate

34

LOC 02 dropping MI Health Issuesbull The passive enrollments have occurred in Macomb amp Wayne for

Medicaid dual eligible We are having the same issue we did as in the Southwest MI amp UP with the passive enrollments I am starting to hear from facilities who are checking there CHAMPS member screens that those residents that have opted out (some residents not all) have lost there 02 Make sure you are checking your CHAMPS member screen both for those that were passively enrolled and those that might have lost there 02 Medicaid that opted out

bull Facilities with LOC issues need to submit the Medicaid ID numbers to the (Only MI Health)MSA-MHL-Enrollmentmichigangov box with the subject line Nursing home LOC Issue so they may work to resolve the issues

35

PPA Offset

bull There are no co-pays deductibles or premiums in MI Health Link so there should be no need to offset the PPA with code 25 MI Health Link enrollees can continue to offset their PPA for non-program covered medical expenses (like Vision-Code 27 Dental-Code 28 and Hearing-Code 26) and use the appropriate codes to offset the PPA when billing the health plan for nursing facility services

bull Resident pay PPA when MedicareMedicaid coinsurance

36

LOCDbull Nursing Facility Level of Care Determination (NFLOCD)

bull The MI Health Link health plan will be responsible for conducting the Michigan Medicaid NFLOCD tool for enrollees seeking admission to a nursing facility For existing residents at the time of enrollment the existing NFLOCD will be adopted for capitation payment purposes The health plan will complete a new NFLCOD tool within the first 90 days of enrollment If a nursing facility resident is disenrolled from MI Health Link the nursing facility will be responsible for conducting a new NFLOCD tool in accordance with published Medicaid policy

37

MI Health Issues-New

bull INTEGRATEDCAREmichigangov

bull Email with Insurance Plan issues Case Manager Issues

38

ACOWhat are they

39

Families Receiving Letters for ACO

40

ACO What is It

bull Whats an ACObull Accountable Care Organizations (ACOs) are groups of doctors hospitals

and other health care providers who come together voluntarily to give coordinated high quality care to their Medicare patients

bull The goal of coordinated care is to ensure that patients especially the chronically ill get the right care at the right time while avoiding

unnecessary duplication of services and preventing medical errorsbull When an ACO succeeds both in delivering high-quality care and

spending health care dollars more wisely it will share in the savings it achieves for the Medicare program

41

Payroll Based JournalMandatory on July 1 2016Internet Explorer Version

Internet Explorer v 10 and v 11 will need to operate in compatibility mode

42

43

If you submit data manually should you also submit it through the XML

bull Now you have three options

bull Submit Manually only

bull Submit through the XML only

bull You are able to submit manually and using the XML

44

45

Staffing Submission Frequently Asked Questions

bull ldquoWho are direct care staffrdquo (Who do we submit data for)bull Submission of data for contract staffbull Medical directors and consultantsbull Staff switching roles or tasks throughout the daybull Hours paid vs hours worked ndash Must be verifiablebull Public postingQuality MeasuresFive Starbull Enforcementbull Voluntary submission risks (noneSo register now)

CMS defines

bull 37 job title codes that are required to match employees to the number of hours each direct care function was performed It is important to work with your teams to define the workers that contribute to each job type and how those daily worked hours are recorded and converted to a PBJ submission

bull The PBJ does include some more specific job descriptions than the 671 For example the PBJ system includes job descriptions for RNs with administrative duties and LPNs with administrative duties versus the 671rsquos more general ldquoNurses with Administrative Duties

Page 46

47

PBJ Medical Director Rolebull Physician Leadership

bull Help the facility ensure that patients have appropriate physician coverage and ensure the provision of physician and health care practitioner services and

bull Help the facility develop a process for reviewing physician and health care practitioner credentials

bull Provide specific guidance for physician performance expectations

bull Help the facility ensure that a system is in place for monitoring the performance of health care practitioners and

bull Facilitate feedback to physicians and other health care practitioners on performance and practices

bull Patient Care - Clinical Leadership

bull Participate in administrative decision-making and the development of policies and procedures related to patient care

bull Help develop approve and implement specific clinical practices for the facility to incorporate into its care-related policies and procedures including areas required by laws and regulations

bull Develop procedures and guidance for facility staff regarding contacting practitioners including information gathering and presentation change in condition assessment and when to contact the medical director

bull Review consider andor act upon consultant recommendations as appropriate that affect the facilitys resident care policies and procedures or the care of an individual resident

bull Review respond to and participate in federal state local and other external surveys and inspections and

bull Help review policies and procedures regarding the adequate protection of patients rights advance care planning and other ethical issues48

PBJ Medical Director Rolebull Quality of Care

bull Help the facility establish systems and methods for reviewing the quality and appropriateness of clinical care and other health-related services and provide appropriate feedback and

bull Participate in the facilitys quality improvement process

bull Advise on infection control issues and approve specific infection control policies to be incorporated into facility policies and procedures

bull Help the facility provide a safe and caring environment

bull Help promote employee health and safety and

bull Assist in the development and implementation of employee health policies and programs

bull Education Information and Communication

bull Promote a learning culture within the facility by educating informing and communicating

bull Provide information to help the facility provide care consistent with current standards of practice (defined as approaches to care procedures techniques and treatments that are based on research and or expert consensus and that are contained in current manuals textbooks and or publications or that are accepted adopted or promulgated by recognized organizations or national bodies)

bull Help the facility develop medical information and communication systems with staff patients and families and others

bull Represent the facility to the professional and lay community on medical and patient care issues

bull Maintain knowledge of the changing social regulatory political and economic factors that affect medical and health services of long term care patients and

bull Help establish appropriate relationships with other health care organizations

49

Dietician

bull When the dietary or food services supervisor is other than a registered dietitian the supervisor shall receive routine consultation and technical assistance from a registered dietitian (RD) Consultation time shall not be less than 4 hours every 60 days Additional consultation time may be needed based on the total number of patients incidence of nutrition-related health problems and food service management needs of the facility

50

Pharmacy Consultant

bull At least once per month a licensed pharmacist must perform a drug regimen review (DRR) for each resident The pharmacist must report any irregularities to the attending physician or director of nursing Furthermore these reports must be acted upon

51

What are the names for the Medicare Numberbull OSCAR -Online Survey Certification and Reporting

bull PTAN-PTAN number is assigned by Medicare to authenticate the provider when using the local Medicare Administrative Contractorrsquos (MAC) self-help tools like the IVR internet portal on-line application status etc Provider Transactions Access Number

bull CCN- CMS Certification Number

bull Medicare Number- example 23-

bull All of the above mean the same thing

52

QTSO

bull Once you are logged in the QTSO site bull You will have a state login to the site to access the various site specific

to your facilitybull Installing you will need administrator rights to your network

53

Medicare UpdateWhat are we seeing

54

CMS Final Rule On Returning Credits

httpswwwfederalregistergovarticles201602122016-02789medicare-program-reporting-and-returning-of-overpayments

55

Over Payment Rule

bull Medicare payments for non covered services

bull Medicare payments in excess of the allowable amount for an identified covered service

bull Errors and non reimbursable expenditures in cost reportsbull Duplicate payment

bull Receipt of Medicare payments when another payor had the primary responsibility for payment

56

Questions to MAC

bull Does the Medicare credit balance report change with this overpayment rule

bull No Medicare Credit Balances are still required at the end of each quarter

bull Will that still be the communication to let CMS or the MAC know that we have received an overpayment

bull Submission of Medicare Credit Balance is one form of communicating overpayments to CMS Other methods include submitting a voluntary refund with required claim information or the submission of a standard overpayment form

57

Questions to MAC

bull Will the MAC still deduct from a future RAbull If the recovery of the overpayment includes adjusting a claim then

the overpayment would be netted against future claims payments and reflected on the RA

bull Or will that process change with this new rulebull Process will remain the samebull Will NGS send communication out on thisbull Yes NGS will communicate this once the final rule is communicated

to the MACs by CMS However this could change depending on final CMS instructions

58

Final Rule on Returning Credits

bull Providers will want to immediately update their current policies governing overpayments in order to comply with this new rule which will take effect on March 14 2016

bull Providers and suppliers are required to use reasonable diligence to investigate credible information regarding overpayments through both proactive compliance efforts and reactive investigations

bull If an overpayment is identified then it must be repaid within 60 days An overpayment is identified when a person has or should have through the exercise of reasonable diligence determined that the person received an overpayment and quantified the amount

bull Providers and suppliers have a maximum of 8 months to report and return overpayments ndash up to 6 months to investigate and quantify the overpayment (ie to identify it) and up to 60 days to report and return the overpayment

59

Final Rule on Returning Credits

bull Providers and suppliers are required to report and return all overpayments within a 6-year lookback period

bull The cause and amount of the overpayment is irrelevant for the determination eg it was due to a mistake it was someone elsersquos fault it is a minor amount An overpayment is an overpayment and must be returned

bull Providers and suppliers must make their own determination to which entity to report and return the overpayment ie to the Medicare contractor or using the OIG Self Disclosure Protocol or the CMS Self Referral Disclosure Protocol

60

Final Rule on Returning Credits

bull Providers and suppliers may use the claims adjustment credit balance self-reported refund process or another appropriate process to report and return overpayments At this time there is no standard refund form to use

bull Failure to report and return an overpayment could subject the provider or supplier to False Claims Act liability Civil Monetary Penalties Law liability and exclusion from federal health care programs

61

P S amp R-Accountants will be asking for this information

The location you login into has changed it is now on EIDM EIDM is the acronym for CMS Enterprise Identity Management system which includes Identity Verification Access Management Authorization Assistance Workflow Tools and Identity Lifecycle Management functions

httpswwwcmsgovResearch-Statistics-Data-and-SystemsCMS-Information-TechnologyIACSCMS-Applications-Loginhtml

Go down the page and click on the PSampRSTARThis will take you to the login pagewill look the same as the old P S amp R didChanges Affecting PSampR System Access (Please Read) (posted 01292015)(Updated 5262015)is changingThe system which controls your PSampR user ID (currently IACS)The new system is referred to as EIDMThis will result in a different way to create new accounts or change passwords to existing accountsIf you already have an account in EIDM you may have to use that account for accessing PSampR after the transitionWhen is the change effectiveJune 13 2015What is staying the sameThe internet address for accessing PSampR remains the sameThe PSampR systemfunctionality is NOT changing 62

Medicare Advantage Payorsbull Medicare Advantage payors are pullingdenying payments on admissions if the patient was readmitted within 30 days after discharge The

client believes that the payors systematically denying payments for all readmissions within 30 days They believe this practice denies them due process to address whether the readmissions were justified and not due to a premature discharge of patient The payors seem to want to act like a QIO without having the same accountabilities of the QIO related to determinations of non-payment

bull Heres the QIO process under section 4240 of the QIO Manualbull 4240 - Readmission Review - (Rev 2 07-11-03)bull Readmission review involves admissions to an acute general short-term hospital occurring less than 31 calendar days from the date of

discharge from the same or another acute general short-term hospital (see sect1154(a)(13) and 42 CFR 47671(a)(8)(ii)) Neither the day of discharge nor the day of admission is counted when determining whether a readmission has occurred

bull A Medical Review Proceduresbull Obtain the appropriate medical records for the initial admission and readmission Perform case review on both stays Analyze the cases

specifically to determine whether the patient was prematurely discharged from the first confinement thus causing readmission Perform an analysis of the stay at the first hospital to determine the cause(s) and extent of any problem(s) (eg incomplete or substandard treatment) Consider the information available to the attending physician who discharged the patient from the first confinement Do not base a determination of a premature discharge on information that the physician or provider could not have known or events that could not have been anticipated at the time of discharge

bull Review both the initial admission and the readmission at the same time unless one of them has previously been reviewed In these cases use at a minimum the PRAF case summary of the other admission in addition to the medical record of the case under review

bull C Denialsbull Deny readmissions under the following circumstancesbull If the readmission was medically unnecessarybull If the readmission resulted from a premature discharge from the same hospital orbull If the readmission was a result of circumvention of PPS by the same hospital (see sect4255)bull With the QIO process there is an appeal within the QIO here the hospital is getting no opportunity to challenge the denials

63

Medicare Provider Enrollment Feebull Provider Enrollment Application Fee Amount for CY 2016bull On December 3 CMS issued a notice Provider Enrollment Application

Fee Amount for CY 2016 [CMSndash6066ndashN] Effective January 1 2016 the CY 2016 application fee is $554 for institutional providers that are

bull Initially enrolling in the Medicare or Medicaid program or the Childrens Health Insurance Program (CHIP)

bull Revalidating their Medicare Medicaid or CHIP enrollmentbull Adding a new Medicare practice locationbull This fee is required with any enrollment application submitted from

January 1 through December 31 2016

64

Medicare MAC-Higlas

bull Effective 142016 CMS has implemented a change to begin netting (offsetting) provider money across workloads within a single organization What this means is that any related providers conducting business in two different workloads (example New York and Maine) will have their money applied to any account receivables (AR) with a remaining balance owed to Medicare within both workloads For example Provider ABC is located in New York and is scheduled to receive a payment of $1000 on todays remittance advice Provider XYZ is related to provider ABC but is located in Maine and has ARs with a balance owed of $200 Provider ABCs $1000 payment will have the $200 applied against provider XYZs ARs resulting in a net payment of $800 This will be reflected on the remittance advice by the same PLB code as seen today for offsets for the $200

65

Two Midnight RuleChange January 1 2016 httpswwwcmsgovMedicareMedicare-Fee-for-Service-PaymentHospitalOutpatientPPSHospital-Outpatient-Regulations-and-Notices-ItemsCMS-1633-FChtml

66

Two Midnight Rulebull However effective January 1 2016 CMS will allow exceptions to the

Two-Midnight Benchmark to be determined on a case-by-case basis by the physician responsible for the care of the beneficiary subject to medical review Said differently Part A payment may be appropriate in some circumstances even though there is no expectation by the physician (or qualified ordering practitioner) of a two-midnight stay and one of the two pre-existing categorical exceptions (CMS ldquoinpatient onlyrdquo list and newly initiated mechanical ventilation) does not apply CMS has indicated that this change to the Two Midnight Rule is in response to stakeholder concern and CMSrsquos continued efforts to develop the most appropriate standard for determining Medicare Part A payment

67

Two Midnight Rulebull A new 42 CFR sect4123(a) provides that a patient is considered an

inpatient of a hospitalhellipif formally admitted as an inpatient pursuant to an order for inpatient admission by a physician or other qualified practitionerhellip The physician orders inpatient status when he or she expects the patient to require a stay that crosses at least 2 midnights[10] Stays expected to be shorter than at least two midnights are generally inappropriate for inpatient admission and inpatient payment under Medicare Part A unless the surgical procedure is specified by Medicare as inpatient only under sect41922(n)[11] The physicians expectationhellipshould be based on such complex medical factors as patient history and comorbidities the severity of signs and symptoms current medical needs and the risk of an adverse event[12] The physician order is part of physician certification of the medical necessity of hospital inpatient serviceshellip[13]

68

InPatient Vs Observation Conthellip

bull Physician certification which begins with an order for inpatient admission requires the physician to certify the reasons for the hospitalization the estimated time the patient will remain in the hospital and plans for post-hospital care if appropriate[14] The certification must be completed signed and documented in the medical record prior to discharge[15]

bull A physicians admission order has no presumptive weight and both the admission order and the physician certification will be evaluated in the context of the evidence in the medical record[16] CMS intends to provide additional information about what evidence in the medical record means in future instructions and manual revisions[17]

69

Two Midnight Rulebull Although the new case-by-case exception appears to be inherently

subjective to a certain extent CMS states that the following factors (among others) would be relevant to determining whether a patient requires inpatient admission under the expanded policy

bull The severity of the signs and symptoms exhibited by the patient bull The medical predictability of something adverse happening to the patient

and bull The need for diagnostic studies that appropriately are outpatient services

(that is their performance does not ordinarily require the patient to remain at the hospital for 24 hours or more)

bull CMS also notes that an inpatient admission (and Part A payment) should be ldquorare and unusualrdquo for minor surgical procedures or other treatment that is expected to keep the patient in the hospital ldquofor only a few hoursrdquo or for a period of time that ldquodoes not span at least overnightrdquo (thus a subset of stays not meeting the Two Midnight Benchmark) CMS indicates that such cases will be prioritized for medical review

70

Health Data Insights amp Medicare Plus Blue

RAC (Retrospective Audits)

71

HDI Health Data amp Med Plus Blue

bull httpwwwhealthdatainsightscombull Blue Cross Medicare Advantage Auditsbull Facilities seeing 10 to 15 requests for Medical Recordsbull In January amp Feburarybull Selected Health Data Insights because they were a premier Audit

Vendor for CMS Recovery Audit Contractor (RAC) demonstration Project They are a audit vendor for Humana

bull Providers not sending Medical Record will get technical denial and lose payments

72

Health Data InSight

bull In 2010 they began the Hospital Reviewbull Medicare Advantage encounter datandashCMS oversight of data integrity OIG

2016bull We will review CMSs oversight of MA encounter data validation and assess

the extent to which CMSrsquos Integrated Data Repository contains timely valid and complete MA encounter data In 2012 CMS began collecting from MA organizations a more comprehensive set of encounter data reflecting the items and services provided to MA plan enrollees Prior CMS and OIG audits have indicated vulnerabilities in the accuracy of data reporting by MA organizations Realizing the potential benefits of the MA encounter data for payment and program integrity oversight is contingent upon the datarsquos completeness validity and timeliness (OEI 03-15-00060 expected issue date FY 2017)

73

Pepper Reports

bull httpswwwpepperresourcesorg

bull Program for Evaluating Payment Patterns Electronic Report ( PEPPER)

bull Annually on or about April 18 2016 will be released

bull Pepper Portal httpssecurefiletmforg

74

CGI Technologies and Solutions Inc httpracbcgicomContactInfoaspxst=1

bull Indiana bull Michiganbull Minnesotabull Illinoisbull Kentuckybull Ohiobull Wisconsin CGI Technologies and Solutions Incbull For general and administrative questions regarding client service outreach

quality assurance or project-specific issues contactbull 1877316RACB (7222)bull Email racbcgicom Tamara Tate Tamaratatecmshhsgovbull 4107861288

75

CGI Federal RAC

bull CGI Federal RAC Region Bbull Email racbcgicombull Phone 1-877-316-RACB (7222)bull Mailing Addressbull Send medical records as followsbull Medical records for Indiana Illinois Kentucky Michigan Ohio Wisconsin

Minnesota DME and Home Health CGI Federal Inc Attn RACB Imaging Dept 1001 Lakeside Ave Suite 800 Cleveland OH 44114

bull If submitting paper records please send medical records as follows For Therapy Reviews CGI Federal Inc Attn RACB Imaging 1001 Lakeside Avenue Suite 800 Cleveland OH 44114

76

How to survive RAC Audit

bull National health expenditures totaled $1679 Billion in 2003 bull National health expenditures were 153 of GROSS Domestic Product

(GDP) in 2003 bull Health care cost increasing at +9 per year bull Doomsday predictions of Medicare running out bull Congressional Action

77

RAC Audits

bull Medicare Modernization Act (MMA) of 2003Mandated a three year audit demonstration project 2005-2008

bull Appoint audit contractors to review Medicare billings for proper coding DRG assignment and medical necessity

bull Audits will apply to all health care providers (hospitals physicians homecare dme etc)

bull Audit contractors to be paid on a contingency basis a percentage of overpayments recovered

78

How Did we get here

bull Overpayments collected due to errors in Medically Unnecessary Services ndash 40

bull Incorrectly Coded ndash 35

bull Other ndash 17

bull NoInsufficient Documentation ndash 8

79

Where are we now

bull All RACrsquos completed required provider outreachAccess to Medicare billing data base given to all RAC RAC review methodology

bull Automated Review-Black amp White Issues (current) bull DRG Validation-complex review (current) bull Complex Review for coding errors (current) bull DME Medical Necessity Reviews ndashcomplex review (calendar year

2010) bull Medical Necessity Reviews-complex review (calendar year 2010)

80

RAC Reviews

bull Responsibilities of the Team Leader bull Must learn each insurance provider participating in a RAC or RAC type

program bull What are their operating rulesbull What is their appeal process Time limits

May be different process for each insurance provider bull Develop a response team

Identify who does what when why and alternate bull individual

Build and develop a manual process Review of computerized system

81

Priority Health SCIO Health Analytics

bull httpswwwsciohealthanalyticscomcore-capabilitiespayment-integrityfacility-auditsskilled-nursing-facility-audits

bull Claims for Medicare members treated at Skilled Nursing Facilities are reimbursed based on the patientsrsquo RUG (Resource Utilization Group) score which is determined using the Minimum Data Set (MDS) Using SCIOs robust analytics claims andor providers that merit review are selected for audit SCIOs auditors conduct a detailed review of the complete medical record and associated MDS to determine if the billed RUG score is valid In the event the review determines that an incorrect RUG score was billed SCIOreg provides the valid score reports the reason the change was necessary and calculates the resulting overpayment

82

+ Cheer

Onward and Upward she shall prevail We are here to care for the residents and provide a wonderful

service

13 83

84

References

bull Priority Healthbull Blue Crossbull Medicaidbull Medicare

85

  • Medicare Mange Care amp Medicaid Changes in the New World We Live In
  • Medicaid
  • NEW Medicaid Change MIlogin
  • Blueprint for Health Innovation MI
  • Provider Enrollment Electronic Signature Form Submission Process MSA 15-54
  • Provider Enrollment Electronic Signature Form Submission Process
  • Provider Enrollment Domain Administrator
  • Medicaid Coinsurance Medicare Advantage
  • Slide Number 9
  • Lawsuit DHS Changes on Caregivers
  • TPL Medicaid Change
  • CHAMPS Member Screen
  • LOC dropping off Not Due to MI Health
  • Issues
  • Secure Email Information
  • Medicaid amp Hospice
  • Medicaid
  • Medicaid Medicare Buy In
  • Manage Medicaid
  • Healthy Michigan Residents
  • Healthy Michigan Medicaid Days
  • McLaren Health Plan
  • Manage Medicaid Plans January 1
  • Slide Number 24
  • MI Health Link
  • MI Health Link 2565
  • What are the Names
  • MI Health Dual Eligible
  • MI Health LOC
  • LOC Medicaid
  • Medicaid Redetermination and MHL Enrollment
  • MI Health Link Portals
  • MI Health Authorizations
  • MI Health Issues
  • LOC 02 dropping MI Health Issues
  • PPA Offset
  • LOCD
  • MI Health Issues-New
  • ACO
  • Families Receiving Letters for ACO
  • ACO What is It
  • Payroll Based Journal
  • Slide Number 43
  • If you submit data manually should you also submit it through the XML
  • Staffing Submission Frequently Asked Questions
  • CMS defines
  • Slide Number 47
  • PBJ Medical Director Role
  • PBJ Medical Director Role
  • Dietician
  • Pharmacy Consultant
  • What are the names for the Medicare Number
  • QTSO
  • Medicare Update
  • CMS Final Rule On Returning Credits
  • Over Payment Rule
  • Questions to MAC
  • Questions to MAC
  • Final Rule on Returning Credits
  • Final Rule on Returning Credits
  • Final Rule on Returning Credits
  • Slide Number 62
  • Medicare Advantage Payors
  • Medicare Provider Enrollment Fee
  • Medicare MAC-Higlas
  • Two Midnight Rule
  • Two Midnight Rule
  • Two Midnight Rule
  • InPatient Vs Observation Conthellip
  • Two Midnight Rule
  • Health Data Insights amp Medicare Plus Blue
  • HDI Health Data amp Med Plus Blue
  • Health Data InSight
  • Pepper Reports
  • CGI Technologies and Solutions Inc httpracbcgicomContactInfoaspxst=1
  • CGI Federal RAC
  • How to survive RAC Audit
  • RAC Audits
  • How Did we get here
  • Where are we now
  • RAC Reviews
  • Priority Health SCIO Health Analytics
  • Cheer
  • References
Page 25: Medicare, Mange Care & Medicaid Changes in the New World we live in

MI Health LinkWhere are we

25

MI Health Link 2565

bull This notification is being sent to providers of long term care services including nursing facilities county medical care facilities and hospital long term care units to provide clarification on the process involved with the submission of the Facility Admission Form (MSA-2565-C) for an individual enrolled in the MI Health Link program

bull The MI Health Link program covers the custodiallong term nursing facility service benefit When an individual who is enrolled in the MI Health Link program is admitted to a nursing facility for custodiallong term nursing services a disenrollment from the Integrated Care Organization (MI Health Link health plan) is NOT REQUIRED The Facility Admission Form (MSA-2565-C) should NOT be sent to the Michigan Department of Health and Human Services (MDHHS) Enrollment Services Section for a disenrollment to be processed

26

What are the Names

bull Started as Integrated Health

bull Then called MMP (Medicare Medicaid Program)

bull Duals (Also Known as Duals as in Dual Eligible)

bull Now called MI Health Link

bull Total confusion

27

MI Health Dual Eligible28

MI Health LOC

29

LOC Medicaidbull We have the new pilot program which started on March

1 2015 in Southwest Michigan Region 4 Counties Macomb Wayne and the UP You could see these patients they are dual eligible in the Pilot program in counties surrounding the pilot

bull MHL-LOC 005 (All other Facilities) or LOC 015 (County Care) These residents have to call Michigan Enrolls to dis-enroll toll-free at 1-800-975-7630 (TTY 1-888-263-5897) Monday-Friday from 8 AM to 7 PM Once they dis-enroll they will go to a LOC 02 you have to do a new LOCD

30

Medicaid Redetermination and MHL Enrollmentbull At the time of re-determination for Medicaid financial eligibility the MI

Health Link (MHL) program will not be sending beneficiaries information about this program Beneficiaries who previously opted out will not be passively enrolled according to an email from the MHL staff The MHL staff wrote

bull ldquoThere is currently no MI Health Link enrollment letter sent to beneficiaries when eligibility is re-determined A person who becomes eligible for MI Health Link enrollment may opt-in at any time

bull When Medicaid re-determination takes place the beneficiary remains in the same ICO unless that beneficiary lost Medicaid coverage If the enrollee loses Medicaid coverage and later regains it they are not passively enrolled into MI Health Link The beneficiary may choose to opt back in to the program at that time if desiredrdquo

bull MHL staff did state that about 1500 beneficiaries will be passively enrolled effective January 1 2016 These specific individuals were given normal notice of 60 and 30 days in which to opt-in or opt-out if they so chose No other large scale passive enrollment is scheduled according to the MHL staff 31

MI Health Link Portals

bull Meridian Health Planbull httpwwwmhplancommibull Amerihealthbull httpwwwamerihealthcaritasvipcarepluscomproviderself-service-

toolsindexaspxbull AetnaCoventrybull httpwwwaetnabetterhealthcomMichiganprovidersportalbull Molinabull httpwwwmolinahealthcarecommembersmien-usmemPageshomeaspxbull HAPMidwestbull httpswwwmidwesthealthplancomLoginaspxbull FidelisCentenebull wwwfidelissccommmp 32

MI Health Authorizationsbull We need to watch these authorization that the plans are giving us for the MI

Health program Some plans are assigning a diagnosis for residents in their prior authorizations They are assigning diagnosis that the residents do not even have You need to make sure these are correct diagnosis and if not you need to work with the case managers of the plans to fix the issue The authorization numbers do change

bull Make sure that any resident that is in a MI Health plan that you have a prior authorization All plans are giving different periods authorizing the residents stay in the facility You need to set up a system to make sure you always have a authorization for the period of time you are rendering the service Here is an example of time frame of authorizations

bull Meridian is authorizing 12 monthsbull Aetna is authorizing 3 monthsbull Molina is authorizing 6 monthsbull The authorization numbers need to go on your claims to the payer You need to

put the authorizations in your software and track the dates

33

MI Health Issuesbull We are seeing some issues with MI Health where the resident does not have the correct LOC or it shows

up correct on CHAMPS but ancillary providers such as Dentist and such cannot see it I think we still have some issues with the information crossing between Bridges DHS system CMS and CHAMPS It in return is creating some access of care issues If it is a true LOC issues Facilities with LOC issues need to submit the Medicaid ID numbers to the MSA-MHL-EnrollmentMichigangov box with the subject line Nursing home LOC Issue so they may work to resolve the issues

bull If it becomes an access to care issue email the information to INTEGRATEDCAREmichigangov Remember in these emails only send the Medicaid ID and explain the situation The State will work with the plans to try to fix the process or improve the process

bull We are also seeing with new admission with LOC 015 or 005 that the plans are stating they have 14 days to authorize admission These are resident in the emergency room and possibly be admitted to you for Rehab The hospital will not keep the resident in ER for 14 days and you cannot admit the resident until you have a prior authorization I would recommend when you are told this by the plan that you need to ask to speak to a manager We will have to work through this

bull Ancillary Provider You need to work with your ancillary providers such as Lab Pharmacy X-Ray Physician and such to get the to be credentialed with the plans We are hearing that some of the pharmacies are not participating with the plans this will create issues for you so I would continue to ask these groups to participate

34

LOC 02 dropping MI Health Issuesbull The passive enrollments have occurred in Macomb amp Wayne for

Medicaid dual eligible We are having the same issue we did as in the Southwest MI amp UP with the passive enrollments I am starting to hear from facilities who are checking there CHAMPS member screens that those residents that have opted out (some residents not all) have lost there 02 Make sure you are checking your CHAMPS member screen both for those that were passively enrolled and those that might have lost there 02 Medicaid that opted out

bull Facilities with LOC issues need to submit the Medicaid ID numbers to the (Only MI Health)MSA-MHL-Enrollmentmichigangov box with the subject line Nursing home LOC Issue so they may work to resolve the issues

35

PPA Offset

bull There are no co-pays deductibles or premiums in MI Health Link so there should be no need to offset the PPA with code 25 MI Health Link enrollees can continue to offset their PPA for non-program covered medical expenses (like Vision-Code 27 Dental-Code 28 and Hearing-Code 26) and use the appropriate codes to offset the PPA when billing the health plan for nursing facility services

bull Resident pay PPA when MedicareMedicaid coinsurance

36

LOCDbull Nursing Facility Level of Care Determination (NFLOCD)

bull The MI Health Link health plan will be responsible for conducting the Michigan Medicaid NFLOCD tool for enrollees seeking admission to a nursing facility For existing residents at the time of enrollment the existing NFLOCD will be adopted for capitation payment purposes The health plan will complete a new NFLCOD tool within the first 90 days of enrollment If a nursing facility resident is disenrolled from MI Health Link the nursing facility will be responsible for conducting a new NFLOCD tool in accordance with published Medicaid policy

37

MI Health Issues-New

bull INTEGRATEDCAREmichigangov

bull Email with Insurance Plan issues Case Manager Issues

38

ACOWhat are they

39

Families Receiving Letters for ACO

40

ACO What is It

bull Whats an ACObull Accountable Care Organizations (ACOs) are groups of doctors hospitals

and other health care providers who come together voluntarily to give coordinated high quality care to their Medicare patients

bull The goal of coordinated care is to ensure that patients especially the chronically ill get the right care at the right time while avoiding

unnecessary duplication of services and preventing medical errorsbull When an ACO succeeds both in delivering high-quality care and

spending health care dollars more wisely it will share in the savings it achieves for the Medicare program

41

Payroll Based JournalMandatory on July 1 2016Internet Explorer Version

Internet Explorer v 10 and v 11 will need to operate in compatibility mode

42

43

If you submit data manually should you also submit it through the XML

bull Now you have three options

bull Submit Manually only

bull Submit through the XML only

bull You are able to submit manually and using the XML

44

45

Staffing Submission Frequently Asked Questions

bull ldquoWho are direct care staffrdquo (Who do we submit data for)bull Submission of data for contract staffbull Medical directors and consultantsbull Staff switching roles or tasks throughout the daybull Hours paid vs hours worked ndash Must be verifiablebull Public postingQuality MeasuresFive Starbull Enforcementbull Voluntary submission risks (noneSo register now)

CMS defines

bull 37 job title codes that are required to match employees to the number of hours each direct care function was performed It is important to work with your teams to define the workers that contribute to each job type and how those daily worked hours are recorded and converted to a PBJ submission

bull The PBJ does include some more specific job descriptions than the 671 For example the PBJ system includes job descriptions for RNs with administrative duties and LPNs with administrative duties versus the 671rsquos more general ldquoNurses with Administrative Duties

Page 46

47

PBJ Medical Director Rolebull Physician Leadership

bull Help the facility ensure that patients have appropriate physician coverage and ensure the provision of physician and health care practitioner services and

bull Help the facility develop a process for reviewing physician and health care practitioner credentials

bull Provide specific guidance for physician performance expectations

bull Help the facility ensure that a system is in place for monitoring the performance of health care practitioners and

bull Facilitate feedback to physicians and other health care practitioners on performance and practices

bull Patient Care - Clinical Leadership

bull Participate in administrative decision-making and the development of policies and procedures related to patient care

bull Help develop approve and implement specific clinical practices for the facility to incorporate into its care-related policies and procedures including areas required by laws and regulations

bull Develop procedures and guidance for facility staff regarding contacting practitioners including information gathering and presentation change in condition assessment and when to contact the medical director

bull Review consider andor act upon consultant recommendations as appropriate that affect the facilitys resident care policies and procedures or the care of an individual resident

bull Review respond to and participate in federal state local and other external surveys and inspections and

bull Help review policies and procedures regarding the adequate protection of patients rights advance care planning and other ethical issues48

PBJ Medical Director Rolebull Quality of Care

bull Help the facility establish systems and methods for reviewing the quality and appropriateness of clinical care and other health-related services and provide appropriate feedback and

bull Participate in the facilitys quality improvement process

bull Advise on infection control issues and approve specific infection control policies to be incorporated into facility policies and procedures

bull Help the facility provide a safe and caring environment

bull Help promote employee health and safety and

bull Assist in the development and implementation of employee health policies and programs

bull Education Information and Communication

bull Promote a learning culture within the facility by educating informing and communicating

bull Provide information to help the facility provide care consistent with current standards of practice (defined as approaches to care procedures techniques and treatments that are based on research and or expert consensus and that are contained in current manuals textbooks and or publications or that are accepted adopted or promulgated by recognized organizations or national bodies)

bull Help the facility develop medical information and communication systems with staff patients and families and others

bull Represent the facility to the professional and lay community on medical and patient care issues

bull Maintain knowledge of the changing social regulatory political and economic factors that affect medical and health services of long term care patients and

bull Help establish appropriate relationships with other health care organizations

49

Dietician

bull When the dietary or food services supervisor is other than a registered dietitian the supervisor shall receive routine consultation and technical assistance from a registered dietitian (RD) Consultation time shall not be less than 4 hours every 60 days Additional consultation time may be needed based on the total number of patients incidence of nutrition-related health problems and food service management needs of the facility

50

Pharmacy Consultant

bull At least once per month a licensed pharmacist must perform a drug regimen review (DRR) for each resident The pharmacist must report any irregularities to the attending physician or director of nursing Furthermore these reports must be acted upon

51

What are the names for the Medicare Numberbull OSCAR -Online Survey Certification and Reporting

bull PTAN-PTAN number is assigned by Medicare to authenticate the provider when using the local Medicare Administrative Contractorrsquos (MAC) self-help tools like the IVR internet portal on-line application status etc Provider Transactions Access Number

bull CCN- CMS Certification Number

bull Medicare Number- example 23-

bull All of the above mean the same thing

52

QTSO

bull Once you are logged in the QTSO site bull You will have a state login to the site to access the various site specific

to your facilitybull Installing you will need administrator rights to your network

53

Medicare UpdateWhat are we seeing

54

CMS Final Rule On Returning Credits

httpswwwfederalregistergovarticles201602122016-02789medicare-program-reporting-and-returning-of-overpayments

55

Over Payment Rule

bull Medicare payments for non covered services

bull Medicare payments in excess of the allowable amount for an identified covered service

bull Errors and non reimbursable expenditures in cost reportsbull Duplicate payment

bull Receipt of Medicare payments when another payor had the primary responsibility for payment

56

Questions to MAC

bull Does the Medicare credit balance report change with this overpayment rule

bull No Medicare Credit Balances are still required at the end of each quarter

bull Will that still be the communication to let CMS or the MAC know that we have received an overpayment

bull Submission of Medicare Credit Balance is one form of communicating overpayments to CMS Other methods include submitting a voluntary refund with required claim information or the submission of a standard overpayment form

57

Questions to MAC

bull Will the MAC still deduct from a future RAbull If the recovery of the overpayment includes adjusting a claim then

the overpayment would be netted against future claims payments and reflected on the RA

bull Or will that process change with this new rulebull Process will remain the samebull Will NGS send communication out on thisbull Yes NGS will communicate this once the final rule is communicated

to the MACs by CMS However this could change depending on final CMS instructions

58

Final Rule on Returning Credits

bull Providers will want to immediately update their current policies governing overpayments in order to comply with this new rule which will take effect on March 14 2016

bull Providers and suppliers are required to use reasonable diligence to investigate credible information regarding overpayments through both proactive compliance efforts and reactive investigations

bull If an overpayment is identified then it must be repaid within 60 days An overpayment is identified when a person has or should have through the exercise of reasonable diligence determined that the person received an overpayment and quantified the amount

bull Providers and suppliers have a maximum of 8 months to report and return overpayments ndash up to 6 months to investigate and quantify the overpayment (ie to identify it) and up to 60 days to report and return the overpayment

59

Final Rule on Returning Credits

bull Providers and suppliers are required to report and return all overpayments within a 6-year lookback period

bull The cause and amount of the overpayment is irrelevant for the determination eg it was due to a mistake it was someone elsersquos fault it is a minor amount An overpayment is an overpayment and must be returned

bull Providers and suppliers must make their own determination to which entity to report and return the overpayment ie to the Medicare contractor or using the OIG Self Disclosure Protocol or the CMS Self Referral Disclosure Protocol

60

Final Rule on Returning Credits

bull Providers and suppliers may use the claims adjustment credit balance self-reported refund process or another appropriate process to report and return overpayments At this time there is no standard refund form to use

bull Failure to report and return an overpayment could subject the provider or supplier to False Claims Act liability Civil Monetary Penalties Law liability and exclusion from federal health care programs

61

P S amp R-Accountants will be asking for this information

The location you login into has changed it is now on EIDM EIDM is the acronym for CMS Enterprise Identity Management system which includes Identity Verification Access Management Authorization Assistance Workflow Tools and Identity Lifecycle Management functions

httpswwwcmsgovResearch-Statistics-Data-and-SystemsCMS-Information-TechnologyIACSCMS-Applications-Loginhtml

Go down the page and click on the PSampRSTARThis will take you to the login pagewill look the same as the old P S amp R didChanges Affecting PSampR System Access (Please Read) (posted 01292015)(Updated 5262015)is changingThe system which controls your PSampR user ID (currently IACS)The new system is referred to as EIDMThis will result in a different way to create new accounts or change passwords to existing accountsIf you already have an account in EIDM you may have to use that account for accessing PSampR after the transitionWhen is the change effectiveJune 13 2015What is staying the sameThe internet address for accessing PSampR remains the sameThe PSampR systemfunctionality is NOT changing 62

Medicare Advantage Payorsbull Medicare Advantage payors are pullingdenying payments on admissions if the patient was readmitted within 30 days after discharge The

client believes that the payors systematically denying payments for all readmissions within 30 days They believe this practice denies them due process to address whether the readmissions were justified and not due to a premature discharge of patient The payors seem to want to act like a QIO without having the same accountabilities of the QIO related to determinations of non-payment

bull Heres the QIO process under section 4240 of the QIO Manualbull 4240 - Readmission Review - (Rev 2 07-11-03)bull Readmission review involves admissions to an acute general short-term hospital occurring less than 31 calendar days from the date of

discharge from the same or another acute general short-term hospital (see sect1154(a)(13) and 42 CFR 47671(a)(8)(ii)) Neither the day of discharge nor the day of admission is counted when determining whether a readmission has occurred

bull A Medical Review Proceduresbull Obtain the appropriate medical records for the initial admission and readmission Perform case review on both stays Analyze the cases

specifically to determine whether the patient was prematurely discharged from the first confinement thus causing readmission Perform an analysis of the stay at the first hospital to determine the cause(s) and extent of any problem(s) (eg incomplete or substandard treatment) Consider the information available to the attending physician who discharged the patient from the first confinement Do not base a determination of a premature discharge on information that the physician or provider could not have known or events that could not have been anticipated at the time of discharge

bull Review both the initial admission and the readmission at the same time unless one of them has previously been reviewed In these cases use at a minimum the PRAF case summary of the other admission in addition to the medical record of the case under review

bull C Denialsbull Deny readmissions under the following circumstancesbull If the readmission was medically unnecessarybull If the readmission resulted from a premature discharge from the same hospital orbull If the readmission was a result of circumvention of PPS by the same hospital (see sect4255)bull With the QIO process there is an appeal within the QIO here the hospital is getting no opportunity to challenge the denials

63

Medicare Provider Enrollment Feebull Provider Enrollment Application Fee Amount for CY 2016bull On December 3 CMS issued a notice Provider Enrollment Application

Fee Amount for CY 2016 [CMSndash6066ndashN] Effective January 1 2016 the CY 2016 application fee is $554 for institutional providers that are

bull Initially enrolling in the Medicare or Medicaid program or the Childrens Health Insurance Program (CHIP)

bull Revalidating their Medicare Medicaid or CHIP enrollmentbull Adding a new Medicare practice locationbull This fee is required with any enrollment application submitted from

January 1 through December 31 2016

64

Medicare MAC-Higlas

bull Effective 142016 CMS has implemented a change to begin netting (offsetting) provider money across workloads within a single organization What this means is that any related providers conducting business in two different workloads (example New York and Maine) will have their money applied to any account receivables (AR) with a remaining balance owed to Medicare within both workloads For example Provider ABC is located in New York and is scheduled to receive a payment of $1000 on todays remittance advice Provider XYZ is related to provider ABC but is located in Maine and has ARs with a balance owed of $200 Provider ABCs $1000 payment will have the $200 applied against provider XYZs ARs resulting in a net payment of $800 This will be reflected on the remittance advice by the same PLB code as seen today for offsets for the $200

65

Two Midnight RuleChange January 1 2016 httpswwwcmsgovMedicareMedicare-Fee-for-Service-PaymentHospitalOutpatientPPSHospital-Outpatient-Regulations-and-Notices-ItemsCMS-1633-FChtml

66

Two Midnight Rulebull However effective January 1 2016 CMS will allow exceptions to the

Two-Midnight Benchmark to be determined on a case-by-case basis by the physician responsible for the care of the beneficiary subject to medical review Said differently Part A payment may be appropriate in some circumstances even though there is no expectation by the physician (or qualified ordering practitioner) of a two-midnight stay and one of the two pre-existing categorical exceptions (CMS ldquoinpatient onlyrdquo list and newly initiated mechanical ventilation) does not apply CMS has indicated that this change to the Two Midnight Rule is in response to stakeholder concern and CMSrsquos continued efforts to develop the most appropriate standard for determining Medicare Part A payment

67

Two Midnight Rulebull A new 42 CFR sect4123(a) provides that a patient is considered an

inpatient of a hospitalhellipif formally admitted as an inpatient pursuant to an order for inpatient admission by a physician or other qualified practitionerhellip The physician orders inpatient status when he or she expects the patient to require a stay that crosses at least 2 midnights[10] Stays expected to be shorter than at least two midnights are generally inappropriate for inpatient admission and inpatient payment under Medicare Part A unless the surgical procedure is specified by Medicare as inpatient only under sect41922(n)[11] The physicians expectationhellipshould be based on such complex medical factors as patient history and comorbidities the severity of signs and symptoms current medical needs and the risk of an adverse event[12] The physician order is part of physician certification of the medical necessity of hospital inpatient serviceshellip[13]

68

InPatient Vs Observation Conthellip

bull Physician certification which begins with an order for inpatient admission requires the physician to certify the reasons for the hospitalization the estimated time the patient will remain in the hospital and plans for post-hospital care if appropriate[14] The certification must be completed signed and documented in the medical record prior to discharge[15]

bull A physicians admission order has no presumptive weight and both the admission order and the physician certification will be evaluated in the context of the evidence in the medical record[16] CMS intends to provide additional information about what evidence in the medical record means in future instructions and manual revisions[17]

69

Two Midnight Rulebull Although the new case-by-case exception appears to be inherently

subjective to a certain extent CMS states that the following factors (among others) would be relevant to determining whether a patient requires inpatient admission under the expanded policy

bull The severity of the signs and symptoms exhibited by the patient bull The medical predictability of something adverse happening to the patient

and bull The need for diagnostic studies that appropriately are outpatient services

(that is their performance does not ordinarily require the patient to remain at the hospital for 24 hours or more)

bull CMS also notes that an inpatient admission (and Part A payment) should be ldquorare and unusualrdquo for minor surgical procedures or other treatment that is expected to keep the patient in the hospital ldquofor only a few hoursrdquo or for a period of time that ldquodoes not span at least overnightrdquo (thus a subset of stays not meeting the Two Midnight Benchmark) CMS indicates that such cases will be prioritized for medical review

70

Health Data Insights amp Medicare Plus Blue

RAC (Retrospective Audits)

71

HDI Health Data amp Med Plus Blue

bull httpwwwhealthdatainsightscombull Blue Cross Medicare Advantage Auditsbull Facilities seeing 10 to 15 requests for Medical Recordsbull In January amp Feburarybull Selected Health Data Insights because they were a premier Audit

Vendor for CMS Recovery Audit Contractor (RAC) demonstration Project They are a audit vendor for Humana

bull Providers not sending Medical Record will get technical denial and lose payments

72

Health Data InSight

bull In 2010 they began the Hospital Reviewbull Medicare Advantage encounter datandashCMS oversight of data integrity OIG

2016bull We will review CMSs oversight of MA encounter data validation and assess

the extent to which CMSrsquos Integrated Data Repository contains timely valid and complete MA encounter data In 2012 CMS began collecting from MA organizations a more comprehensive set of encounter data reflecting the items and services provided to MA plan enrollees Prior CMS and OIG audits have indicated vulnerabilities in the accuracy of data reporting by MA organizations Realizing the potential benefits of the MA encounter data for payment and program integrity oversight is contingent upon the datarsquos completeness validity and timeliness (OEI 03-15-00060 expected issue date FY 2017)

73

Pepper Reports

bull httpswwwpepperresourcesorg

bull Program for Evaluating Payment Patterns Electronic Report ( PEPPER)

bull Annually on or about April 18 2016 will be released

bull Pepper Portal httpssecurefiletmforg

74

CGI Technologies and Solutions Inc httpracbcgicomContactInfoaspxst=1

bull Indiana bull Michiganbull Minnesotabull Illinoisbull Kentuckybull Ohiobull Wisconsin CGI Technologies and Solutions Incbull For general and administrative questions regarding client service outreach

quality assurance or project-specific issues contactbull 1877316RACB (7222)bull Email racbcgicom Tamara Tate Tamaratatecmshhsgovbull 4107861288

75

CGI Federal RAC

bull CGI Federal RAC Region Bbull Email racbcgicombull Phone 1-877-316-RACB (7222)bull Mailing Addressbull Send medical records as followsbull Medical records for Indiana Illinois Kentucky Michigan Ohio Wisconsin

Minnesota DME and Home Health CGI Federal Inc Attn RACB Imaging Dept 1001 Lakeside Ave Suite 800 Cleveland OH 44114

bull If submitting paper records please send medical records as follows For Therapy Reviews CGI Federal Inc Attn RACB Imaging 1001 Lakeside Avenue Suite 800 Cleveland OH 44114

76

How to survive RAC Audit

bull National health expenditures totaled $1679 Billion in 2003 bull National health expenditures were 153 of GROSS Domestic Product

(GDP) in 2003 bull Health care cost increasing at +9 per year bull Doomsday predictions of Medicare running out bull Congressional Action

77

RAC Audits

bull Medicare Modernization Act (MMA) of 2003Mandated a three year audit demonstration project 2005-2008

bull Appoint audit contractors to review Medicare billings for proper coding DRG assignment and medical necessity

bull Audits will apply to all health care providers (hospitals physicians homecare dme etc)

bull Audit contractors to be paid on a contingency basis a percentage of overpayments recovered

78

How Did we get here

bull Overpayments collected due to errors in Medically Unnecessary Services ndash 40

bull Incorrectly Coded ndash 35

bull Other ndash 17

bull NoInsufficient Documentation ndash 8

79

Where are we now

bull All RACrsquos completed required provider outreachAccess to Medicare billing data base given to all RAC RAC review methodology

bull Automated Review-Black amp White Issues (current) bull DRG Validation-complex review (current) bull Complex Review for coding errors (current) bull DME Medical Necessity Reviews ndashcomplex review (calendar year

2010) bull Medical Necessity Reviews-complex review (calendar year 2010)

80

RAC Reviews

bull Responsibilities of the Team Leader bull Must learn each insurance provider participating in a RAC or RAC type

program bull What are their operating rulesbull What is their appeal process Time limits

May be different process for each insurance provider bull Develop a response team

Identify who does what when why and alternate bull individual

Build and develop a manual process Review of computerized system

81

Priority Health SCIO Health Analytics

bull httpswwwsciohealthanalyticscomcore-capabilitiespayment-integrityfacility-auditsskilled-nursing-facility-audits

bull Claims for Medicare members treated at Skilled Nursing Facilities are reimbursed based on the patientsrsquo RUG (Resource Utilization Group) score which is determined using the Minimum Data Set (MDS) Using SCIOs robust analytics claims andor providers that merit review are selected for audit SCIOs auditors conduct a detailed review of the complete medical record and associated MDS to determine if the billed RUG score is valid In the event the review determines that an incorrect RUG score was billed SCIOreg provides the valid score reports the reason the change was necessary and calculates the resulting overpayment

82

+ Cheer

Onward and Upward she shall prevail We are here to care for the residents and provide a wonderful

service

13 83

84

References

bull Priority Healthbull Blue Crossbull Medicaidbull Medicare

85

  • Medicare Mange Care amp Medicaid Changes in the New World We Live In
  • Medicaid
  • NEW Medicaid Change MIlogin
  • Blueprint for Health Innovation MI
  • Provider Enrollment Electronic Signature Form Submission Process MSA 15-54
  • Provider Enrollment Electronic Signature Form Submission Process
  • Provider Enrollment Domain Administrator
  • Medicaid Coinsurance Medicare Advantage
  • Slide Number 9
  • Lawsuit DHS Changes on Caregivers
  • TPL Medicaid Change
  • CHAMPS Member Screen
  • LOC dropping off Not Due to MI Health
  • Issues
  • Secure Email Information
  • Medicaid amp Hospice
  • Medicaid
  • Medicaid Medicare Buy In
  • Manage Medicaid
  • Healthy Michigan Residents
  • Healthy Michigan Medicaid Days
  • McLaren Health Plan
  • Manage Medicaid Plans January 1
  • Slide Number 24
  • MI Health Link
  • MI Health Link 2565
  • What are the Names
  • MI Health Dual Eligible
  • MI Health LOC
  • LOC Medicaid
  • Medicaid Redetermination and MHL Enrollment
  • MI Health Link Portals
  • MI Health Authorizations
  • MI Health Issues
  • LOC 02 dropping MI Health Issues
  • PPA Offset
  • LOCD
  • MI Health Issues-New
  • ACO
  • Families Receiving Letters for ACO
  • ACO What is It
  • Payroll Based Journal
  • Slide Number 43
  • If you submit data manually should you also submit it through the XML
  • Staffing Submission Frequently Asked Questions
  • CMS defines
  • Slide Number 47
  • PBJ Medical Director Role
  • PBJ Medical Director Role
  • Dietician
  • Pharmacy Consultant
  • What are the names for the Medicare Number
  • QTSO
  • Medicare Update
  • CMS Final Rule On Returning Credits
  • Over Payment Rule
  • Questions to MAC
  • Questions to MAC
  • Final Rule on Returning Credits
  • Final Rule on Returning Credits
  • Final Rule on Returning Credits
  • Slide Number 62
  • Medicare Advantage Payors
  • Medicare Provider Enrollment Fee
  • Medicare MAC-Higlas
  • Two Midnight Rule
  • Two Midnight Rule
  • Two Midnight Rule
  • InPatient Vs Observation Conthellip
  • Two Midnight Rule
  • Health Data Insights amp Medicare Plus Blue
  • HDI Health Data amp Med Plus Blue
  • Health Data InSight
  • Pepper Reports
  • CGI Technologies and Solutions Inc httpracbcgicomContactInfoaspxst=1
  • CGI Federal RAC
  • How to survive RAC Audit
  • RAC Audits
  • How Did we get here
  • Where are we now
  • RAC Reviews
  • Priority Health SCIO Health Analytics
  • Cheer
  • References
Page 26: Medicare, Mange Care & Medicaid Changes in the New World we live in

MI Health Link 2565

bull This notification is being sent to providers of long term care services including nursing facilities county medical care facilities and hospital long term care units to provide clarification on the process involved with the submission of the Facility Admission Form (MSA-2565-C) for an individual enrolled in the MI Health Link program

bull The MI Health Link program covers the custodiallong term nursing facility service benefit When an individual who is enrolled in the MI Health Link program is admitted to a nursing facility for custodiallong term nursing services a disenrollment from the Integrated Care Organization (MI Health Link health plan) is NOT REQUIRED The Facility Admission Form (MSA-2565-C) should NOT be sent to the Michigan Department of Health and Human Services (MDHHS) Enrollment Services Section for a disenrollment to be processed

26

What are the Names

bull Started as Integrated Health

bull Then called MMP (Medicare Medicaid Program)

bull Duals (Also Known as Duals as in Dual Eligible)

bull Now called MI Health Link

bull Total confusion

27

MI Health Dual Eligible28

MI Health LOC

29

LOC Medicaidbull We have the new pilot program which started on March

1 2015 in Southwest Michigan Region 4 Counties Macomb Wayne and the UP You could see these patients they are dual eligible in the Pilot program in counties surrounding the pilot

bull MHL-LOC 005 (All other Facilities) or LOC 015 (County Care) These residents have to call Michigan Enrolls to dis-enroll toll-free at 1-800-975-7630 (TTY 1-888-263-5897) Monday-Friday from 8 AM to 7 PM Once they dis-enroll they will go to a LOC 02 you have to do a new LOCD

30

Medicaid Redetermination and MHL Enrollmentbull At the time of re-determination for Medicaid financial eligibility the MI

Health Link (MHL) program will not be sending beneficiaries information about this program Beneficiaries who previously opted out will not be passively enrolled according to an email from the MHL staff The MHL staff wrote

bull ldquoThere is currently no MI Health Link enrollment letter sent to beneficiaries when eligibility is re-determined A person who becomes eligible for MI Health Link enrollment may opt-in at any time

bull When Medicaid re-determination takes place the beneficiary remains in the same ICO unless that beneficiary lost Medicaid coverage If the enrollee loses Medicaid coverage and later regains it they are not passively enrolled into MI Health Link The beneficiary may choose to opt back in to the program at that time if desiredrdquo

bull MHL staff did state that about 1500 beneficiaries will be passively enrolled effective January 1 2016 These specific individuals were given normal notice of 60 and 30 days in which to opt-in or opt-out if they so chose No other large scale passive enrollment is scheduled according to the MHL staff 31

MI Health Link Portals

bull Meridian Health Planbull httpwwwmhplancommibull Amerihealthbull httpwwwamerihealthcaritasvipcarepluscomproviderself-service-

toolsindexaspxbull AetnaCoventrybull httpwwwaetnabetterhealthcomMichiganprovidersportalbull Molinabull httpwwwmolinahealthcarecommembersmien-usmemPageshomeaspxbull HAPMidwestbull httpswwwmidwesthealthplancomLoginaspxbull FidelisCentenebull wwwfidelissccommmp 32

MI Health Authorizationsbull We need to watch these authorization that the plans are giving us for the MI

Health program Some plans are assigning a diagnosis for residents in their prior authorizations They are assigning diagnosis that the residents do not even have You need to make sure these are correct diagnosis and if not you need to work with the case managers of the plans to fix the issue The authorization numbers do change

bull Make sure that any resident that is in a MI Health plan that you have a prior authorization All plans are giving different periods authorizing the residents stay in the facility You need to set up a system to make sure you always have a authorization for the period of time you are rendering the service Here is an example of time frame of authorizations

bull Meridian is authorizing 12 monthsbull Aetna is authorizing 3 monthsbull Molina is authorizing 6 monthsbull The authorization numbers need to go on your claims to the payer You need to

put the authorizations in your software and track the dates

33

MI Health Issuesbull We are seeing some issues with MI Health where the resident does not have the correct LOC or it shows

up correct on CHAMPS but ancillary providers such as Dentist and such cannot see it I think we still have some issues with the information crossing between Bridges DHS system CMS and CHAMPS It in return is creating some access of care issues If it is a true LOC issues Facilities with LOC issues need to submit the Medicaid ID numbers to the MSA-MHL-EnrollmentMichigangov box with the subject line Nursing home LOC Issue so they may work to resolve the issues

bull If it becomes an access to care issue email the information to INTEGRATEDCAREmichigangov Remember in these emails only send the Medicaid ID and explain the situation The State will work with the plans to try to fix the process or improve the process

bull We are also seeing with new admission with LOC 015 or 005 that the plans are stating they have 14 days to authorize admission These are resident in the emergency room and possibly be admitted to you for Rehab The hospital will not keep the resident in ER for 14 days and you cannot admit the resident until you have a prior authorization I would recommend when you are told this by the plan that you need to ask to speak to a manager We will have to work through this

bull Ancillary Provider You need to work with your ancillary providers such as Lab Pharmacy X-Ray Physician and such to get the to be credentialed with the plans We are hearing that some of the pharmacies are not participating with the plans this will create issues for you so I would continue to ask these groups to participate

34

LOC 02 dropping MI Health Issuesbull The passive enrollments have occurred in Macomb amp Wayne for

Medicaid dual eligible We are having the same issue we did as in the Southwest MI amp UP with the passive enrollments I am starting to hear from facilities who are checking there CHAMPS member screens that those residents that have opted out (some residents not all) have lost there 02 Make sure you are checking your CHAMPS member screen both for those that were passively enrolled and those that might have lost there 02 Medicaid that opted out

bull Facilities with LOC issues need to submit the Medicaid ID numbers to the (Only MI Health)MSA-MHL-Enrollmentmichigangov box with the subject line Nursing home LOC Issue so they may work to resolve the issues

35

PPA Offset

bull There are no co-pays deductibles or premiums in MI Health Link so there should be no need to offset the PPA with code 25 MI Health Link enrollees can continue to offset their PPA for non-program covered medical expenses (like Vision-Code 27 Dental-Code 28 and Hearing-Code 26) and use the appropriate codes to offset the PPA when billing the health plan for nursing facility services

bull Resident pay PPA when MedicareMedicaid coinsurance

36

LOCDbull Nursing Facility Level of Care Determination (NFLOCD)

bull The MI Health Link health plan will be responsible for conducting the Michigan Medicaid NFLOCD tool for enrollees seeking admission to a nursing facility For existing residents at the time of enrollment the existing NFLOCD will be adopted for capitation payment purposes The health plan will complete a new NFLCOD tool within the first 90 days of enrollment If a nursing facility resident is disenrolled from MI Health Link the nursing facility will be responsible for conducting a new NFLOCD tool in accordance with published Medicaid policy

37

MI Health Issues-New

bull INTEGRATEDCAREmichigangov

bull Email with Insurance Plan issues Case Manager Issues

38

ACOWhat are they

39

Families Receiving Letters for ACO

40

ACO What is It

bull Whats an ACObull Accountable Care Organizations (ACOs) are groups of doctors hospitals

and other health care providers who come together voluntarily to give coordinated high quality care to their Medicare patients

bull The goal of coordinated care is to ensure that patients especially the chronically ill get the right care at the right time while avoiding

unnecessary duplication of services and preventing medical errorsbull When an ACO succeeds both in delivering high-quality care and

spending health care dollars more wisely it will share in the savings it achieves for the Medicare program

41

Payroll Based JournalMandatory on July 1 2016Internet Explorer Version

Internet Explorer v 10 and v 11 will need to operate in compatibility mode

42

43

If you submit data manually should you also submit it through the XML

bull Now you have three options

bull Submit Manually only

bull Submit through the XML only

bull You are able to submit manually and using the XML

44

45

Staffing Submission Frequently Asked Questions

bull ldquoWho are direct care staffrdquo (Who do we submit data for)bull Submission of data for contract staffbull Medical directors and consultantsbull Staff switching roles or tasks throughout the daybull Hours paid vs hours worked ndash Must be verifiablebull Public postingQuality MeasuresFive Starbull Enforcementbull Voluntary submission risks (noneSo register now)

CMS defines

bull 37 job title codes that are required to match employees to the number of hours each direct care function was performed It is important to work with your teams to define the workers that contribute to each job type and how those daily worked hours are recorded and converted to a PBJ submission

bull The PBJ does include some more specific job descriptions than the 671 For example the PBJ system includes job descriptions for RNs with administrative duties and LPNs with administrative duties versus the 671rsquos more general ldquoNurses with Administrative Duties

Page 46

47

PBJ Medical Director Rolebull Physician Leadership

bull Help the facility ensure that patients have appropriate physician coverage and ensure the provision of physician and health care practitioner services and

bull Help the facility develop a process for reviewing physician and health care practitioner credentials

bull Provide specific guidance for physician performance expectations

bull Help the facility ensure that a system is in place for monitoring the performance of health care practitioners and

bull Facilitate feedback to physicians and other health care practitioners on performance and practices

bull Patient Care - Clinical Leadership

bull Participate in administrative decision-making and the development of policies and procedures related to patient care

bull Help develop approve and implement specific clinical practices for the facility to incorporate into its care-related policies and procedures including areas required by laws and regulations

bull Develop procedures and guidance for facility staff regarding contacting practitioners including information gathering and presentation change in condition assessment and when to contact the medical director

bull Review consider andor act upon consultant recommendations as appropriate that affect the facilitys resident care policies and procedures or the care of an individual resident

bull Review respond to and participate in federal state local and other external surveys and inspections and

bull Help review policies and procedures regarding the adequate protection of patients rights advance care planning and other ethical issues48

PBJ Medical Director Rolebull Quality of Care

bull Help the facility establish systems and methods for reviewing the quality and appropriateness of clinical care and other health-related services and provide appropriate feedback and

bull Participate in the facilitys quality improvement process

bull Advise on infection control issues and approve specific infection control policies to be incorporated into facility policies and procedures

bull Help the facility provide a safe and caring environment

bull Help promote employee health and safety and

bull Assist in the development and implementation of employee health policies and programs

bull Education Information and Communication

bull Promote a learning culture within the facility by educating informing and communicating

bull Provide information to help the facility provide care consistent with current standards of practice (defined as approaches to care procedures techniques and treatments that are based on research and or expert consensus and that are contained in current manuals textbooks and or publications or that are accepted adopted or promulgated by recognized organizations or national bodies)

bull Help the facility develop medical information and communication systems with staff patients and families and others

bull Represent the facility to the professional and lay community on medical and patient care issues

bull Maintain knowledge of the changing social regulatory political and economic factors that affect medical and health services of long term care patients and

bull Help establish appropriate relationships with other health care organizations

49

Dietician

bull When the dietary or food services supervisor is other than a registered dietitian the supervisor shall receive routine consultation and technical assistance from a registered dietitian (RD) Consultation time shall not be less than 4 hours every 60 days Additional consultation time may be needed based on the total number of patients incidence of nutrition-related health problems and food service management needs of the facility

50

Pharmacy Consultant

bull At least once per month a licensed pharmacist must perform a drug regimen review (DRR) for each resident The pharmacist must report any irregularities to the attending physician or director of nursing Furthermore these reports must be acted upon

51

What are the names for the Medicare Numberbull OSCAR -Online Survey Certification and Reporting

bull PTAN-PTAN number is assigned by Medicare to authenticate the provider when using the local Medicare Administrative Contractorrsquos (MAC) self-help tools like the IVR internet portal on-line application status etc Provider Transactions Access Number

bull CCN- CMS Certification Number

bull Medicare Number- example 23-

bull All of the above mean the same thing

52

QTSO

bull Once you are logged in the QTSO site bull You will have a state login to the site to access the various site specific

to your facilitybull Installing you will need administrator rights to your network

53

Medicare UpdateWhat are we seeing

54

CMS Final Rule On Returning Credits

httpswwwfederalregistergovarticles201602122016-02789medicare-program-reporting-and-returning-of-overpayments

55

Over Payment Rule

bull Medicare payments for non covered services

bull Medicare payments in excess of the allowable amount for an identified covered service

bull Errors and non reimbursable expenditures in cost reportsbull Duplicate payment

bull Receipt of Medicare payments when another payor had the primary responsibility for payment

56

Questions to MAC

bull Does the Medicare credit balance report change with this overpayment rule

bull No Medicare Credit Balances are still required at the end of each quarter

bull Will that still be the communication to let CMS or the MAC know that we have received an overpayment

bull Submission of Medicare Credit Balance is one form of communicating overpayments to CMS Other methods include submitting a voluntary refund with required claim information or the submission of a standard overpayment form

57

Questions to MAC

bull Will the MAC still deduct from a future RAbull If the recovery of the overpayment includes adjusting a claim then

the overpayment would be netted against future claims payments and reflected on the RA

bull Or will that process change with this new rulebull Process will remain the samebull Will NGS send communication out on thisbull Yes NGS will communicate this once the final rule is communicated

to the MACs by CMS However this could change depending on final CMS instructions

58

Final Rule on Returning Credits

bull Providers will want to immediately update their current policies governing overpayments in order to comply with this new rule which will take effect on March 14 2016

bull Providers and suppliers are required to use reasonable diligence to investigate credible information regarding overpayments through both proactive compliance efforts and reactive investigations

bull If an overpayment is identified then it must be repaid within 60 days An overpayment is identified when a person has or should have through the exercise of reasonable diligence determined that the person received an overpayment and quantified the amount

bull Providers and suppliers have a maximum of 8 months to report and return overpayments ndash up to 6 months to investigate and quantify the overpayment (ie to identify it) and up to 60 days to report and return the overpayment

59

Final Rule on Returning Credits

bull Providers and suppliers are required to report and return all overpayments within a 6-year lookback period

bull The cause and amount of the overpayment is irrelevant for the determination eg it was due to a mistake it was someone elsersquos fault it is a minor amount An overpayment is an overpayment and must be returned

bull Providers and suppliers must make their own determination to which entity to report and return the overpayment ie to the Medicare contractor or using the OIG Self Disclosure Protocol or the CMS Self Referral Disclosure Protocol

60

Final Rule on Returning Credits

bull Providers and suppliers may use the claims adjustment credit balance self-reported refund process or another appropriate process to report and return overpayments At this time there is no standard refund form to use

bull Failure to report and return an overpayment could subject the provider or supplier to False Claims Act liability Civil Monetary Penalties Law liability and exclusion from federal health care programs

61

P S amp R-Accountants will be asking for this information

The location you login into has changed it is now on EIDM EIDM is the acronym for CMS Enterprise Identity Management system which includes Identity Verification Access Management Authorization Assistance Workflow Tools and Identity Lifecycle Management functions

httpswwwcmsgovResearch-Statistics-Data-and-SystemsCMS-Information-TechnologyIACSCMS-Applications-Loginhtml

Go down the page and click on the PSampRSTARThis will take you to the login pagewill look the same as the old P S amp R didChanges Affecting PSampR System Access (Please Read) (posted 01292015)(Updated 5262015)is changingThe system which controls your PSampR user ID (currently IACS)The new system is referred to as EIDMThis will result in a different way to create new accounts or change passwords to existing accountsIf you already have an account in EIDM you may have to use that account for accessing PSampR after the transitionWhen is the change effectiveJune 13 2015What is staying the sameThe internet address for accessing PSampR remains the sameThe PSampR systemfunctionality is NOT changing 62

Medicare Advantage Payorsbull Medicare Advantage payors are pullingdenying payments on admissions if the patient was readmitted within 30 days after discharge The

client believes that the payors systematically denying payments for all readmissions within 30 days They believe this practice denies them due process to address whether the readmissions were justified and not due to a premature discharge of patient The payors seem to want to act like a QIO without having the same accountabilities of the QIO related to determinations of non-payment

bull Heres the QIO process under section 4240 of the QIO Manualbull 4240 - Readmission Review - (Rev 2 07-11-03)bull Readmission review involves admissions to an acute general short-term hospital occurring less than 31 calendar days from the date of

discharge from the same or another acute general short-term hospital (see sect1154(a)(13) and 42 CFR 47671(a)(8)(ii)) Neither the day of discharge nor the day of admission is counted when determining whether a readmission has occurred

bull A Medical Review Proceduresbull Obtain the appropriate medical records for the initial admission and readmission Perform case review on both stays Analyze the cases

specifically to determine whether the patient was prematurely discharged from the first confinement thus causing readmission Perform an analysis of the stay at the first hospital to determine the cause(s) and extent of any problem(s) (eg incomplete or substandard treatment) Consider the information available to the attending physician who discharged the patient from the first confinement Do not base a determination of a premature discharge on information that the physician or provider could not have known or events that could not have been anticipated at the time of discharge

bull Review both the initial admission and the readmission at the same time unless one of them has previously been reviewed In these cases use at a minimum the PRAF case summary of the other admission in addition to the medical record of the case under review

bull C Denialsbull Deny readmissions under the following circumstancesbull If the readmission was medically unnecessarybull If the readmission resulted from a premature discharge from the same hospital orbull If the readmission was a result of circumvention of PPS by the same hospital (see sect4255)bull With the QIO process there is an appeal within the QIO here the hospital is getting no opportunity to challenge the denials

63

Medicare Provider Enrollment Feebull Provider Enrollment Application Fee Amount for CY 2016bull On December 3 CMS issued a notice Provider Enrollment Application

Fee Amount for CY 2016 [CMSndash6066ndashN] Effective January 1 2016 the CY 2016 application fee is $554 for institutional providers that are

bull Initially enrolling in the Medicare or Medicaid program or the Childrens Health Insurance Program (CHIP)

bull Revalidating their Medicare Medicaid or CHIP enrollmentbull Adding a new Medicare practice locationbull This fee is required with any enrollment application submitted from

January 1 through December 31 2016

64

Medicare MAC-Higlas

bull Effective 142016 CMS has implemented a change to begin netting (offsetting) provider money across workloads within a single organization What this means is that any related providers conducting business in two different workloads (example New York and Maine) will have their money applied to any account receivables (AR) with a remaining balance owed to Medicare within both workloads For example Provider ABC is located in New York and is scheduled to receive a payment of $1000 on todays remittance advice Provider XYZ is related to provider ABC but is located in Maine and has ARs with a balance owed of $200 Provider ABCs $1000 payment will have the $200 applied against provider XYZs ARs resulting in a net payment of $800 This will be reflected on the remittance advice by the same PLB code as seen today for offsets for the $200

65

Two Midnight RuleChange January 1 2016 httpswwwcmsgovMedicareMedicare-Fee-for-Service-PaymentHospitalOutpatientPPSHospital-Outpatient-Regulations-and-Notices-ItemsCMS-1633-FChtml

66

Two Midnight Rulebull However effective January 1 2016 CMS will allow exceptions to the

Two-Midnight Benchmark to be determined on a case-by-case basis by the physician responsible for the care of the beneficiary subject to medical review Said differently Part A payment may be appropriate in some circumstances even though there is no expectation by the physician (or qualified ordering practitioner) of a two-midnight stay and one of the two pre-existing categorical exceptions (CMS ldquoinpatient onlyrdquo list and newly initiated mechanical ventilation) does not apply CMS has indicated that this change to the Two Midnight Rule is in response to stakeholder concern and CMSrsquos continued efforts to develop the most appropriate standard for determining Medicare Part A payment

67

Two Midnight Rulebull A new 42 CFR sect4123(a) provides that a patient is considered an

inpatient of a hospitalhellipif formally admitted as an inpatient pursuant to an order for inpatient admission by a physician or other qualified practitionerhellip The physician orders inpatient status when he or she expects the patient to require a stay that crosses at least 2 midnights[10] Stays expected to be shorter than at least two midnights are generally inappropriate for inpatient admission and inpatient payment under Medicare Part A unless the surgical procedure is specified by Medicare as inpatient only under sect41922(n)[11] The physicians expectationhellipshould be based on such complex medical factors as patient history and comorbidities the severity of signs and symptoms current medical needs and the risk of an adverse event[12] The physician order is part of physician certification of the medical necessity of hospital inpatient serviceshellip[13]

68

InPatient Vs Observation Conthellip

bull Physician certification which begins with an order for inpatient admission requires the physician to certify the reasons for the hospitalization the estimated time the patient will remain in the hospital and plans for post-hospital care if appropriate[14] The certification must be completed signed and documented in the medical record prior to discharge[15]

bull A physicians admission order has no presumptive weight and both the admission order and the physician certification will be evaluated in the context of the evidence in the medical record[16] CMS intends to provide additional information about what evidence in the medical record means in future instructions and manual revisions[17]

69

Two Midnight Rulebull Although the new case-by-case exception appears to be inherently

subjective to a certain extent CMS states that the following factors (among others) would be relevant to determining whether a patient requires inpatient admission under the expanded policy

bull The severity of the signs and symptoms exhibited by the patient bull The medical predictability of something adverse happening to the patient

and bull The need for diagnostic studies that appropriately are outpatient services

(that is their performance does not ordinarily require the patient to remain at the hospital for 24 hours or more)

bull CMS also notes that an inpatient admission (and Part A payment) should be ldquorare and unusualrdquo for minor surgical procedures or other treatment that is expected to keep the patient in the hospital ldquofor only a few hoursrdquo or for a period of time that ldquodoes not span at least overnightrdquo (thus a subset of stays not meeting the Two Midnight Benchmark) CMS indicates that such cases will be prioritized for medical review

70

Health Data Insights amp Medicare Plus Blue

RAC (Retrospective Audits)

71

HDI Health Data amp Med Plus Blue

bull httpwwwhealthdatainsightscombull Blue Cross Medicare Advantage Auditsbull Facilities seeing 10 to 15 requests for Medical Recordsbull In January amp Feburarybull Selected Health Data Insights because they were a premier Audit

Vendor for CMS Recovery Audit Contractor (RAC) demonstration Project They are a audit vendor for Humana

bull Providers not sending Medical Record will get technical denial and lose payments

72

Health Data InSight

bull In 2010 they began the Hospital Reviewbull Medicare Advantage encounter datandashCMS oversight of data integrity OIG

2016bull We will review CMSs oversight of MA encounter data validation and assess

the extent to which CMSrsquos Integrated Data Repository contains timely valid and complete MA encounter data In 2012 CMS began collecting from MA organizations a more comprehensive set of encounter data reflecting the items and services provided to MA plan enrollees Prior CMS and OIG audits have indicated vulnerabilities in the accuracy of data reporting by MA organizations Realizing the potential benefits of the MA encounter data for payment and program integrity oversight is contingent upon the datarsquos completeness validity and timeliness (OEI 03-15-00060 expected issue date FY 2017)

73

Pepper Reports

bull httpswwwpepperresourcesorg

bull Program for Evaluating Payment Patterns Electronic Report ( PEPPER)

bull Annually on or about April 18 2016 will be released

bull Pepper Portal httpssecurefiletmforg

74

CGI Technologies and Solutions Inc httpracbcgicomContactInfoaspxst=1

bull Indiana bull Michiganbull Minnesotabull Illinoisbull Kentuckybull Ohiobull Wisconsin CGI Technologies and Solutions Incbull For general and administrative questions regarding client service outreach

quality assurance or project-specific issues contactbull 1877316RACB (7222)bull Email racbcgicom Tamara Tate Tamaratatecmshhsgovbull 4107861288

75

CGI Federal RAC

bull CGI Federal RAC Region Bbull Email racbcgicombull Phone 1-877-316-RACB (7222)bull Mailing Addressbull Send medical records as followsbull Medical records for Indiana Illinois Kentucky Michigan Ohio Wisconsin

Minnesota DME and Home Health CGI Federal Inc Attn RACB Imaging Dept 1001 Lakeside Ave Suite 800 Cleveland OH 44114

bull If submitting paper records please send medical records as follows For Therapy Reviews CGI Federal Inc Attn RACB Imaging 1001 Lakeside Avenue Suite 800 Cleveland OH 44114

76

How to survive RAC Audit

bull National health expenditures totaled $1679 Billion in 2003 bull National health expenditures were 153 of GROSS Domestic Product

(GDP) in 2003 bull Health care cost increasing at +9 per year bull Doomsday predictions of Medicare running out bull Congressional Action

77

RAC Audits

bull Medicare Modernization Act (MMA) of 2003Mandated a three year audit demonstration project 2005-2008

bull Appoint audit contractors to review Medicare billings for proper coding DRG assignment and medical necessity

bull Audits will apply to all health care providers (hospitals physicians homecare dme etc)

bull Audit contractors to be paid on a contingency basis a percentage of overpayments recovered

78

How Did we get here

bull Overpayments collected due to errors in Medically Unnecessary Services ndash 40

bull Incorrectly Coded ndash 35

bull Other ndash 17

bull NoInsufficient Documentation ndash 8

79

Where are we now

bull All RACrsquos completed required provider outreachAccess to Medicare billing data base given to all RAC RAC review methodology

bull Automated Review-Black amp White Issues (current) bull DRG Validation-complex review (current) bull Complex Review for coding errors (current) bull DME Medical Necessity Reviews ndashcomplex review (calendar year

2010) bull Medical Necessity Reviews-complex review (calendar year 2010)

80

RAC Reviews

bull Responsibilities of the Team Leader bull Must learn each insurance provider participating in a RAC or RAC type

program bull What are their operating rulesbull What is their appeal process Time limits

May be different process for each insurance provider bull Develop a response team

Identify who does what when why and alternate bull individual

Build and develop a manual process Review of computerized system

81

Priority Health SCIO Health Analytics

bull httpswwwsciohealthanalyticscomcore-capabilitiespayment-integrityfacility-auditsskilled-nursing-facility-audits

bull Claims for Medicare members treated at Skilled Nursing Facilities are reimbursed based on the patientsrsquo RUG (Resource Utilization Group) score which is determined using the Minimum Data Set (MDS) Using SCIOs robust analytics claims andor providers that merit review are selected for audit SCIOs auditors conduct a detailed review of the complete medical record and associated MDS to determine if the billed RUG score is valid In the event the review determines that an incorrect RUG score was billed SCIOreg provides the valid score reports the reason the change was necessary and calculates the resulting overpayment

82

+ Cheer

Onward and Upward she shall prevail We are here to care for the residents and provide a wonderful

service

13 83

84

References

bull Priority Healthbull Blue Crossbull Medicaidbull Medicare

85

  • Medicare Mange Care amp Medicaid Changes in the New World We Live In
  • Medicaid
  • NEW Medicaid Change MIlogin
  • Blueprint for Health Innovation MI
  • Provider Enrollment Electronic Signature Form Submission Process MSA 15-54
  • Provider Enrollment Electronic Signature Form Submission Process
  • Provider Enrollment Domain Administrator
  • Medicaid Coinsurance Medicare Advantage
  • Slide Number 9
  • Lawsuit DHS Changes on Caregivers
  • TPL Medicaid Change
  • CHAMPS Member Screen
  • LOC dropping off Not Due to MI Health
  • Issues
  • Secure Email Information
  • Medicaid amp Hospice
  • Medicaid
  • Medicaid Medicare Buy In
  • Manage Medicaid
  • Healthy Michigan Residents
  • Healthy Michigan Medicaid Days
  • McLaren Health Plan
  • Manage Medicaid Plans January 1
  • Slide Number 24
  • MI Health Link
  • MI Health Link 2565
  • What are the Names
  • MI Health Dual Eligible
  • MI Health LOC
  • LOC Medicaid
  • Medicaid Redetermination and MHL Enrollment
  • MI Health Link Portals
  • MI Health Authorizations
  • MI Health Issues
  • LOC 02 dropping MI Health Issues
  • PPA Offset
  • LOCD
  • MI Health Issues-New
  • ACO
  • Families Receiving Letters for ACO
  • ACO What is It
  • Payroll Based Journal
  • Slide Number 43
  • If you submit data manually should you also submit it through the XML
  • Staffing Submission Frequently Asked Questions
  • CMS defines
  • Slide Number 47
  • PBJ Medical Director Role
  • PBJ Medical Director Role
  • Dietician
  • Pharmacy Consultant
  • What are the names for the Medicare Number
  • QTSO
  • Medicare Update
  • CMS Final Rule On Returning Credits
  • Over Payment Rule
  • Questions to MAC
  • Questions to MAC
  • Final Rule on Returning Credits
  • Final Rule on Returning Credits
  • Final Rule on Returning Credits
  • Slide Number 62
  • Medicare Advantage Payors
  • Medicare Provider Enrollment Fee
  • Medicare MAC-Higlas
  • Two Midnight Rule
  • Two Midnight Rule
  • Two Midnight Rule
  • InPatient Vs Observation Conthellip
  • Two Midnight Rule
  • Health Data Insights amp Medicare Plus Blue
  • HDI Health Data amp Med Plus Blue
  • Health Data InSight
  • Pepper Reports
  • CGI Technologies and Solutions Inc httpracbcgicomContactInfoaspxst=1
  • CGI Federal RAC
  • How to survive RAC Audit
  • RAC Audits
  • How Did we get here
  • Where are we now
  • RAC Reviews
  • Priority Health SCIO Health Analytics
  • Cheer
  • References
Page 27: Medicare, Mange Care & Medicaid Changes in the New World we live in

What are the Names

bull Started as Integrated Health

bull Then called MMP (Medicare Medicaid Program)

bull Duals (Also Known as Duals as in Dual Eligible)

bull Now called MI Health Link

bull Total confusion

27

MI Health Dual Eligible28

MI Health LOC

29

LOC Medicaidbull We have the new pilot program which started on March

1 2015 in Southwest Michigan Region 4 Counties Macomb Wayne and the UP You could see these patients they are dual eligible in the Pilot program in counties surrounding the pilot

bull MHL-LOC 005 (All other Facilities) or LOC 015 (County Care) These residents have to call Michigan Enrolls to dis-enroll toll-free at 1-800-975-7630 (TTY 1-888-263-5897) Monday-Friday from 8 AM to 7 PM Once they dis-enroll they will go to a LOC 02 you have to do a new LOCD

30

Medicaid Redetermination and MHL Enrollmentbull At the time of re-determination for Medicaid financial eligibility the MI

Health Link (MHL) program will not be sending beneficiaries information about this program Beneficiaries who previously opted out will not be passively enrolled according to an email from the MHL staff The MHL staff wrote

bull ldquoThere is currently no MI Health Link enrollment letter sent to beneficiaries when eligibility is re-determined A person who becomes eligible for MI Health Link enrollment may opt-in at any time

bull When Medicaid re-determination takes place the beneficiary remains in the same ICO unless that beneficiary lost Medicaid coverage If the enrollee loses Medicaid coverage and later regains it they are not passively enrolled into MI Health Link The beneficiary may choose to opt back in to the program at that time if desiredrdquo

bull MHL staff did state that about 1500 beneficiaries will be passively enrolled effective January 1 2016 These specific individuals were given normal notice of 60 and 30 days in which to opt-in or opt-out if they so chose No other large scale passive enrollment is scheduled according to the MHL staff 31

MI Health Link Portals

bull Meridian Health Planbull httpwwwmhplancommibull Amerihealthbull httpwwwamerihealthcaritasvipcarepluscomproviderself-service-

toolsindexaspxbull AetnaCoventrybull httpwwwaetnabetterhealthcomMichiganprovidersportalbull Molinabull httpwwwmolinahealthcarecommembersmien-usmemPageshomeaspxbull HAPMidwestbull httpswwwmidwesthealthplancomLoginaspxbull FidelisCentenebull wwwfidelissccommmp 32

MI Health Authorizationsbull We need to watch these authorization that the plans are giving us for the MI

Health program Some plans are assigning a diagnosis for residents in their prior authorizations They are assigning diagnosis that the residents do not even have You need to make sure these are correct diagnosis and if not you need to work with the case managers of the plans to fix the issue The authorization numbers do change

bull Make sure that any resident that is in a MI Health plan that you have a prior authorization All plans are giving different periods authorizing the residents stay in the facility You need to set up a system to make sure you always have a authorization for the period of time you are rendering the service Here is an example of time frame of authorizations

bull Meridian is authorizing 12 monthsbull Aetna is authorizing 3 monthsbull Molina is authorizing 6 monthsbull The authorization numbers need to go on your claims to the payer You need to

put the authorizations in your software and track the dates

33

MI Health Issuesbull We are seeing some issues with MI Health where the resident does not have the correct LOC or it shows

up correct on CHAMPS but ancillary providers such as Dentist and such cannot see it I think we still have some issues with the information crossing between Bridges DHS system CMS and CHAMPS It in return is creating some access of care issues If it is a true LOC issues Facilities with LOC issues need to submit the Medicaid ID numbers to the MSA-MHL-EnrollmentMichigangov box with the subject line Nursing home LOC Issue so they may work to resolve the issues

bull If it becomes an access to care issue email the information to INTEGRATEDCAREmichigangov Remember in these emails only send the Medicaid ID and explain the situation The State will work with the plans to try to fix the process or improve the process

bull We are also seeing with new admission with LOC 015 or 005 that the plans are stating they have 14 days to authorize admission These are resident in the emergency room and possibly be admitted to you for Rehab The hospital will not keep the resident in ER for 14 days and you cannot admit the resident until you have a prior authorization I would recommend when you are told this by the plan that you need to ask to speak to a manager We will have to work through this

bull Ancillary Provider You need to work with your ancillary providers such as Lab Pharmacy X-Ray Physician and such to get the to be credentialed with the plans We are hearing that some of the pharmacies are not participating with the plans this will create issues for you so I would continue to ask these groups to participate

34

LOC 02 dropping MI Health Issuesbull The passive enrollments have occurred in Macomb amp Wayne for

Medicaid dual eligible We are having the same issue we did as in the Southwest MI amp UP with the passive enrollments I am starting to hear from facilities who are checking there CHAMPS member screens that those residents that have opted out (some residents not all) have lost there 02 Make sure you are checking your CHAMPS member screen both for those that were passively enrolled and those that might have lost there 02 Medicaid that opted out

bull Facilities with LOC issues need to submit the Medicaid ID numbers to the (Only MI Health)MSA-MHL-Enrollmentmichigangov box with the subject line Nursing home LOC Issue so they may work to resolve the issues

35

PPA Offset

bull There are no co-pays deductibles or premiums in MI Health Link so there should be no need to offset the PPA with code 25 MI Health Link enrollees can continue to offset their PPA for non-program covered medical expenses (like Vision-Code 27 Dental-Code 28 and Hearing-Code 26) and use the appropriate codes to offset the PPA when billing the health plan for nursing facility services

bull Resident pay PPA when MedicareMedicaid coinsurance

36

LOCDbull Nursing Facility Level of Care Determination (NFLOCD)

bull The MI Health Link health plan will be responsible for conducting the Michigan Medicaid NFLOCD tool for enrollees seeking admission to a nursing facility For existing residents at the time of enrollment the existing NFLOCD will be adopted for capitation payment purposes The health plan will complete a new NFLCOD tool within the first 90 days of enrollment If a nursing facility resident is disenrolled from MI Health Link the nursing facility will be responsible for conducting a new NFLOCD tool in accordance with published Medicaid policy

37

MI Health Issues-New

bull INTEGRATEDCAREmichigangov

bull Email with Insurance Plan issues Case Manager Issues

38

ACOWhat are they

39

Families Receiving Letters for ACO

40

ACO What is It

bull Whats an ACObull Accountable Care Organizations (ACOs) are groups of doctors hospitals

and other health care providers who come together voluntarily to give coordinated high quality care to their Medicare patients

bull The goal of coordinated care is to ensure that patients especially the chronically ill get the right care at the right time while avoiding

unnecessary duplication of services and preventing medical errorsbull When an ACO succeeds both in delivering high-quality care and

spending health care dollars more wisely it will share in the savings it achieves for the Medicare program

41

Payroll Based JournalMandatory on July 1 2016Internet Explorer Version

Internet Explorer v 10 and v 11 will need to operate in compatibility mode

42

43

If you submit data manually should you also submit it through the XML

bull Now you have three options

bull Submit Manually only

bull Submit through the XML only

bull You are able to submit manually and using the XML

44

45

Staffing Submission Frequently Asked Questions

bull ldquoWho are direct care staffrdquo (Who do we submit data for)bull Submission of data for contract staffbull Medical directors and consultantsbull Staff switching roles or tasks throughout the daybull Hours paid vs hours worked ndash Must be verifiablebull Public postingQuality MeasuresFive Starbull Enforcementbull Voluntary submission risks (noneSo register now)

CMS defines

bull 37 job title codes that are required to match employees to the number of hours each direct care function was performed It is important to work with your teams to define the workers that contribute to each job type and how those daily worked hours are recorded and converted to a PBJ submission

bull The PBJ does include some more specific job descriptions than the 671 For example the PBJ system includes job descriptions for RNs with administrative duties and LPNs with administrative duties versus the 671rsquos more general ldquoNurses with Administrative Duties

Page 46

47

PBJ Medical Director Rolebull Physician Leadership

bull Help the facility ensure that patients have appropriate physician coverage and ensure the provision of physician and health care practitioner services and

bull Help the facility develop a process for reviewing physician and health care practitioner credentials

bull Provide specific guidance for physician performance expectations

bull Help the facility ensure that a system is in place for monitoring the performance of health care practitioners and

bull Facilitate feedback to physicians and other health care practitioners on performance and practices

bull Patient Care - Clinical Leadership

bull Participate in administrative decision-making and the development of policies and procedures related to patient care

bull Help develop approve and implement specific clinical practices for the facility to incorporate into its care-related policies and procedures including areas required by laws and regulations

bull Develop procedures and guidance for facility staff regarding contacting practitioners including information gathering and presentation change in condition assessment and when to contact the medical director

bull Review consider andor act upon consultant recommendations as appropriate that affect the facilitys resident care policies and procedures or the care of an individual resident

bull Review respond to and participate in federal state local and other external surveys and inspections and

bull Help review policies and procedures regarding the adequate protection of patients rights advance care planning and other ethical issues48

PBJ Medical Director Rolebull Quality of Care

bull Help the facility establish systems and methods for reviewing the quality and appropriateness of clinical care and other health-related services and provide appropriate feedback and

bull Participate in the facilitys quality improvement process

bull Advise on infection control issues and approve specific infection control policies to be incorporated into facility policies and procedures

bull Help the facility provide a safe and caring environment

bull Help promote employee health and safety and

bull Assist in the development and implementation of employee health policies and programs

bull Education Information and Communication

bull Promote a learning culture within the facility by educating informing and communicating

bull Provide information to help the facility provide care consistent with current standards of practice (defined as approaches to care procedures techniques and treatments that are based on research and or expert consensus and that are contained in current manuals textbooks and or publications or that are accepted adopted or promulgated by recognized organizations or national bodies)

bull Help the facility develop medical information and communication systems with staff patients and families and others

bull Represent the facility to the professional and lay community on medical and patient care issues

bull Maintain knowledge of the changing social regulatory political and economic factors that affect medical and health services of long term care patients and

bull Help establish appropriate relationships with other health care organizations

49

Dietician

bull When the dietary or food services supervisor is other than a registered dietitian the supervisor shall receive routine consultation and technical assistance from a registered dietitian (RD) Consultation time shall not be less than 4 hours every 60 days Additional consultation time may be needed based on the total number of patients incidence of nutrition-related health problems and food service management needs of the facility

50

Pharmacy Consultant

bull At least once per month a licensed pharmacist must perform a drug regimen review (DRR) for each resident The pharmacist must report any irregularities to the attending physician or director of nursing Furthermore these reports must be acted upon

51

What are the names for the Medicare Numberbull OSCAR -Online Survey Certification and Reporting

bull PTAN-PTAN number is assigned by Medicare to authenticate the provider when using the local Medicare Administrative Contractorrsquos (MAC) self-help tools like the IVR internet portal on-line application status etc Provider Transactions Access Number

bull CCN- CMS Certification Number

bull Medicare Number- example 23-

bull All of the above mean the same thing

52

QTSO

bull Once you are logged in the QTSO site bull You will have a state login to the site to access the various site specific

to your facilitybull Installing you will need administrator rights to your network

53

Medicare UpdateWhat are we seeing

54

CMS Final Rule On Returning Credits

httpswwwfederalregistergovarticles201602122016-02789medicare-program-reporting-and-returning-of-overpayments

55

Over Payment Rule

bull Medicare payments for non covered services

bull Medicare payments in excess of the allowable amount for an identified covered service

bull Errors and non reimbursable expenditures in cost reportsbull Duplicate payment

bull Receipt of Medicare payments when another payor had the primary responsibility for payment

56

Questions to MAC

bull Does the Medicare credit balance report change with this overpayment rule

bull No Medicare Credit Balances are still required at the end of each quarter

bull Will that still be the communication to let CMS or the MAC know that we have received an overpayment

bull Submission of Medicare Credit Balance is one form of communicating overpayments to CMS Other methods include submitting a voluntary refund with required claim information or the submission of a standard overpayment form

57

Questions to MAC

bull Will the MAC still deduct from a future RAbull If the recovery of the overpayment includes adjusting a claim then

the overpayment would be netted against future claims payments and reflected on the RA

bull Or will that process change with this new rulebull Process will remain the samebull Will NGS send communication out on thisbull Yes NGS will communicate this once the final rule is communicated

to the MACs by CMS However this could change depending on final CMS instructions

58

Final Rule on Returning Credits

bull Providers will want to immediately update their current policies governing overpayments in order to comply with this new rule which will take effect on March 14 2016

bull Providers and suppliers are required to use reasonable diligence to investigate credible information regarding overpayments through both proactive compliance efforts and reactive investigations

bull If an overpayment is identified then it must be repaid within 60 days An overpayment is identified when a person has or should have through the exercise of reasonable diligence determined that the person received an overpayment and quantified the amount

bull Providers and suppliers have a maximum of 8 months to report and return overpayments ndash up to 6 months to investigate and quantify the overpayment (ie to identify it) and up to 60 days to report and return the overpayment

59

Final Rule on Returning Credits

bull Providers and suppliers are required to report and return all overpayments within a 6-year lookback period

bull The cause and amount of the overpayment is irrelevant for the determination eg it was due to a mistake it was someone elsersquos fault it is a minor amount An overpayment is an overpayment and must be returned

bull Providers and suppliers must make their own determination to which entity to report and return the overpayment ie to the Medicare contractor or using the OIG Self Disclosure Protocol or the CMS Self Referral Disclosure Protocol

60

Final Rule on Returning Credits

bull Providers and suppliers may use the claims adjustment credit balance self-reported refund process or another appropriate process to report and return overpayments At this time there is no standard refund form to use

bull Failure to report and return an overpayment could subject the provider or supplier to False Claims Act liability Civil Monetary Penalties Law liability and exclusion from federal health care programs

61

P S amp R-Accountants will be asking for this information

The location you login into has changed it is now on EIDM EIDM is the acronym for CMS Enterprise Identity Management system which includes Identity Verification Access Management Authorization Assistance Workflow Tools and Identity Lifecycle Management functions

httpswwwcmsgovResearch-Statistics-Data-and-SystemsCMS-Information-TechnologyIACSCMS-Applications-Loginhtml

Go down the page and click on the PSampRSTARThis will take you to the login pagewill look the same as the old P S amp R didChanges Affecting PSampR System Access (Please Read) (posted 01292015)(Updated 5262015)is changingThe system which controls your PSampR user ID (currently IACS)The new system is referred to as EIDMThis will result in a different way to create new accounts or change passwords to existing accountsIf you already have an account in EIDM you may have to use that account for accessing PSampR after the transitionWhen is the change effectiveJune 13 2015What is staying the sameThe internet address for accessing PSampR remains the sameThe PSampR systemfunctionality is NOT changing 62

Medicare Advantage Payorsbull Medicare Advantage payors are pullingdenying payments on admissions if the patient was readmitted within 30 days after discharge The

client believes that the payors systematically denying payments for all readmissions within 30 days They believe this practice denies them due process to address whether the readmissions were justified and not due to a premature discharge of patient The payors seem to want to act like a QIO without having the same accountabilities of the QIO related to determinations of non-payment

bull Heres the QIO process under section 4240 of the QIO Manualbull 4240 - Readmission Review - (Rev 2 07-11-03)bull Readmission review involves admissions to an acute general short-term hospital occurring less than 31 calendar days from the date of

discharge from the same or another acute general short-term hospital (see sect1154(a)(13) and 42 CFR 47671(a)(8)(ii)) Neither the day of discharge nor the day of admission is counted when determining whether a readmission has occurred

bull A Medical Review Proceduresbull Obtain the appropriate medical records for the initial admission and readmission Perform case review on both stays Analyze the cases

specifically to determine whether the patient was prematurely discharged from the first confinement thus causing readmission Perform an analysis of the stay at the first hospital to determine the cause(s) and extent of any problem(s) (eg incomplete or substandard treatment) Consider the information available to the attending physician who discharged the patient from the first confinement Do not base a determination of a premature discharge on information that the physician or provider could not have known or events that could not have been anticipated at the time of discharge

bull Review both the initial admission and the readmission at the same time unless one of them has previously been reviewed In these cases use at a minimum the PRAF case summary of the other admission in addition to the medical record of the case under review

bull C Denialsbull Deny readmissions under the following circumstancesbull If the readmission was medically unnecessarybull If the readmission resulted from a premature discharge from the same hospital orbull If the readmission was a result of circumvention of PPS by the same hospital (see sect4255)bull With the QIO process there is an appeal within the QIO here the hospital is getting no opportunity to challenge the denials

63

Medicare Provider Enrollment Feebull Provider Enrollment Application Fee Amount for CY 2016bull On December 3 CMS issued a notice Provider Enrollment Application

Fee Amount for CY 2016 [CMSndash6066ndashN] Effective January 1 2016 the CY 2016 application fee is $554 for institutional providers that are

bull Initially enrolling in the Medicare or Medicaid program or the Childrens Health Insurance Program (CHIP)

bull Revalidating their Medicare Medicaid or CHIP enrollmentbull Adding a new Medicare practice locationbull This fee is required with any enrollment application submitted from

January 1 through December 31 2016

64

Medicare MAC-Higlas

bull Effective 142016 CMS has implemented a change to begin netting (offsetting) provider money across workloads within a single organization What this means is that any related providers conducting business in two different workloads (example New York and Maine) will have their money applied to any account receivables (AR) with a remaining balance owed to Medicare within both workloads For example Provider ABC is located in New York and is scheduled to receive a payment of $1000 on todays remittance advice Provider XYZ is related to provider ABC but is located in Maine and has ARs with a balance owed of $200 Provider ABCs $1000 payment will have the $200 applied against provider XYZs ARs resulting in a net payment of $800 This will be reflected on the remittance advice by the same PLB code as seen today for offsets for the $200

65

Two Midnight RuleChange January 1 2016 httpswwwcmsgovMedicareMedicare-Fee-for-Service-PaymentHospitalOutpatientPPSHospital-Outpatient-Regulations-and-Notices-ItemsCMS-1633-FChtml

66

Two Midnight Rulebull However effective January 1 2016 CMS will allow exceptions to the

Two-Midnight Benchmark to be determined on a case-by-case basis by the physician responsible for the care of the beneficiary subject to medical review Said differently Part A payment may be appropriate in some circumstances even though there is no expectation by the physician (or qualified ordering practitioner) of a two-midnight stay and one of the two pre-existing categorical exceptions (CMS ldquoinpatient onlyrdquo list and newly initiated mechanical ventilation) does not apply CMS has indicated that this change to the Two Midnight Rule is in response to stakeholder concern and CMSrsquos continued efforts to develop the most appropriate standard for determining Medicare Part A payment

67

Two Midnight Rulebull A new 42 CFR sect4123(a) provides that a patient is considered an

inpatient of a hospitalhellipif formally admitted as an inpatient pursuant to an order for inpatient admission by a physician or other qualified practitionerhellip The physician orders inpatient status when he or she expects the patient to require a stay that crosses at least 2 midnights[10] Stays expected to be shorter than at least two midnights are generally inappropriate for inpatient admission and inpatient payment under Medicare Part A unless the surgical procedure is specified by Medicare as inpatient only under sect41922(n)[11] The physicians expectationhellipshould be based on such complex medical factors as patient history and comorbidities the severity of signs and symptoms current medical needs and the risk of an adverse event[12] The physician order is part of physician certification of the medical necessity of hospital inpatient serviceshellip[13]

68

InPatient Vs Observation Conthellip

bull Physician certification which begins with an order for inpatient admission requires the physician to certify the reasons for the hospitalization the estimated time the patient will remain in the hospital and plans for post-hospital care if appropriate[14] The certification must be completed signed and documented in the medical record prior to discharge[15]

bull A physicians admission order has no presumptive weight and both the admission order and the physician certification will be evaluated in the context of the evidence in the medical record[16] CMS intends to provide additional information about what evidence in the medical record means in future instructions and manual revisions[17]

69

Two Midnight Rulebull Although the new case-by-case exception appears to be inherently

subjective to a certain extent CMS states that the following factors (among others) would be relevant to determining whether a patient requires inpatient admission under the expanded policy

bull The severity of the signs and symptoms exhibited by the patient bull The medical predictability of something adverse happening to the patient

and bull The need for diagnostic studies that appropriately are outpatient services

(that is their performance does not ordinarily require the patient to remain at the hospital for 24 hours or more)

bull CMS also notes that an inpatient admission (and Part A payment) should be ldquorare and unusualrdquo for minor surgical procedures or other treatment that is expected to keep the patient in the hospital ldquofor only a few hoursrdquo or for a period of time that ldquodoes not span at least overnightrdquo (thus a subset of stays not meeting the Two Midnight Benchmark) CMS indicates that such cases will be prioritized for medical review

70

Health Data Insights amp Medicare Plus Blue

RAC (Retrospective Audits)

71

HDI Health Data amp Med Plus Blue

bull httpwwwhealthdatainsightscombull Blue Cross Medicare Advantage Auditsbull Facilities seeing 10 to 15 requests for Medical Recordsbull In January amp Feburarybull Selected Health Data Insights because they were a premier Audit

Vendor for CMS Recovery Audit Contractor (RAC) demonstration Project They are a audit vendor for Humana

bull Providers not sending Medical Record will get technical denial and lose payments

72

Health Data InSight

bull In 2010 they began the Hospital Reviewbull Medicare Advantage encounter datandashCMS oversight of data integrity OIG

2016bull We will review CMSs oversight of MA encounter data validation and assess

the extent to which CMSrsquos Integrated Data Repository contains timely valid and complete MA encounter data In 2012 CMS began collecting from MA organizations a more comprehensive set of encounter data reflecting the items and services provided to MA plan enrollees Prior CMS and OIG audits have indicated vulnerabilities in the accuracy of data reporting by MA organizations Realizing the potential benefits of the MA encounter data for payment and program integrity oversight is contingent upon the datarsquos completeness validity and timeliness (OEI 03-15-00060 expected issue date FY 2017)

73

Pepper Reports

bull httpswwwpepperresourcesorg

bull Program for Evaluating Payment Patterns Electronic Report ( PEPPER)

bull Annually on or about April 18 2016 will be released

bull Pepper Portal httpssecurefiletmforg

74

CGI Technologies and Solutions Inc httpracbcgicomContactInfoaspxst=1

bull Indiana bull Michiganbull Minnesotabull Illinoisbull Kentuckybull Ohiobull Wisconsin CGI Technologies and Solutions Incbull For general and administrative questions regarding client service outreach

quality assurance or project-specific issues contactbull 1877316RACB (7222)bull Email racbcgicom Tamara Tate Tamaratatecmshhsgovbull 4107861288

75

CGI Federal RAC

bull CGI Federal RAC Region Bbull Email racbcgicombull Phone 1-877-316-RACB (7222)bull Mailing Addressbull Send medical records as followsbull Medical records for Indiana Illinois Kentucky Michigan Ohio Wisconsin

Minnesota DME and Home Health CGI Federal Inc Attn RACB Imaging Dept 1001 Lakeside Ave Suite 800 Cleveland OH 44114

bull If submitting paper records please send medical records as follows For Therapy Reviews CGI Federal Inc Attn RACB Imaging 1001 Lakeside Avenue Suite 800 Cleveland OH 44114

76

How to survive RAC Audit

bull National health expenditures totaled $1679 Billion in 2003 bull National health expenditures were 153 of GROSS Domestic Product

(GDP) in 2003 bull Health care cost increasing at +9 per year bull Doomsday predictions of Medicare running out bull Congressional Action

77

RAC Audits

bull Medicare Modernization Act (MMA) of 2003Mandated a three year audit demonstration project 2005-2008

bull Appoint audit contractors to review Medicare billings for proper coding DRG assignment and medical necessity

bull Audits will apply to all health care providers (hospitals physicians homecare dme etc)

bull Audit contractors to be paid on a contingency basis a percentage of overpayments recovered

78

How Did we get here

bull Overpayments collected due to errors in Medically Unnecessary Services ndash 40

bull Incorrectly Coded ndash 35

bull Other ndash 17

bull NoInsufficient Documentation ndash 8

79

Where are we now

bull All RACrsquos completed required provider outreachAccess to Medicare billing data base given to all RAC RAC review methodology

bull Automated Review-Black amp White Issues (current) bull DRG Validation-complex review (current) bull Complex Review for coding errors (current) bull DME Medical Necessity Reviews ndashcomplex review (calendar year

2010) bull Medical Necessity Reviews-complex review (calendar year 2010)

80

RAC Reviews

bull Responsibilities of the Team Leader bull Must learn each insurance provider participating in a RAC or RAC type

program bull What are their operating rulesbull What is their appeal process Time limits

May be different process for each insurance provider bull Develop a response team

Identify who does what when why and alternate bull individual

Build and develop a manual process Review of computerized system

81

Priority Health SCIO Health Analytics

bull httpswwwsciohealthanalyticscomcore-capabilitiespayment-integrityfacility-auditsskilled-nursing-facility-audits

bull Claims for Medicare members treated at Skilled Nursing Facilities are reimbursed based on the patientsrsquo RUG (Resource Utilization Group) score which is determined using the Minimum Data Set (MDS) Using SCIOs robust analytics claims andor providers that merit review are selected for audit SCIOs auditors conduct a detailed review of the complete medical record and associated MDS to determine if the billed RUG score is valid In the event the review determines that an incorrect RUG score was billed SCIOreg provides the valid score reports the reason the change was necessary and calculates the resulting overpayment

82

+ Cheer

Onward and Upward she shall prevail We are here to care for the residents and provide a wonderful

service

13 83

84

References

bull Priority Healthbull Blue Crossbull Medicaidbull Medicare

85

  • Medicare Mange Care amp Medicaid Changes in the New World We Live In
  • Medicaid
  • NEW Medicaid Change MIlogin
  • Blueprint for Health Innovation MI
  • Provider Enrollment Electronic Signature Form Submission Process MSA 15-54
  • Provider Enrollment Electronic Signature Form Submission Process
  • Provider Enrollment Domain Administrator
  • Medicaid Coinsurance Medicare Advantage
  • Slide Number 9
  • Lawsuit DHS Changes on Caregivers
  • TPL Medicaid Change
  • CHAMPS Member Screen
  • LOC dropping off Not Due to MI Health
  • Issues
  • Secure Email Information
  • Medicaid amp Hospice
  • Medicaid
  • Medicaid Medicare Buy In
  • Manage Medicaid
  • Healthy Michigan Residents
  • Healthy Michigan Medicaid Days
  • McLaren Health Plan
  • Manage Medicaid Plans January 1
  • Slide Number 24
  • MI Health Link
  • MI Health Link 2565
  • What are the Names
  • MI Health Dual Eligible
  • MI Health LOC
  • LOC Medicaid
  • Medicaid Redetermination and MHL Enrollment
  • MI Health Link Portals
  • MI Health Authorizations
  • MI Health Issues
  • LOC 02 dropping MI Health Issues
  • PPA Offset
  • LOCD
  • MI Health Issues-New
  • ACO
  • Families Receiving Letters for ACO
  • ACO What is It
  • Payroll Based Journal
  • Slide Number 43
  • If you submit data manually should you also submit it through the XML
  • Staffing Submission Frequently Asked Questions
  • CMS defines
  • Slide Number 47
  • PBJ Medical Director Role
  • PBJ Medical Director Role
  • Dietician
  • Pharmacy Consultant
  • What are the names for the Medicare Number
  • QTSO
  • Medicare Update
  • CMS Final Rule On Returning Credits
  • Over Payment Rule
  • Questions to MAC
  • Questions to MAC
  • Final Rule on Returning Credits
  • Final Rule on Returning Credits
  • Final Rule on Returning Credits
  • Slide Number 62
  • Medicare Advantage Payors
  • Medicare Provider Enrollment Fee
  • Medicare MAC-Higlas
  • Two Midnight Rule
  • Two Midnight Rule
  • Two Midnight Rule
  • InPatient Vs Observation Conthellip
  • Two Midnight Rule
  • Health Data Insights amp Medicare Plus Blue
  • HDI Health Data amp Med Plus Blue
  • Health Data InSight
  • Pepper Reports
  • CGI Technologies and Solutions Inc httpracbcgicomContactInfoaspxst=1
  • CGI Federal RAC
  • How to survive RAC Audit
  • RAC Audits
  • How Did we get here
  • Where are we now
  • RAC Reviews
  • Priority Health SCIO Health Analytics
  • Cheer
  • References
Page 28: Medicare, Mange Care & Medicaid Changes in the New World we live in

MI Health Dual Eligible28

MI Health LOC

29

LOC Medicaidbull We have the new pilot program which started on March

1 2015 in Southwest Michigan Region 4 Counties Macomb Wayne and the UP You could see these patients they are dual eligible in the Pilot program in counties surrounding the pilot

bull MHL-LOC 005 (All other Facilities) or LOC 015 (County Care) These residents have to call Michigan Enrolls to dis-enroll toll-free at 1-800-975-7630 (TTY 1-888-263-5897) Monday-Friday from 8 AM to 7 PM Once they dis-enroll they will go to a LOC 02 you have to do a new LOCD

30

Medicaid Redetermination and MHL Enrollmentbull At the time of re-determination for Medicaid financial eligibility the MI

Health Link (MHL) program will not be sending beneficiaries information about this program Beneficiaries who previously opted out will not be passively enrolled according to an email from the MHL staff The MHL staff wrote

bull ldquoThere is currently no MI Health Link enrollment letter sent to beneficiaries when eligibility is re-determined A person who becomes eligible for MI Health Link enrollment may opt-in at any time

bull When Medicaid re-determination takes place the beneficiary remains in the same ICO unless that beneficiary lost Medicaid coverage If the enrollee loses Medicaid coverage and later regains it they are not passively enrolled into MI Health Link The beneficiary may choose to opt back in to the program at that time if desiredrdquo

bull MHL staff did state that about 1500 beneficiaries will be passively enrolled effective January 1 2016 These specific individuals were given normal notice of 60 and 30 days in which to opt-in or opt-out if they so chose No other large scale passive enrollment is scheduled according to the MHL staff 31

MI Health Link Portals

bull Meridian Health Planbull httpwwwmhplancommibull Amerihealthbull httpwwwamerihealthcaritasvipcarepluscomproviderself-service-

toolsindexaspxbull AetnaCoventrybull httpwwwaetnabetterhealthcomMichiganprovidersportalbull Molinabull httpwwwmolinahealthcarecommembersmien-usmemPageshomeaspxbull HAPMidwestbull httpswwwmidwesthealthplancomLoginaspxbull FidelisCentenebull wwwfidelissccommmp 32

MI Health Authorizationsbull We need to watch these authorization that the plans are giving us for the MI

Health program Some plans are assigning a diagnosis for residents in their prior authorizations They are assigning diagnosis that the residents do not even have You need to make sure these are correct diagnosis and if not you need to work with the case managers of the plans to fix the issue The authorization numbers do change

bull Make sure that any resident that is in a MI Health plan that you have a prior authorization All plans are giving different periods authorizing the residents stay in the facility You need to set up a system to make sure you always have a authorization for the period of time you are rendering the service Here is an example of time frame of authorizations

bull Meridian is authorizing 12 monthsbull Aetna is authorizing 3 monthsbull Molina is authorizing 6 monthsbull The authorization numbers need to go on your claims to the payer You need to

put the authorizations in your software and track the dates

33

MI Health Issuesbull We are seeing some issues with MI Health where the resident does not have the correct LOC or it shows

up correct on CHAMPS but ancillary providers such as Dentist and such cannot see it I think we still have some issues with the information crossing between Bridges DHS system CMS and CHAMPS It in return is creating some access of care issues If it is a true LOC issues Facilities with LOC issues need to submit the Medicaid ID numbers to the MSA-MHL-EnrollmentMichigangov box with the subject line Nursing home LOC Issue so they may work to resolve the issues

bull If it becomes an access to care issue email the information to INTEGRATEDCAREmichigangov Remember in these emails only send the Medicaid ID and explain the situation The State will work with the plans to try to fix the process or improve the process

bull We are also seeing with new admission with LOC 015 or 005 that the plans are stating they have 14 days to authorize admission These are resident in the emergency room and possibly be admitted to you for Rehab The hospital will not keep the resident in ER for 14 days and you cannot admit the resident until you have a prior authorization I would recommend when you are told this by the plan that you need to ask to speak to a manager We will have to work through this

bull Ancillary Provider You need to work with your ancillary providers such as Lab Pharmacy X-Ray Physician and such to get the to be credentialed with the plans We are hearing that some of the pharmacies are not participating with the plans this will create issues for you so I would continue to ask these groups to participate

34

LOC 02 dropping MI Health Issuesbull The passive enrollments have occurred in Macomb amp Wayne for

Medicaid dual eligible We are having the same issue we did as in the Southwest MI amp UP with the passive enrollments I am starting to hear from facilities who are checking there CHAMPS member screens that those residents that have opted out (some residents not all) have lost there 02 Make sure you are checking your CHAMPS member screen both for those that were passively enrolled and those that might have lost there 02 Medicaid that opted out

bull Facilities with LOC issues need to submit the Medicaid ID numbers to the (Only MI Health)MSA-MHL-Enrollmentmichigangov box with the subject line Nursing home LOC Issue so they may work to resolve the issues

35

PPA Offset

bull There are no co-pays deductibles or premiums in MI Health Link so there should be no need to offset the PPA with code 25 MI Health Link enrollees can continue to offset their PPA for non-program covered medical expenses (like Vision-Code 27 Dental-Code 28 and Hearing-Code 26) and use the appropriate codes to offset the PPA when billing the health plan for nursing facility services

bull Resident pay PPA when MedicareMedicaid coinsurance

36

LOCDbull Nursing Facility Level of Care Determination (NFLOCD)

bull The MI Health Link health plan will be responsible for conducting the Michigan Medicaid NFLOCD tool for enrollees seeking admission to a nursing facility For existing residents at the time of enrollment the existing NFLOCD will be adopted for capitation payment purposes The health plan will complete a new NFLCOD tool within the first 90 days of enrollment If a nursing facility resident is disenrolled from MI Health Link the nursing facility will be responsible for conducting a new NFLOCD tool in accordance with published Medicaid policy

37

MI Health Issues-New

bull INTEGRATEDCAREmichigangov

bull Email with Insurance Plan issues Case Manager Issues

38

ACOWhat are they

39

Families Receiving Letters for ACO

40

ACO What is It

bull Whats an ACObull Accountable Care Organizations (ACOs) are groups of doctors hospitals

and other health care providers who come together voluntarily to give coordinated high quality care to their Medicare patients

bull The goal of coordinated care is to ensure that patients especially the chronically ill get the right care at the right time while avoiding

unnecessary duplication of services and preventing medical errorsbull When an ACO succeeds both in delivering high-quality care and

spending health care dollars more wisely it will share in the savings it achieves for the Medicare program

41

Payroll Based JournalMandatory on July 1 2016Internet Explorer Version

Internet Explorer v 10 and v 11 will need to operate in compatibility mode

42

43

If you submit data manually should you also submit it through the XML

bull Now you have three options

bull Submit Manually only

bull Submit through the XML only

bull You are able to submit manually and using the XML

44

45

Staffing Submission Frequently Asked Questions

bull ldquoWho are direct care staffrdquo (Who do we submit data for)bull Submission of data for contract staffbull Medical directors and consultantsbull Staff switching roles or tasks throughout the daybull Hours paid vs hours worked ndash Must be verifiablebull Public postingQuality MeasuresFive Starbull Enforcementbull Voluntary submission risks (noneSo register now)

CMS defines

bull 37 job title codes that are required to match employees to the number of hours each direct care function was performed It is important to work with your teams to define the workers that contribute to each job type and how those daily worked hours are recorded and converted to a PBJ submission

bull The PBJ does include some more specific job descriptions than the 671 For example the PBJ system includes job descriptions for RNs with administrative duties and LPNs with administrative duties versus the 671rsquos more general ldquoNurses with Administrative Duties

Page 46

47

PBJ Medical Director Rolebull Physician Leadership

bull Help the facility ensure that patients have appropriate physician coverage and ensure the provision of physician and health care practitioner services and

bull Help the facility develop a process for reviewing physician and health care practitioner credentials

bull Provide specific guidance for physician performance expectations

bull Help the facility ensure that a system is in place for monitoring the performance of health care practitioners and

bull Facilitate feedback to physicians and other health care practitioners on performance and practices

bull Patient Care - Clinical Leadership

bull Participate in administrative decision-making and the development of policies and procedures related to patient care

bull Help develop approve and implement specific clinical practices for the facility to incorporate into its care-related policies and procedures including areas required by laws and regulations

bull Develop procedures and guidance for facility staff regarding contacting practitioners including information gathering and presentation change in condition assessment and when to contact the medical director

bull Review consider andor act upon consultant recommendations as appropriate that affect the facilitys resident care policies and procedures or the care of an individual resident

bull Review respond to and participate in federal state local and other external surveys and inspections and

bull Help review policies and procedures regarding the adequate protection of patients rights advance care planning and other ethical issues48

PBJ Medical Director Rolebull Quality of Care

bull Help the facility establish systems and methods for reviewing the quality and appropriateness of clinical care and other health-related services and provide appropriate feedback and

bull Participate in the facilitys quality improvement process

bull Advise on infection control issues and approve specific infection control policies to be incorporated into facility policies and procedures

bull Help the facility provide a safe and caring environment

bull Help promote employee health and safety and

bull Assist in the development and implementation of employee health policies and programs

bull Education Information and Communication

bull Promote a learning culture within the facility by educating informing and communicating

bull Provide information to help the facility provide care consistent with current standards of practice (defined as approaches to care procedures techniques and treatments that are based on research and or expert consensus and that are contained in current manuals textbooks and or publications or that are accepted adopted or promulgated by recognized organizations or national bodies)

bull Help the facility develop medical information and communication systems with staff patients and families and others

bull Represent the facility to the professional and lay community on medical and patient care issues

bull Maintain knowledge of the changing social regulatory political and economic factors that affect medical and health services of long term care patients and

bull Help establish appropriate relationships with other health care organizations

49

Dietician

bull When the dietary or food services supervisor is other than a registered dietitian the supervisor shall receive routine consultation and technical assistance from a registered dietitian (RD) Consultation time shall not be less than 4 hours every 60 days Additional consultation time may be needed based on the total number of patients incidence of nutrition-related health problems and food service management needs of the facility

50

Pharmacy Consultant

bull At least once per month a licensed pharmacist must perform a drug regimen review (DRR) for each resident The pharmacist must report any irregularities to the attending physician or director of nursing Furthermore these reports must be acted upon

51

What are the names for the Medicare Numberbull OSCAR -Online Survey Certification and Reporting

bull PTAN-PTAN number is assigned by Medicare to authenticate the provider when using the local Medicare Administrative Contractorrsquos (MAC) self-help tools like the IVR internet portal on-line application status etc Provider Transactions Access Number

bull CCN- CMS Certification Number

bull Medicare Number- example 23-

bull All of the above mean the same thing

52

QTSO

bull Once you are logged in the QTSO site bull You will have a state login to the site to access the various site specific

to your facilitybull Installing you will need administrator rights to your network

53

Medicare UpdateWhat are we seeing

54

CMS Final Rule On Returning Credits

httpswwwfederalregistergovarticles201602122016-02789medicare-program-reporting-and-returning-of-overpayments

55

Over Payment Rule

bull Medicare payments for non covered services

bull Medicare payments in excess of the allowable amount for an identified covered service

bull Errors and non reimbursable expenditures in cost reportsbull Duplicate payment

bull Receipt of Medicare payments when another payor had the primary responsibility for payment

56

Questions to MAC

bull Does the Medicare credit balance report change with this overpayment rule

bull No Medicare Credit Balances are still required at the end of each quarter

bull Will that still be the communication to let CMS or the MAC know that we have received an overpayment

bull Submission of Medicare Credit Balance is one form of communicating overpayments to CMS Other methods include submitting a voluntary refund with required claim information or the submission of a standard overpayment form

57

Questions to MAC

bull Will the MAC still deduct from a future RAbull If the recovery of the overpayment includes adjusting a claim then

the overpayment would be netted against future claims payments and reflected on the RA

bull Or will that process change with this new rulebull Process will remain the samebull Will NGS send communication out on thisbull Yes NGS will communicate this once the final rule is communicated

to the MACs by CMS However this could change depending on final CMS instructions

58

Final Rule on Returning Credits

bull Providers will want to immediately update their current policies governing overpayments in order to comply with this new rule which will take effect on March 14 2016

bull Providers and suppliers are required to use reasonable diligence to investigate credible information regarding overpayments through both proactive compliance efforts and reactive investigations

bull If an overpayment is identified then it must be repaid within 60 days An overpayment is identified when a person has or should have through the exercise of reasonable diligence determined that the person received an overpayment and quantified the amount

bull Providers and suppliers have a maximum of 8 months to report and return overpayments ndash up to 6 months to investigate and quantify the overpayment (ie to identify it) and up to 60 days to report and return the overpayment

59

Final Rule on Returning Credits

bull Providers and suppliers are required to report and return all overpayments within a 6-year lookback period

bull The cause and amount of the overpayment is irrelevant for the determination eg it was due to a mistake it was someone elsersquos fault it is a minor amount An overpayment is an overpayment and must be returned

bull Providers and suppliers must make their own determination to which entity to report and return the overpayment ie to the Medicare contractor or using the OIG Self Disclosure Protocol or the CMS Self Referral Disclosure Protocol

60

Final Rule on Returning Credits

bull Providers and suppliers may use the claims adjustment credit balance self-reported refund process or another appropriate process to report and return overpayments At this time there is no standard refund form to use

bull Failure to report and return an overpayment could subject the provider or supplier to False Claims Act liability Civil Monetary Penalties Law liability and exclusion from federal health care programs

61

P S amp R-Accountants will be asking for this information

The location you login into has changed it is now on EIDM EIDM is the acronym for CMS Enterprise Identity Management system which includes Identity Verification Access Management Authorization Assistance Workflow Tools and Identity Lifecycle Management functions

httpswwwcmsgovResearch-Statistics-Data-and-SystemsCMS-Information-TechnologyIACSCMS-Applications-Loginhtml

Go down the page and click on the PSampRSTARThis will take you to the login pagewill look the same as the old P S amp R didChanges Affecting PSampR System Access (Please Read) (posted 01292015)(Updated 5262015)is changingThe system which controls your PSampR user ID (currently IACS)The new system is referred to as EIDMThis will result in a different way to create new accounts or change passwords to existing accountsIf you already have an account in EIDM you may have to use that account for accessing PSampR after the transitionWhen is the change effectiveJune 13 2015What is staying the sameThe internet address for accessing PSampR remains the sameThe PSampR systemfunctionality is NOT changing 62

Medicare Advantage Payorsbull Medicare Advantage payors are pullingdenying payments on admissions if the patient was readmitted within 30 days after discharge The

client believes that the payors systematically denying payments for all readmissions within 30 days They believe this practice denies them due process to address whether the readmissions were justified and not due to a premature discharge of patient The payors seem to want to act like a QIO without having the same accountabilities of the QIO related to determinations of non-payment

bull Heres the QIO process under section 4240 of the QIO Manualbull 4240 - Readmission Review - (Rev 2 07-11-03)bull Readmission review involves admissions to an acute general short-term hospital occurring less than 31 calendar days from the date of

discharge from the same or another acute general short-term hospital (see sect1154(a)(13) and 42 CFR 47671(a)(8)(ii)) Neither the day of discharge nor the day of admission is counted when determining whether a readmission has occurred

bull A Medical Review Proceduresbull Obtain the appropriate medical records for the initial admission and readmission Perform case review on both stays Analyze the cases

specifically to determine whether the patient was prematurely discharged from the first confinement thus causing readmission Perform an analysis of the stay at the first hospital to determine the cause(s) and extent of any problem(s) (eg incomplete or substandard treatment) Consider the information available to the attending physician who discharged the patient from the first confinement Do not base a determination of a premature discharge on information that the physician or provider could not have known or events that could not have been anticipated at the time of discharge

bull Review both the initial admission and the readmission at the same time unless one of them has previously been reviewed In these cases use at a minimum the PRAF case summary of the other admission in addition to the medical record of the case under review

bull C Denialsbull Deny readmissions under the following circumstancesbull If the readmission was medically unnecessarybull If the readmission resulted from a premature discharge from the same hospital orbull If the readmission was a result of circumvention of PPS by the same hospital (see sect4255)bull With the QIO process there is an appeal within the QIO here the hospital is getting no opportunity to challenge the denials

63

Medicare Provider Enrollment Feebull Provider Enrollment Application Fee Amount for CY 2016bull On December 3 CMS issued a notice Provider Enrollment Application

Fee Amount for CY 2016 [CMSndash6066ndashN] Effective January 1 2016 the CY 2016 application fee is $554 for institutional providers that are

bull Initially enrolling in the Medicare or Medicaid program or the Childrens Health Insurance Program (CHIP)

bull Revalidating their Medicare Medicaid or CHIP enrollmentbull Adding a new Medicare practice locationbull This fee is required with any enrollment application submitted from

January 1 through December 31 2016

64

Medicare MAC-Higlas

bull Effective 142016 CMS has implemented a change to begin netting (offsetting) provider money across workloads within a single organization What this means is that any related providers conducting business in two different workloads (example New York and Maine) will have their money applied to any account receivables (AR) with a remaining balance owed to Medicare within both workloads For example Provider ABC is located in New York and is scheduled to receive a payment of $1000 on todays remittance advice Provider XYZ is related to provider ABC but is located in Maine and has ARs with a balance owed of $200 Provider ABCs $1000 payment will have the $200 applied against provider XYZs ARs resulting in a net payment of $800 This will be reflected on the remittance advice by the same PLB code as seen today for offsets for the $200

65

Two Midnight RuleChange January 1 2016 httpswwwcmsgovMedicareMedicare-Fee-for-Service-PaymentHospitalOutpatientPPSHospital-Outpatient-Regulations-and-Notices-ItemsCMS-1633-FChtml

66

Two Midnight Rulebull However effective January 1 2016 CMS will allow exceptions to the

Two-Midnight Benchmark to be determined on a case-by-case basis by the physician responsible for the care of the beneficiary subject to medical review Said differently Part A payment may be appropriate in some circumstances even though there is no expectation by the physician (or qualified ordering practitioner) of a two-midnight stay and one of the two pre-existing categorical exceptions (CMS ldquoinpatient onlyrdquo list and newly initiated mechanical ventilation) does not apply CMS has indicated that this change to the Two Midnight Rule is in response to stakeholder concern and CMSrsquos continued efforts to develop the most appropriate standard for determining Medicare Part A payment

67

Two Midnight Rulebull A new 42 CFR sect4123(a) provides that a patient is considered an

inpatient of a hospitalhellipif formally admitted as an inpatient pursuant to an order for inpatient admission by a physician or other qualified practitionerhellip The physician orders inpatient status when he or she expects the patient to require a stay that crosses at least 2 midnights[10] Stays expected to be shorter than at least two midnights are generally inappropriate for inpatient admission and inpatient payment under Medicare Part A unless the surgical procedure is specified by Medicare as inpatient only under sect41922(n)[11] The physicians expectationhellipshould be based on such complex medical factors as patient history and comorbidities the severity of signs and symptoms current medical needs and the risk of an adverse event[12] The physician order is part of physician certification of the medical necessity of hospital inpatient serviceshellip[13]

68

InPatient Vs Observation Conthellip

bull Physician certification which begins with an order for inpatient admission requires the physician to certify the reasons for the hospitalization the estimated time the patient will remain in the hospital and plans for post-hospital care if appropriate[14] The certification must be completed signed and documented in the medical record prior to discharge[15]

bull A physicians admission order has no presumptive weight and both the admission order and the physician certification will be evaluated in the context of the evidence in the medical record[16] CMS intends to provide additional information about what evidence in the medical record means in future instructions and manual revisions[17]

69

Two Midnight Rulebull Although the new case-by-case exception appears to be inherently

subjective to a certain extent CMS states that the following factors (among others) would be relevant to determining whether a patient requires inpatient admission under the expanded policy

bull The severity of the signs and symptoms exhibited by the patient bull The medical predictability of something adverse happening to the patient

and bull The need for diagnostic studies that appropriately are outpatient services

(that is their performance does not ordinarily require the patient to remain at the hospital for 24 hours or more)

bull CMS also notes that an inpatient admission (and Part A payment) should be ldquorare and unusualrdquo for minor surgical procedures or other treatment that is expected to keep the patient in the hospital ldquofor only a few hoursrdquo or for a period of time that ldquodoes not span at least overnightrdquo (thus a subset of stays not meeting the Two Midnight Benchmark) CMS indicates that such cases will be prioritized for medical review

70

Health Data Insights amp Medicare Plus Blue

RAC (Retrospective Audits)

71

HDI Health Data amp Med Plus Blue

bull httpwwwhealthdatainsightscombull Blue Cross Medicare Advantage Auditsbull Facilities seeing 10 to 15 requests for Medical Recordsbull In January amp Feburarybull Selected Health Data Insights because they were a premier Audit

Vendor for CMS Recovery Audit Contractor (RAC) demonstration Project They are a audit vendor for Humana

bull Providers not sending Medical Record will get technical denial and lose payments

72

Health Data InSight

bull In 2010 they began the Hospital Reviewbull Medicare Advantage encounter datandashCMS oversight of data integrity OIG

2016bull We will review CMSs oversight of MA encounter data validation and assess

the extent to which CMSrsquos Integrated Data Repository contains timely valid and complete MA encounter data In 2012 CMS began collecting from MA organizations a more comprehensive set of encounter data reflecting the items and services provided to MA plan enrollees Prior CMS and OIG audits have indicated vulnerabilities in the accuracy of data reporting by MA organizations Realizing the potential benefits of the MA encounter data for payment and program integrity oversight is contingent upon the datarsquos completeness validity and timeliness (OEI 03-15-00060 expected issue date FY 2017)

73

Pepper Reports

bull httpswwwpepperresourcesorg

bull Program for Evaluating Payment Patterns Electronic Report ( PEPPER)

bull Annually on or about April 18 2016 will be released

bull Pepper Portal httpssecurefiletmforg

74

CGI Technologies and Solutions Inc httpracbcgicomContactInfoaspxst=1

bull Indiana bull Michiganbull Minnesotabull Illinoisbull Kentuckybull Ohiobull Wisconsin CGI Technologies and Solutions Incbull For general and administrative questions regarding client service outreach

quality assurance or project-specific issues contactbull 1877316RACB (7222)bull Email racbcgicom Tamara Tate Tamaratatecmshhsgovbull 4107861288

75

CGI Federal RAC

bull CGI Federal RAC Region Bbull Email racbcgicombull Phone 1-877-316-RACB (7222)bull Mailing Addressbull Send medical records as followsbull Medical records for Indiana Illinois Kentucky Michigan Ohio Wisconsin

Minnesota DME and Home Health CGI Federal Inc Attn RACB Imaging Dept 1001 Lakeside Ave Suite 800 Cleveland OH 44114

bull If submitting paper records please send medical records as follows For Therapy Reviews CGI Federal Inc Attn RACB Imaging 1001 Lakeside Avenue Suite 800 Cleveland OH 44114

76

How to survive RAC Audit

bull National health expenditures totaled $1679 Billion in 2003 bull National health expenditures were 153 of GROSS Domestic Product

(GDP) in 2003 bull Health care cost increasing at +9 per year bull Doomsday predictions of Medicare running out bull Congressional Action

77

RAC Audits

bull Medicare Modernization Act (MMA) of 2003Mandated a three year audit demonstration project 2005-2008

bull Appoint audit contractors to review Medicare billings for proper coding DRG assignment and medical necessity

bull Audits will apply to all health care providers (hospitals physicians homecare dme etc)

bull Audit contractors to be paid on a contingency basis a percentage of overpayments recovered

78

How Did we get here

bull Overpayments collected due to errors in Medically Unnecessary Services ndash 40

bull Incorrectly Coded ndash 35

bull Other ndash 17

bull NoInsufficient Documentation ndash 8

79

Where are we now

bull All RACrsquos completed required provider outreachAccess to Medicare billing data base given to all RAC RAC review methodology

bull Automated Review-Black amp White Issues (current) bull DRG Validation-complex review (current) bull Complex Review for coding errors (current) bull DME Medical Necessity Reviews ndashcomplex review (calendar year

2010) bull Medical Necessity Reviews-complex review (calendar year 2010)

80

RAC Reviews

bull Responsibilities of the Team Leader bull Must learn each insurance provider participating in a RAC or RAC type

program bull What are their operating rulesbull What is their appeal process Time limits

May be different process for each insurance provider bull Develop a response team

Identify who does what when why and alternate bull individual

Build and develop a manual process Review of computerized system

81

Priority Health SCIO Health Analytics

bull httpswwwsciohealthanalyticscomcore-capabilitiespayment-integrityfacility-auditsskilled-nursing-facility-audits

bull Claims for Medicare members treated at Skilled Nursing Facilities are reimbursed based on the patientsrsquo RUG (Resource Utilization Group) score which is determined using the Minimum Data Set (MDS) Using SCIOs robust analytics claims andor providers that merit review are selected for audit SCIOs auditors conduct a detailed review of the complete medical record and associated MDS to determine if the billed RUG score is valid In the event the review determines that an incorrect RUG score was billed SCIOreg provides the valid score reports the reason the change was necessary and calculates the resulting overpayment

82

+ Cheer

Onward and Upward she shall prevail We are here to care for the residents and provide a wonderful

service

13 83

84

References

bull Priority Healthbull Blue Crossbull Medicaidbull Medicare

85

  • Medicare Mange Care amp Medicaid Changes in the New World We Live In
  • Medicaid
  • NEW Medicaid Change MIlogin
  • Blueprint for Health Innovation MI
  • Provider Enrollment Electronic Signature Form Submission Process MSA 15-54
  • Provider Enrollment Electronic Signature Form Submission Process
  • Provider Enrollment Domain Administrator
  • Medicaid Coinsurance Medicare Advantage
  • Slide Number 9
  • Lawsuit DHS Changes on Caregivers
  • TPL Medicaid Change
  • CHAMPS Member Screen
  • LOC dropping off Not Due to MI Health
  • Issues
  • Secure Email Information
  • Medicaid amp Hospice
  • Medicaid
  • Medicaid Medicare Buy In
  • Manage Medicaid
  • Healthy Michigan Residents
  • Healthy Michigan Medicaid Days
  • McLaren Health Plan
  • Manage Medicaid Plans January 1
  • Slide Number 24
  • MI Health Link
  • MI Health Link 2565
  • What are the Names
  • MI Health Dual Eligible
  • MI Health LOC
  • LOC Medicaid
  • Medicaid Redetermination and MHL Enrollment
  • MI Health Link Portals
  • MI Health Authorizations
  • MI Health Issues
  • LOC 02 dropping MI Health Issues
  • PPA Offset
  • LOCD
  • MI Health Issues-New
  • ACO
  • Families Receiving Letters for ACO
  • ACO What is It
  • Payroll Based Journal
  • Slide Number 43
  • If you submit data manually should you also submit it through the XML
  • Staffing Submission Frequently Asked Questions
  • CMS defines
  • Slide Number 47
  • PBJ Medical Director Role
  • PBJ Medical Director Role
  • Dietician
  • Pharmacy Consultant
  • What are the names for the Medicare Number
  • QTSO
  • Medicare Update
  • CMS Final Rule On Returning Credits
  • Over Payment Rule
  • Questions to MAC
  • Questions to MAC
  • Final Rule on Returning Credits
  • Final Rule on Returning Credits
  • Final Rule on Returning Credits
  • Slide Number 62
  • Medicare Advantage Payors
  • Medicare Provider Enrollment Fee
  • Medicare MAC-Higlas
  • Two Midnight Rule
  • Two Midnight Rule
  • Two Midnight Rule
  • InPatient Vs Observation Conthellip
  • Two Midnight Rule
  • Health Data Insights amp Medicare Plus Blue
  • HDI Health Data amp Med Plus Blue
  • Health Data InSight
  • Pepper Reports
  • CGI Technologies and Solutions Inc httpracbcgicomContactInfoaspxst=1
  • CGI Federal RAC
  • How to survive RAC Audit
  • RAC Audits
  • How Did we get here
  • Where are we now
  • RAC Reviews
  • Priority Health SCIO Health Analytics
  • Cheer
  • References
Page 29: Medicare, Mange Care & Medicaid Changes in the New World we live in

MI Health LOC

29

LOC Medicaidbull We have the new pilot program which started on March

1 2015 in Southwest Michigan Region 4 Counties Macomb Wayne and the UP You could see these patients they are dual eligible in the Pilot program in counties surrounding the pilot

bull MHL-LOC 005 (All other Facilities) or LOC 015 (County Care) These residents have to call Michigan Enrolls to dis-enroll toll-free at 1-800-975-7630 (TTY 1-888-263-5897) Monday-Friday from 8 AM to 7 PM Once they dis-enroll they will go to a LOC 02 you have to do a new LOCD

30

Medicaid Redetermination and MHL Enrollmentbull At the time of re-determination for Medicaid financial eligibility the MI

Health Link (MHL) program will not be sending beneficiaries information about this program Beneficiaries who previously opted out will not be passively enrolled according to an email from the MHL staff The MHL staff wrote

bull ldquoThere is currently no MI Health Link enrollment letter sent to beneficiaries when eligibility is re-determined A person who becomes eligible for MI Health Link enrollment may opt-in at any time

bull When Medicaid re-determination takes place the beneficiary remains in the same ICO unless that beneficiary lost Medicaid coverage If the enrollee loses Medicaid coverage and later regains it they are not passively enrolled into MI Health Link The beneficiary may choose to opt back in to the program at that time if desiredrdquo

bull MHL staff did state that about 1500 beneficiaries will be passively enrolled effective January 1 2016 These specific individuals were given normal notice of 60 and 30 days in which to opt-in or opt-out if they so chose No other large scale passive enrollment is scheduled according to the MHL staff 31

MI Health Link Portals

bull Meridian Health Planbull httpwwwmhplancommibull Amerihealthbull httpwwwamerihealthcaritasvipcarepluscomproviderself-service-

toolsindexaspxbull AetnaCoventrybull httpwwwaetnabetterhealthcomMichiganprovidersportalbull Molinabull httpwwwmolinahealthcarecommembersmien-usmemPageshomeaspxbull HAPMidwestbull httpswwwmidwesthealthplancomLoginaspxbull FidelisCentenebull wwwfidelissccommmp 32

MI Health Authorizationsbull We need to watch these authorization that the plans are giving us for the MI

Health program Some plans are assigning a diagnosis for residents in their prior authorizations They are assigning diagnosis that the residents do not even have You need to make sure these are correct diagnosis and if not you need to work with the case managers of the plans to fix the issue The authorization numbers do change

bull Make sure that any resident that is in a MI Health plan that you have a prior authorization All plans are giving different periods authorizing the residents stay in the facility You need to set up a system to make sure you always have a authorization for the period of time you are rendering the service Here is an example of time frame of authorizations

bull Meridian is authorizing 12 monthsbull Aetna is authorizing 3 monthsbull Molina is authorizing 6 monthsbull The authorization numbers need to go on your claims to the payer You need to

put the authorizations in your software and track the dates

33

MI Health Issuesbull We are seeing some issues with MI Health where the resident does not have the correct LOC or it shows

up correct on CHAMPS but ancillary providers such as Dentist and such cannot see it I think we still have some issues with the information crossing between Bridges DHS system CMS and CHAMPS It in return is creating some access of care issues If it is a true LOC issues Facilities with LOC issues need to submit the Medicaid ID numbers to the MSA-MHL-EnrollmentMichigangov box with the subject line Nursing home LOC Issue so they may work to resolve the issues

bull If it becomes an access to care issue email the information to INTEGRATEDCAREmichigangov Remember in these emails only send the Medicaid ID and explain the situation The State will work with the plans to try to fix the process or improve the process

bull We are also seeing with new admission with LOC 015 or 005 that the plans are stating they have 14 days to authorize admission These are resident in the emergency room and possibly be admitted to you for Rehab The hospital will not keep the resident in ER for 14 days and you cannot admit the resident until you have a prior authorization I would recommend when you are told this by the plan that you need to ask to speak to a manager We will have to work through this

bull Ancillary Provider You need to work with your ancillary providers such as Lab Pharmacy X-Ray Physician and such to get the to be credentialed with the plans We are hearing that some of the pharmacies are not participating with the plans this will create issues for you so I would continue to ask these groups to participate

34

LOC 02 dropping MI Health Issuesbull The passive enrollments have occurred in Macomb amp Wayne for

Medicaid dual eligible We are having the same issue we did as in the Southwest MI amp UP with the passive enrollments I am starting to hear from facilities who are checking there CHAMPS member screens that those residents that have opted out (some residents not all) have lost there 02 Make sure you are checking your CHAMPS member screen both for those that were passively enrolled and those that might have lost there 02 Medicaid that opted out

bull Facilities with LOC issues need to submit the Medicaid ID numbers to the (Only MI Health)MSA-MHL-Enrollmentmichigangov box with the subject line Nursing home LOC Issue so they may work to resolve the issues

35

PPA Offset

bull There are no co-pays deductibles or premiums in MI Health Link so there should be no need to offset the PPA with code 25 MI Health Link enrollees can continue to offset their PPA for non-program covered medical expenses (like Vision-Code 27 Dental-Code 28 and Hearing-Code 26) and use the appropriate codes to offset the PPA when billing the health plan for nursing facility services

bull Resident pay PPA when MedicareMedicaid coinsurance

36

LOCDbull Nursing Facility Level of Care Determination (NFLOCD)

bull The MI Health Link health plan will be responsible for conducting the Michigan Medicaid NFLOCD tool for enrollees seeking admission to a nursing facility For existing residents at the time of enrollment the existing NFLOCD will be adopted for capitation payment purposes The health plan will complete a new NFLCOD tool within the first 90 days of enrollment If a nursing facility resident is disenrolled from MI Health Link the nursing facility will be responsible for conducting a new NFLOCD tool in accordance with published Medicaid policy

37

MI Health Issues-New

bull INTEGRATEDCAREmichigangov

bull Email with Insurance Plan issues Case Manager Issues

38

ACOWhat are they

39

Families Receiving Letters for ACO

40

ACO What is It

bull Whats an ACObull Accountable Care Organizations (ACOs) are groups of doctors hospitals

and other health care providers who come together voluntarily to give coordinated high quality care to their Medicare patients

bull The goal of coordinated care is to ensure that patients especially the chronically ill get the right care at the right time while avoiding

unnecessary duplication of services and preventing medical errorsbull When an ACO succeeds both in delivering high-quality care and

spending health care dollars more wisely it will share in the savings it achieves for the Medicare program

41

Payroll Based JournalMandatory on July 1 2016Internet Explorer Version

Internet Explorer v 10 and v 11 will need to operate in compatibility mode

42

43

If you submit data manually should you also submit it through the XML

bull Now you have three options

bull Submit Manually only

bull Submit through the XML only

bull You are able to submit manually and using the XML

44

45

Staffing Submission Frequently Asked Questions

bull ldquoWho are direct care staffrdquo (Who do we submit data for)bull Submission of data for contract staffbull Medical directors and consultantsbull Staff switching roles or tasks throughout the daybull Hours paid vs hours worked ndash Must be verifiablebull Public postingQuality MeasuresFive Starbull Enforcementbull Voluntary submission risks (noneSo register now)

CMS defines

bull 37 job title codes that are required to match employees to the number of hours each direct care function was performed It is important to work with your teams to define the workers that contribute to each job type and how those daily worked hours are recorded and converted to a PBJ submission

bull The PBJ does include some more specific job descriptions than the 671 For example the PBJ system includes job descriptions for RNs with administrative duties and LPNs with administrative duties versus the 671rsquos more general ldquoNurses with Administrative Duties

Page 46

47

PBJ Medical Director Rolebull Physician Leadership

bull Help the facility ensure that patients have appropriate physician coverage and ensure the provision of physician and health care practitioner services and

bull Help the facility develop a process for reviewing physician and health care practitioner credentials

bull Provide specific guidance for physician performance expectations

bull Help the facility ensure that a system is in place for monitoring the performance of health care practitioners and

bull Facilitate feedback to physicians and other health care practitioners on performance and practices

bull Patient Care - Clinical Leadership

bull Participate in administrative decision-making and the development of policies and procedures related to patient care

bull Help develop approve and implement specific clinical practices for the facility to incorporate into its care-related policies and procedures including areas required by laws and regulations

bull Develop procedures and guidance for facility staff regarding contacting practitioners including information gathering and presentation change in condition assessment and when to contact the medical director

bull Review consider andor act upon consultant recommendations as appropriate that affect the facilitys resident care policies and procedures or the care of an individual resident

bull Review respond to and participate in federal state local and other external surveys and inspections and

bull Help review policies and procedures regarding the adequate protection of patients rights advance care planning and other ethical issues48

PBJ Medical Director Rolebull Quality of Care

bull Help the facility establish systems and methods for reviewing the quality and appropriateness of clinical care and other health-related services and provide appropriate feedback and

bull Participate in the facilitys quality improvement process

bull Advise on infection control issues and approve specific infection control policies to be incorporated into facility policies and procedures

bull Help the facility provide a safe and caring environment

bull Help promote employee health and safety and

bull Assist in the development and implementation of employee health policies and programs

bull Education Information and Communication

bull Promote a learning culture within the facility by educating informing and communicating

bull Provide information to help the facility provide care consistent with current standards of practice (defined as approaches to care procedures techniques and treatments that are based on research and or expert consensus and that are contained in current manuals textbooks and or publications or that are accepted adopted or promulgated by recognized organizations or national bodies)

bull Help the facility develop medical information and communication systems with staff patients and families and others

bull Represent the facility to the professional and lay community on medical and patient care issues

bull Maintain knowledge of the changing social regulatory political and economic factors that affect medical and health services of long term care patients and

bull Help establish appropriate relationships with other health care organizations

49

Dietician

bull When the dietary or food services supervisor is other than a registered dietitian the supervisor shall receive routine consultation and technical assistance from a registered dietitian (RD) Consultation time shall not be less than 4 hours every 60 days Additional consultation time may be needed based on the total number of patients incidence of nutrition-related health problems and food service management needs of the facility

50

Pharmacy Consultant

bull At least once per month a licensed pharmacist must perform a drug regimen review (DRR) for each resident The pharmacist must report any irregularities to the attending physician or director of nursing Furthermore these reports must be acted upon

51

What are the names for the Medicare Numberbull OSCAR -Online Survey Certification and Reporting

bull PTAN-PTAN number is assigned by Medicare to authenticate the provider when using the local Medicare Administrative Contractorrsquos (MAC) self-help tools like the IVR internet portal on-line application status etc Provider Transactions Access Number

bull CCN- CMS Certification Number

bull Medicare Number- example 23-

bull All of the above mean the same thing

52

QTSO

bull Once you are logged in the QTSO site bull You will have a state login to the site to access the various site specific

to your facilitybull Installing you will need administrator rights to your network

53

Medicare UpdateWhat are we seeing

54

CMS Final Rule On Returning Credits

httpswwwfederalregistergovarticles201602122016-02789medicare-program-reporting-and-returning-of-overpayments

55

Over Payment Rule

bull Medicare payments for non covered services

bull Medicare payments in excess of the allowable amount for an identified covered service

bull Errors and non reimbursable expenditures in cost reportsbull Duplicate payment

bull Receipt of Medicare payments when another payor had the primary responsibility for payment

56

Questions to MAC

bull Does the Medicare credit balance report change with this overpayment rule

bull No Medicare Credit Balances are still required at the end of each quarter

bull Will that still be the communication to let CMS or the MAC know that we have received an overpayment

bull Submission of Medicare Credit Balance is one form of communicating overpayments to CMS Other methods include submitting a voluntary refund with required claim information or the submission of a standard overpayment form

57

Questions to MAC

bull Will the MAC still deduct from a future RAbull If the recovery of the overpayment includes adjusting a claim then

the overpayment would be netted against future claims payments and reflected on the RA

bull Or will that process change with this new rulebull Process will remain the samebull Will NGS send communication out on thisbull Yes NGS will communicate this once the final rule is communicated

to the MACs by CMS However this could change depending on final CMS instructions

58

Final Rule on Returning Credits

bull Providers will want to immediately update their current policies governing overpayments in order to comply with this new rule which will take effect on March 14 2016

bull Providers and suppliers are required to use reasonable diligence to investigate credible information regarding overpayments through both proactive compliance efforts and reactive investigations

bull If an overpayment is identified then it must be repaid within 60 days An overpayment is identified when a person has or should have through the exercise of reasonable diligence determined that the person received an overpayment and quantified the amount

bull Providers and suppliers have a maximum of 8 months to report and return overpayments ndash up to 6 months to investigate and quantify the overpayment (ie to identify it) and up to 60 days to report and return the overpayment

59

Final Rule on Returning Credits

bull Providers and suppliers are required to report and return all overpayments within a 6-year lookback period

bull The cause and amount of the overpayment is irrelevant for the determination eg it was due to a mistake it was someone elsersquos fault it is a minor amount An overpayment is an overpayment and must be returned

bull Providers and suppliers must make their own determination to which entity to report and return the overpayment ie to the Medicare contractor or using the OIG Self Disclosure Protocol or the CMS Self Referral Disclosure Protocol

60

Final Rule on Returning Credits

bull Providers and suppliers may use the claims adjustment credit balance self-reported refund process or another appropriate process to report and return overpayments At this time there is no standard refund form to use

bull Failure to report and return an overpayment could subject the provider or supplier to False Claims Act liability Civil Monetary Penalties Law liability and exclusion from federal health care programs

61

P S amp R-Accountants will be asking for this information

The location you login into has changed it is now on EIDM EIDM is the acronym for CMS Enterprise Identity Management system which includes Identity Verification Access Management Authorization Assistance Workflow Tools and Identity Lifecycle Management functions

httpswwwcmsgovResearch-Statistics-Data-and-SystemsCMS-Information-TechnologyIACSCMS-Applications-Loginhtml

Go down the page and click on the PSampRSTARThis will take you to the login pagewill look the same as the old P S amp R didChanges Affecting PSampR System Access (Please Read) (posted 01292015)(Updated 5262015)is changingThe system which controls your PSampR user ID (currently IACS)The new system is referred to as EIDMThis will result in a different way to create new accounts or change passwords to existing accountsIf you already have an account in EIDM you may have to use that account for accessing PSampR after the transitionWhen is the change effectiveJune 13 2015What is staying the sameThe internet address for accessing PSampR remains the sameThe PSampR systemfunctionality is NOT changing 62

Medicare Advantage Payorsbull Medicare Advantage payors are pullingdenying payments on admissions if the patient was readmitted within 30 days after discharge The

client believes that the payors systematically denying payments for all readmissions within 30 days They believe this practice denies them due process to address whether the readmissions were justified and not due to a premature discharge of patient The payors seem to want to act like a QIO without having the same accountabilities of the QIO related to determinations of non-payment

bull Heres the QIO process under section 4240 of the QIO Manualbull 4240 - Readmission Review - (Rev 2 07-11-03)bull Readmission review involves admissions to an acute general short-term hospital occurring less than 31 calendar days from the date of

discharge from the same or another acute general short-term hospital (see sect1154(a)(13) and 42 CFR 47671(a)(8)(ii)) Neither the day of discharge nor the day of admission is counted when determining whether a readmission has occurred

bull A Medical Review Proceduresbull Obtain the appropriate medical records for the initial admission and readmission Perform case review on both stays Analyze the cases

specifically to determine whether the patient was prematurely discharged from the first confinement thus causing readmission Perform an analysis of the stay at the first hospital to determine the cause(s) and extent of any problem(s) (eg incomplete or substandard treatment) Consider the information available to the attending physician who discharged the patient from the first confinement Do not base a determination of a premature discharge on information that the physician or provider could not have known or events that could not have been anticipated at the time of discharge

bull Review both the initial admission and the readmission at the same time unless one of them has previously been reviewed In these cases use at a minimum the PRAF case summary of the other admission in addition to the medical record of the case under review

bull C Denialsbull Deny readmissions under the following circumstancesbull If the readmission was medically unnecessarybull If the readmission resulted from a premature discharge from the same hospital orbull If the readmission was a result of circumvention of PPS by the same hospital (see sect4255)bull With the QIO process there is an appeal within the QIO here the hospital is getting no opportunity to challenge the denials

63

Medicare Provider Enrollment Feebull Provider Enrollment Application Fee Amount for CY 2016bull On December 3 CMS issued a notice Provider Enrollment Application

Fee Amount for CY 2016 [CMSndash6066ndashN] Effective January 1 2016 the CY 2016 application fee is $554 for institutional providers that are

bull Initially enrolling in the Medicare or Medicaid program or the Childrens Health Insurance Program (CHIP)

bull Revalidating their Medicare Medicaid or CHIP enrollmentbull Adding a new Medicare practice locationbull This fee is required with any enrollment application submitted from

January 1 through December 31 2016

64

Medicare MAC-Higlas

bull Effective 142016 CMS has implemented a change to begin netting (offsetting) provider money across workloads within a single organization What this means is that any related providers conducting business in two different workloads (example New York and Maine) will have their money applied to any account receivables (AR) with a remaining balance owed to Medicare within both workloads For example Provider ABC is located in New York and is scheduled to receive a payment of $1000 on todays remittance advice Provider XYZ is related to provider ABC but is located in Maine and has ARs with a balance owed of $200 Provider ABCs $1000 payment will have the $200 applied against provider XYZs ARs resulting in a net payment of $800 This will be reflected on the remittance advice by the same PLB code as seen today for offsets for the $200

65

Two Midnight RuleChange January 1 2016 httpswwwcmsgovMedicareMedicare-Fee-for-Service-PaymentHospitalOutpatientPPSHospital-Outpatient-Regulations-and-Notices-ItemsCMS-1633-FChtml

66

Two Midnight Rulebull However effective January 1 2016 CMS will allow exceptions to the

Two-Midnight Benchmark to be determined on a case-by-case basis by the physician responsible for the care of the beneficiary subject to medical review Said differently Part A payment may be appropriate in some circumstances even though there is no expectation by the physician (or qualified ordering practitioner) of a two-midnight stay and one of the two pre-existing categorical exceptions (CMS ldquoinpatient onlyrdquo list and newly initiated mechanical ventilation) does not apply CMS has indicated that this change to the Two Midnight Rule is in response to stakeholder concern and CMSrsquos continued efforts to develop the most appropriate standard for determining Medicare Part A payment

67

Two Midnight Rulebull A new 42 CFR sect4123(a) provides that a patient is considered an

inpatient of a hospitalhellipif formally admitted as an inpatient pursuant to an order for inpatient admission by a physician or other qualified practitionerhellip The physician orders inpatient status when he or she expects the patient to require a stay that crosses at least 2 midnights[10] Stays expected to be shorter than at least two midnights are generally inappropriate for inpatient admission and inpatient payment under Medicare Part A unless the surgical procedure is specified by Medicare as inpatient only under sect41922(n)[11] The physicians expectationhellipshould be based on such complex medical factors as patient history and comorbidities the severity of signs and symptoms current medical needs and the risk of an adverse event[12] The physician order is part of physician certification of the medical necessity of hospital inpatient serviceshellip[13]

68

InPatient Vs Observation Conthellip

bull Physician certification which begins with an order for inpatient admission requires the physician to certify the reasons for the hospitalization the estimated time the patient will remain in the hospital and plans for post-hospital care if appropriate[14] The certification must be completed signed and documented in the medical record prior to discharge[15]

bull A physicians admission order has no presumptive weight and both the admission order and the physician certification will be evaluated in the context of the evidence in the medical record[16] CMS intends to provide additional information about what evidence in the medical record means in future instructions and manual revisions[17]

69

Two Midnight Rulebull Although the new case-by-case exception appears to be inherently

subjective to a certain extent CMS states that the following factors (among others) would be relevant to determining whether a patient requires inpatient admission under the expanded policy

bull The severity of the signs and symptoms exhibited by the patient bull The medical predictability of something adverse happening to the patient

and bull The need for diagnostic studies that appropriately are outpatient services

(that is their performance does not ordinarily require the patient to remain at the hospital for 24 hours or more)

bull CMS also notes that an inpatient admission (and Part A payment) should be ldquorare and unusualrdquo for minor surgical procedures or other treatment that is expected to keep the patient in the hospital ldquofor only a few hoursrdquo or for a period of time that ldquodoes not span at least overnightrdquo (thus a subset of stays not meeting the Two Midnight Benchmark) CMS indicates that such cases will be prioritized for medical review

70

Health Data Insights amp Medicare Plus Blue

RAC (Retrospective Audits)

71

HDI Health Data amp Med Plus Blue

bull httpwwwhealthdatainsightscombull Blue Cross Medicare Advantage Auditsbull Facilities seeing 10 to 15 requests for Medical Recordsbull In January amp Feburarybull Selected Health Data Insights because they were a premier Audit

Vendor for CMS Recovery Audit Contractor (RAC) demonstration Project They are a audit vendor for Humana

bull Providers not sending Medical Record will get technical denial and lose payments

72

Health Data InSight

bull In 2010 they began the Hospital Reviewbull Medicare Advantage encounter datandashCMS oversight of data integrity OIG

2016bull We will review CMSs oversight of MA encounter data validation and assess

the extent to which CMSrsquos Integrated Data Repository contains timely valid and complete MA encounter data In 2012 CMS began collecting from MA organizations a more comprehensive set of encounter data reflecting the items and services provided to MA plan enrollees Prior CMS and OIG audits have indicated vulnerabilities in the accuracy of data reporting by MA organizations Realizing the potential benefits of the MA encounter data for payment and program integrity oversight is contingent upon the datarsquos completeness validity and timeliness (OEI 03-15-00060 expected issue date FY 2017)

73

Pepper Reports

bull httpswwwpepperresourcesorg

bull Program for Evaluating Payment Patterns Electronic Report ( PEPPER)

bull Annually on or about April 18 2016 will be released

bull Pepper Portal httpssecurefiletmforg

74

CGI Technologies and Solutions Inc httpracbcgicomContactInfoaspxst=1

bull Indiana bull Michiganbull Minnesotabull Illinoisbull Kentuckybull Ohiobull Wisconsin CGI Technologies and Solutions Incbull For general and administrative questions regarding client service outreach

quality assurance or project-specific issues contactbull 1877316RACB (7222)bull Email racbcgicom Tamara Tate Tamaratatecmshhsgovbull 4107861288

75

CGI Federal RAC

bull CGI Federal RAC Region Bbull Email racbcgicombull Phone 1-877-316-RACB (7222)bull Mailing Addressbull Send medical records as followsbull Medical records for Indiana Illinois Kentucky Michigan Ohio Wisconsin

Minnesota DME and Home Health CGI Federal Inc Attn RACB Imaging Dept 1001 Lakeside Ave Suite 800 Cleveland OH 44114

bull If submitting paper records please send medical records as follows For Therapy Reviews CGI Federal Inc Attn RACB Imaging 1001 Lakeside Avenue Suite 800 Cleveland OH 44114

76

How to survive RAC Audit

bull National health expenditures totaled $1679 Billion in 2003 bull National health expenditures were 153 of GROSS Domestic Product

(GDP) in 2003 bull Health care cost increasing at +9 per year bull Doomsday predictions of Medicare running out bull Congressional Action

77

RAC Audits

bull Medicare Modernization Act (MMA) of 2003Mandated a three year audit demonstration project 2005-2008

bull Appoint audit contractors to review Medicare billings for proper coding DRG assignment and medical necessity

bull Audits will apply to all health care providers (hospitals physicians homecare dme etc)

bull Audit contractors to be paid on a contingency basis a percentage of overpayments recovered

78

How Did we get here

bull Overpayments collected due to errors in Medically Unnecessary Services ndash 40

bull Incorrectly Coded ndash 35

bull Other ndash 17

bull NoInsufficient Documentation ndash 8

79

Where are we now

bull All RACrsquos completed required provider outreachAccess to Medicare billing data base given to all RAC RAC review methodology

bull Automated Review-Black amp White Issues (current) bull DRG Validation-complex review (current) bull Complex Review for coding errors (current) bull DME Medical Necessity Reviews ndashcomplex review (calendar year

2010) bull Medical Necessity Reviews-complex review (calendar year 2010)

80

RAC Reviews

bull Responsibilities of the Team Leader bull Must learn each insurance provider participating in a RAC or RAC type

program bull What are their operating rulesbull What is their appeal process Time limits

May be different process for each insurance provider bull Develop a response team

Identify who does what when why and alternate bull individual

Build and develop a manual process Review of computerized system

81

Priority Health SCIO Health Analytics

bull httpswwwsciohealthanalyticscomcore-capabilitiespayment-integrityfacility-auditsskilled-nursing-facility-audits

bull Claims for Medicare members treated at Skilled Nursing Facilities are reimbursed based on the patientsrsquo RUG (Resource Utilization Group) score which is determined using the Minimum Data Set (MDS) Using SCIOs robust analytics claims andor providers that merit review are selected for audit SCIOs auditors conduct a detailed review of the complete medical record and associated MDS to determine if the billed RUG score is valid In the event the review determines that an incorrect RUG score was billed SCIOreg provides the valid score reports the reason the change was necessary and calculates the resulting overpayment

82

+ Cheer

Onward and Upward she shall prevail We are here to care for the residents and provide a wonderful

service

13 83

84

References

bull Priority Healthbull Blue Crossbull Medicaidbull Medicare

85

  • Medicare Mange Care amp Medicaid Changes in the New World We Live In
  • Medicaid
  • NEW Medicaid Change MIlogin
  • Blueprint for Health Innovation MI
  • Provider Enrollment Electronic Signature Form Submission Process MSA 15-54
  • Provider Enrollment Electronic Signature Form Submission Process
  • Provider Enrollment Domain Administrator
  • Medicaid Coinsurance Medicare Advantage
  • Slide Number 9
  • Lawsuit DHS Changes on Caregivers
  • TPL Medicaid Change
  • CHAMPS Member Screen
  • LOC dropping off Not Due to MI Health
  • Issues
  • Secure Email Information
  • Medicaid amp Hospice
  • Medicaid
  • Medicaid Medicare Buy In
  • Manage Medicaid
  • Healthy Michigan Residents
  • Healthy Michigan Medicaid Days
  • McLaren Health Plan
  • Manage Medicaid Plans January 1
  • Slide Number 24
  • MI Health Link
  • MI Health Link 2565
  • What are the Names
  • MI Health Dual Eligible
  • MI Health LOC
  • LOC Medicaid
  • Medicaid Redetermination and MHL Enrollment
  • MI Health Link Portals
  • MI Health Authorizations
  • MI Health Issues
  • LOC 02 dropping MI Health Issues
  • PPA Offset
  • LOCD
  • MI Health Issues-New
  • ACO
  • Families Receiving Letters for ACO
  • ACO What is It
  • Payroll Based Journal
  • Slide Number 43
  • If you submit data manually should you also submit it through the XML
  • Staffing Submission Frequently Asked Questions
  • CMS defines
  • Slide Number 47
  • PBJ Medical Director Role
  • PBJ Medical Director Role
  • Dietician
  • Pharmacy Consultant
  • What are the names for the Medicare Number
  • QTSO
  • Medicare Update
  • CMS Final Rule On Returning Credits
  • Over Payment Rule
  • Questions to MAC
  • Questions to MAC
  • Final Rule on Returning Credits
  • Final Rule on Returning Credits
  • Final Rule on Returning Credits
  • Slide Number 62
  • Medicare Advantage Payors
  • Medicare Provider Enrollment Fee
  • Medicare MAC-Higlas
  • Two Midnight Rule
  • Two Midnight Rule
  • Two Midnight Rule
  • InPatient Vs Observation Conthellip
  • Two Midnight Rule
  • Health Data Insights amp Medicare Plus Blue
  • HDI Health Data amp Med Plus Blue
  • Health Data InSight
  • Pepper Reports
  • CGI Technologies and Solutions Inc httpracbcgicomContactInfoaspxst=1
  • CGI Federal RAC
  • How to survive RAC Audit
  • RAC Audits
  • How Did we get here
  • Where are we now
  • RAC Reviews
  • Priority Health SCIO Health Analytics
  • Cheer
  • References
Page 30: Medicare, Mange Care & Medicaid Changes in the New World we live in

LOC Medicaidbull We have the new pilot program which started on March

1 2015 in Southwest Michigan Region 4 Counties Macomb Wayne and the UP You could see these patients they are dual eligible in the Pilot program in counties surrounding the pilot

bull MHL-LOC 005 (All other Facilities) or LOC 015 (County Care) These residents have to call Michigan Enrolls to dis-enroll toll-free at 1-800-975-7630 (TTY 1-888-263-5897) Monday-Friday from 8 AM to 7 PM Once they dis-enroll they will go to a LOC 02 you have to do a new LOCD

30

Medicaid Redetermination and MHL Enrollmentbull At the time of re-determination for Medicaid financial eligibility the MI

Health Link (MHL) program will not be sending beneficiaries information about this program Beneficiaries who previously opted out will not be passively enrolled according to an email from the MHL staff The MHL staff wrote

bull ldquoThere is currently no MI Health Link enrollment letter sent to beneficiaries when eligibility is re-determined A person who becomes eligible for MI Health Link enrollment may opt-in at any time

bull When Medicaid re-determination takes place the beneficiary remains in the same ICO unless that beneficiary lost Medicaid coverage If the enrollee loses Medicaid coverage and later regains it they are not passively enrolled into MI Health Link The beneficiary may choose to opt back in to the program at that time if desiredrdquo

bull MHL staff did state that about 1500 beneficiaries will be passively enrolled effective January 1 2016 These specific individuals were given normal notice of 60 and 30 days in which to opt-in or opt-out if they so chose No other large scale passive enrollment is scheduled according to the MHL staff 31

MI Health Link Portals

bull Meridian Health Planbull httpwwwmhplancommibull Amerihealthbull httpwwwamerihealthcaritasvipcarepluscomproviderself-service-

toolsindexaspxbull AetnaCoventrybull httpwwwaetnabetterhealthcomMichiganprovidersportalbull Molinabull httpwwwmolinahealthcarecommembersmien-usmemPageshomeaspxbull HAPMidwestbull httpswwwmidwesthealthplancomLoginaspxbull FidelisCentenebull wwwfidelissccommmp 32

MI Health Authorizationsbull We need to watch these authorization that the plans are giving us for the MI

Health program Some plans are assigning a diagnosis for residents in their prior authorizations They are assigning diagnosis that the residents do not even have You need to make sure these are correct diagnosis and if not you need to work with the case managers of the plans to fix the issue The authorization numbers do change

bull Make sure that any resident that is in a MI Health plan that you have a prior authorization All plans are giving different periods authorizing the residents stay in the facility You need to set up a system to make sure you always have a authorization for the period of time you are rendering the service Here is an example of time frame of authorizations

bull Meridian is authorizing 12 monthsbull Aetna is authorizing 3 monthsbull Molina is authorizing 6 monthsbull The authorization numbers need to go on your claims to the payer You need to

put the authorizations in your software and track the dates

33

MI Health Issuesbull We are seeing some issues with MI Health where the resident does not have the correct LOC or it shows

up correct on CHAMPS but ancillary providers such as Dentist and such cannot see it I think we still have some issues with the information crossing between Bridges DHS system CMS and CHAMPS It in return is creating some access of care issues If it is a true LOC issues Facilities with LOC issues need to submit the Medicaid ID numbers to the MSA-MHL-EnrollmentMichigangov box with the subject line Nursing home LOC Issue so they may work to resolve the issues

bull If it becomes an access to care issue email the information to INTEGRATEDCAREmichigangov Remember in these emails only send the Medicaid ID and explain the situation The State will work with the plans to try to fix the process or improve the process

bull We are also seeing with new admission with LOC 015 or 005 that the plans are stating they have 14 days to authorize admission These are resident in the emergency room and possibly be admitted to you for Rehab The hospital will not keep the resident in ER for 14 days and you cannot admit the resident until you have a prior authorization I would recommend when you are told this by the plan that you need to ask to speak to a manager We will have to work through this

bull Ancillary Provider You need to work with your ancillary providers such as Lab Pharmacy X-Ray Physician and such to get the to be credentialed with the plans We are hearing that some of the pharmacies are not participating with the plans this will create issues for you so I would continue to ask these groups to participate

34

LOC 02 dropping MI Health Issuesbull The passive enrollments have occurred in Macomb amp Wayne for

Medicaid dual eligible We are having the same issue we did as in the Southwest MI amp UP with the passive enrollments I am starting to hear from facilities who are checking there CHAMPS member screens that those residents that have opted out (some residents not all) have lost there 02 Make sure you are checking your CHAMPS member screen both for those that were passively enrolled and those that might have lost there 02 Medicaid that opted out

bull Facilities with LOC issues need to submit the Medicaid ID numbers to the (Only MI Health)MSA-MHL-Enrollmentmichigangov box with the subject line Nursing home LOC Issue so they may work to resolve the issues

35

PPA Offset

bull There are no co-pays deductibles or premiums in MI Health Link so there should be no need to offset the PPA with code 25 MI Health Link enrollees can continue to offset their PPA for non-program covered medical expenses (like Vision-Code 27 Dental-Code 28 and Hearing-Code 26) and use the appropriate codes to offset the PPA when billing the health plan for nursing facility services

bull Resident pay PPA when MedicareMedicaid coinsurance

36

LOCDbull Nursing Facility Level of Care Determination (NFLOCD)

bull The MI Health Link health plan will be responsible for conducting the Michigan Medicaid NFLOCD tool for enrollees seeking admission to a nursing facility For existing residents at the time of enrollment the existing NFLOCD will be adopted for capitation payment purposes The health plan will complete a new NFLCOD tool within the first 90 days of enrollment If a nursing facility resident is disenrolled from MI Health Link the nursing facility will be responsible for conducting a new NFLOCD tool in accordance with published Medicaid policy

37

MI Health Issues-New

bull INTEGRATEDCAREmichigangov

bull Email with Insurance Plan issues Case Manager Issues

38

ACOWhat are they

39

Families Receiving Letters for ACO

40

ACO What is It

bull Whats an ACObull Accountable Care Organizations (ACOs) are groups of doctors hospitals

and other health care providers who come together voluntarily to give coordinated high quality care to their Medicare patients

bull The goal of coordinated care is to ensure that patients especially the chronically ill get the right care at the right time while avoiding

unnecessary duplication of services and preventing medical errorsbull When an ACO succeeds both in delivering high-quality care and

spending health care dollars more wisely it will share in the savings it achieves for the Medicare program

41

Payroll Based JournalMandatory on July 1 2016Internet Explorer Version

Internet Explorer v 10 and v 11 will need to operate in compatibility mode

42

43

If you submit data manually should you also submit it through the XML

bull Now you have three options

bull Submit Manually only

bull Submit through the XML only

bull You are able to submit manually and using the XML

44

45

Staffing Submission Frequently Asked Questions

bull ldquoWho are direct care staffrdquo (Who do we submit data for)bull Submission of data for contract staffbull Medical directors and consultantsbull Staff switching roles or tasks throughout the daybull Hours paid vs hours worked ndash Must be verifiablebull Public postingQuality MeasuresFive Starbull Enforcementbull Voluntary submission risks (noneSo register now)

CMS defines

bull 37 job title codes that are required to match employees to the number of hours each direct care function was performed It is important to work with your teams to define the workers that contribute to each job type and how those daily worked hours are recorded and converted to a PBJ submission

bull The PBJ does include some more specific job descriptions than the 671 For example the PBJ system includes job descriptions for RNs with administrative duties and LPNs with administrative duties versus the 671rsquos more general ldquoNurses with Administrative Duties

Page 46

47

PBJ Medical Director Rolebull Physician Leadership

bull Help the facility ensure that patients have appropriate physician coverage and ensure the provision of physician and health care practitioner services and

bull Help the facility develop a process for reviewing physician and health care practitioner credentials

bull Provide specific guidance for physician performance expectations

bull Help the facility ensure that a system is in place for monitoring the performance of health care practitioners and

bull Facilitate feedback to physicians and other health care practitioners on performance and practices

bull Patient Care - Clinical Leadership

bull Participate in administrative decision-making and the development of policies and procedures related to patient care

bull Help develop approve and implement specific clinical practices for the facility to incorporate into its care-related policies and procedures including areas required by laws and regulations

bull Develop procedures and guidance for facility staff regarding contacting practitioners including information gathering and presentation change in condition assessment and when to contact the medical director

bull Review consider andor act upon consultant recommendations as appropriate that affect the facilitys resident care policies and procedures or the care of an individual resident

bull Review respond to and participate in federal state local and other external surveys and inspections and

bull Help review policies and procedures regarding the adequate protection of patients rights advance care planning and other ethical issues48

PBJ Medical Director Rolebull Quality of Care

bull Help the facility establish systems and methods for reviewing the quality and appropriateness of clinical care and other health-related services and provide appropriate feedback and

bull Participate in the facilitys quality improvement process

bull Advise on infection control issues and approve specific infection control policies to be incorporated into facility policies and procedures

bull Help the facility provide a safe and caring environment

bull Help promote employee health and safety and

bull Assist in the development and implementation of employee health policies and programs

bull Education Information and Communication

bull Promote a learning culture within the facility by educating informing and communicating

bull Provide information to help the facility provide care consistent with current standards of practice (defined as approaches to care procedures techniques and treatments that are based on research and or expert consensus and that are contained in current manuals textbooks and or publications or that are accepted adopted or promulgated by recognized organizations or national bodies)

bull Help the facility develop medical information and communication systems with staff patients and families and others

bull Represent the facility to the professional and lay community on medical and patient care issues

bull Maintain knowledge of the changing social regulatory political and economic factors that affect medical and health services of long term care patients and

bull Help establish appropriate relationships with other health care organizations

49

Dietician

bull When the dietary or food services supervisor is other than a registered dietitian the supervisor shall receive routine consultation and technical assistance from a registered dietitian (RD) Consultation time shall not be less than 4 hours every 60 days Additional consultation time may be needed based on the total number of patients incidence of nutrition-related health problems and food service management needs of the facility

50

Pharmacy Consultant

bull At least once per month a licensed pharmacist must perform a drug regimen review (DRR) for each resident The pharmacist must report any irregularities to the attending physician or director of nursing Furthermore these reports must be acted upon

51

What are the names for the Medicare Numberbull OSCAR -Online Survey Certification and Reporting

bull PTAN-PTAN number is assigned by Medicare to authenticate the provider when using the local Medicare Administrative Contractorrsquos (MAC) self-help tools like the IVR internet portal on-line application status etc Provider Transactions Access Number

bull CCN- CMS Certification Number

bull Medicare Number- example 23-

bull All of the above mean the same thing

52

QTSO

bull Once you are logged in the QTSO site bull You will have a state login to the site to access the various site specific

to your facilitybull Installing you will need administrator rights to your network

53

Medicare UpdateWhat are we seeing

54

CMS Final Rule On Returning Credits

httpswwwfederalregistergovarticles201602122016-02789medicare-program-reporting-and-returning-of-overpayments

55

Over Payment Rule

bull Medicare payments for non covered services

bull Medicare payments in excess of the allowable amount for an identified covered service

bull Errors and non reimbursable expenditures in cost reportsbull Duplicate payment

bull Receipt of Medicare payments when another payor had the primary responsibility for payment

56

Questions to MAC

bull Does the Medicare credit balance report change with this overpayment rule

bull No Medicare Credit Balances are still required at the end of each quarter

bull Will that still be the communication to let CMS or the MAC know that we have received an overpayment

bull Submission of Medicare Credit Balance is one form of communicating overpayments to CMS Other methods include submitting a voluntary refund with required claim information or the submission of a standard overpayment form

57

Questions to MAC

bull Will the MAC still deduct from a future RAbull If the recovery of the overpayment includes adjusting a claim then

the overpayment would be netted against future claims payments and reflected on the RA

bull Or will that process change with this new rulebull Process will remain the samebull Will NGS send communication out on thisbull Yes NGS will communicate this once the final rule is communicated

to the MACs by CMS However this could change depending on final CMS instructions

58

Final Rule on Returning Credits

bull Providers will want to immediately update their current policies governing overpayments in order to comply with this new rule which will take effect on March 14 2016

bull Providers and suppliers are required to use reasonable diligence to investigate credible information regarding overpayments through both proactive compliance efforts and reactive investigations

bull If an overpayment is identified then it must be repaid within 60 days An overpayment is identified when a person has or should have through the exercise of reasonable diligence determined that the person received an overpayment and quantified the amount

bull Providers and suppliers have a maximum of 8 months to report and return overpayments ndash up to 6 months to investigate and quantify the overpayment (ie to identify it) and up to 60 days to report and return the overpayment

59

Final Rule on Returning Credits

bull Providers and suppliers are required to report and return all overpayments within a 6-year lookback period

bull The cause and amount of the overpayment is irrelevant for the determination eg it was due to a mistake it was someone elsersquos fault it is a minor amount An overpayment is an overpayment and must be returned

bull Providers and suppliers must make their own determination to which entity to report and return the overpayment ie to the Medicare contractor or using the OIG Self Disclosure Protocol or the CMS Self Referral Disclosure Protocol

60

Final Rule on Returning Credits

bull Providers and suppliers may use the claims adjustment credit balance self-reported refund process or another appropriate process to report and return overpayments At this time there is no standard refund form to use

bull Failure to report and return an overpayment could subject the provider or supplier to False Claims Act liability Civil Monetary Penalties Law liability and exclusion from federal health care programs

61

P S amp R-Accountants will be asking for this information

The location you login into has changed it is now on EIDM EIDM is the acronym for CMS Enterprise Identity Management system which includes Identity Verification Access Management Authorization Assistance Workflow Tools and Identity Lifecycle Management functions

httpswwwcmsgovResearch-Statistics-Data-and-SystemsCMS-Information-TechnologyIACSCMS-Applications-Loginhtml

Go down the page and click on the PSampRSTARThis will take you to the login pagewill look the same as the old P S amp R didChanges Affecting PSampR System Access (Please Read) (posted 01292015)(Updated 5262015)is changingThe system which controls your PSampR user ID (currently IACS)The new system is referred to as EIDMThis will result in a different way to create new accounts or change passwords to existing accountsIf you already have an account in EIDM you may have to use that account for accessing PSampR after the transitionWhen is the change effectiveJune 13 2015What is staying the sameThe internet address for accessing PSampR remains the sameThe PSampR systemfunctionality is NOT changing 62

Medicare Advantage Payorsbull Medicare Advantage payors are pullingdenying payments on admissions if the patient was readmitted within 30 days after discharge The

client believes that the payors systematically denying payments for all readmissions within 30 days They believe this practice denies them due process to address whether the readmissions were justified and not due to a premature discharge of patient The payors seem to want to act like a QIO without having the same accountabilities of the QIO related to determinations of non-payment

bull Heres the QIO process under section 4240 of the QIO Manualbull 4240 - Readmission Review - (Rev 2 07-11-03)bull Readmission review involves admissions to an acute general short-term hospital occurring less than 31 calendar days from the date of

discharge from the same or another acute general short-term hospital (see sect1154(a)(13) and 42 CFR 47671(a)(8)(ii)) Neither the day of discharge nor the day of admission is counted when determining whether a readmission has occurred

bull A Medical Review Proceduresbull Obtain the appropriate medical records for the initial admission and readmission Perform case review on both stays Analyze the cases

specifically to determine whether the patient was prematurely discharged from the first confinement thus causing readmission Perform an analysis of the stay at the first hospital to determine the cause(s) and extent of any problem(s) (eg incomplete or substandard treatment) Consider the information available to the attending physician who discharged the patient from the first confinement Do not base a determination of a premature discharge on information that the physician or provider could not have known or events that could not have been anticipated at the time of discharge

bull Review both the initial admission and the readmission at the same time unless one of them has previously been reviewed In these cases use at a minimum the PRAF case summary of the other admission in addition to the medical record of the case under review

bull C Denialsbull Deny readmissions under the following circumstancesbull If the readmission was medically unnecessarybull If the readmission resulted from a premature discharge from the same hospital orbull If the readmission was a result of circumvention of PPS by the same hospital (see sect4255)bull With the QIO process there is an appeal within the QIO here the hospital is getting no opportunity to challenge the denials

63

Medicare Provider Enrollment Feebull Provider Enrollment Application Fee Amount for CY 2016bull On December 3 CMS issued a notice Provider Enrollment Application

Fee Amount for CY 2016 [CMSndash6066ndashN] Effective January 1 2016 the CY 2016 application fee is $554 for institutional providers that are

bull Initially enrolling in the Medicare or Medicaid program or the Childrens Health Insurance Program (CHIP)

bull Revalidating their Medicare Medicaid or CHIP enrollmentbull Adding a new Medicare practice locationbull This fee is required with any enrollment application submitted from

January 1 through December 31 2016

64

Medicare MAC-Higlas

bull Effective 142016 CMS has implemented a change to begin netting (offsetting) provider money across workloads within a single organization What this means is that any related providers conducting business in two different workloads (example New York and Maine) will have their money applied to any account receivables (AR) with a remaining balance owed to Medicare within both workloads For example Provider ABC is located in New York and is scheduled to receive a payment of $1000 on todays remittance advice Provider XYZ is related to provider ABC but is located in Maine and has ARs with a balance owed of $200 Provider ABCs $1000 payment will have the $200 applied against provider XYZs ARs resulting in a net payment of $800 This will be reflected on the remittance advice by the same PLB code as seen today for offsets for the $200

65

Two Midnight RuleChange January 1 2016 httpswwwcmsgovMedicareMedicare-Fee-for-Service-PaymentHospitalOutpatientPPSHospital-Outpatient-Regulations-and-Notices-ItemsCMS-1633-FChtml

66

Two Midnight Rulebull However effective January 1 2016 CMS will allow exceptions to the

Two-Midnight Benchmark to be determined on a case-by-case basis by the physician responsible for the care of the beneficiary subject to medical review Said differently Part A payment may be appropriate in some circumstances even though there is no expectation by the physician (or qualified ordering practitioner) of a two-midnight stay and one of the two pre-existing categorical exceptions (CMS ldquoinpatient onlyrdquo list and newly initiated mechanical ventilation) does not apply CMS has indicated that this change to the Two Midnight Rule is in response to stakeholder concern and CMSrsquos continued efforts to develop the most appropriate standard for determining Medicare Part A payment

67

Two Midnight Rulebull A new 42 CFR sect4123(a) provides that a patient is considered an

inpatient of a hospitalhellipif formally admitted as an inpatient pursuant to an order for inpatient admission by a physician or other qualified practitionerhellip The physician orders inpatient status when he or she expects the patient to require a stay that crosses at least 2 midnights[10] Stays expected to be shorter than at least two midnights are generally inappropriate for inpatient admission and inpatient payment under Medicare Part A unless the surgical procedure is specified by Medicare as inpatient only under sect41922(n)[11] The physicians expectationhellipshould be based on such complex medical factors as patient history and comorbidities the severity of signs and symptoms current medical needs and the risk of an adverse event[12] The physician order is part of physician certification of the medical necessity of hospital inpatient serviceshellip[13]

68

InPatient Vs Observation Conthellip

bull Physician certification which begins with an order for inpatient admission requires the physician to certify the reasons for the hospitalization the estimated time the patient will remain in the hospital and plans for post-hospital care if appropriate[14] The certification must be completed signed and documented in the medical record prior to discharge[15]

bull A physicians admission order has no presumptive weight and both the admission order and the physician certification will be evaluated in the context of the evidence in the medical record[16] CMS intends to provide additional information about what evidence in the medical record means in future instructions and manual revisions[17]

69

Two Midnight Rulebull Although the new case-by-case exception appears to be inherently

subjective to a certain extent CMS states that the following factors (among others) would be relevant to determining whether a patient requires inpatient admission under the expanded policy

bull The severity of the signs and symptoms exhibited by the patient bull The medical predictability of something adverse happening to the patient

and bull The need for diagnostic studies that appropriately are outpatient services

(that is their performance does not ordinarily require the patient to remain at the hospital for 24 hours or more)

bull CMS also notes that an inpatient admission (and Part A payment) should be ldquorare and unusualrdquo for minor surgical procedures or other treatment that is expected to keep the patient in the hospital ldquofor only a few hoursrdquo or for a period of time that ldquodoes not span at least overnightrdquo (thus a subset of stays not meeting the Two Midnight Benchmark) CMS indicates that such cases will be prioritized for medical review

70

Health Data Insights amp Medicare Plus Blue

RAC (Retrospective Audits)

71

HDI Health Data amp Med Plus Blue

bull httpwwwhealthdatainsightscombull Blue Cross Medicare Advantage Auditsbull Facilities seeing 10 to 15 requests for Medical Recordsbull In January amp Feburarybull Selected Health Data Insights because they were a premier Audit

Vendor for CMS Recovery Audit Contractor (RAC) demonstration Project They are a audit vendor for Humana

bull Providers not sending Medical Record will get technical denial and lose payments

72

Health Data InSight

bull In 2010 they began the Hospital Reviewbull Medicare Advantage encounter datandashCMS oversight of data integrity OIG

2016bull We will review CMSs oversight of MA encounter data validation and assess

the extent to which CMSrsquos Integrated Data Repository contains timely valid and complete MA encounter data In 2012 CMS began collecting from MA organizations a more comprehensive set of encounter data reflecting the items and services provided to MA plan enrollees Prior CMS and OIG audits have indicated vulnerabilities in the accuracy of data reporting by MA organizations Realizing the potential benefits of the MA encounter data for payment and program integrity oversight is contingent upon the datarsquos completeness validity and timeliness (OEI 03-15-00060 expected issue date FY 2017)

73

Pepper Reports

bull httpswwwpepperresourcesorg

bull Program for Evaluating Payment Patterns Electronic Report ( PEPPER)

bull Annually on or about April 18 2016 will be released

bull Pepper Portal httpssecurefiletmforg

74

CGI Technologies and Solutions Inc httpracbcgicomContactInfoaspxst=1

bull Indiana bull Michiganbull Minnesotabull Illinoisbull Kentuckybull Ohiobull Wisconsin CGI Technologies and Solutions Incbull For general and administrative questions regarding client service outreach

quality assurance or project-specific issues contactbull 1877316RACB (7222)bull Email racbcgicom Tamara Tate Tamaratatecmshhsgovbull 4107861288

75

CGI Federal RAC

bull CGI Federal RAC Region Bbull Email racbcgicombull Phone 1-877-316-RACB (7222)bull Mailing Addressbull Send medical records as followsbull Medical records for Indiana Illinois Kentucky Michigan Ohio Wisconsin

Minnesota DME and Home Health CGI Federal Inc Attn RACB Imaging Dept 1001 Lakeside Ave Suite 800 Cleveland OH 44114

bull If submitting paper records please send medical records as follows For Therapy Reviews CGI Federal Inc Attn RACB Imaging 1001 Lakeside Avenue Suite 800 Cleveland OH 44114

76

How to survive RAC Audit

bull National health expenditures totaled $1679 Billion in 2003 bull National health expenditures were 153 of GROSS Domestic Product

(GDP) in 2003 bull Health care cost increasing at +9 per year bull Doomsday predictions of Medicare running out bull Congressional Action

77

RAC Audits

bull Medicare Modernization Act (MMA) of 2003Mandated a three year audit demonstration project 2005-2008

bull Appoint audit contractors to review Medicare billings for proper coding DRG assignment and medical necessity

bull Audits will apply to all health care providers (hospitals physicians homecare dme etc)

bull Audit contractors to be paid on a contingency basis a percentage of overpayments recovered

78

How Did we get here

bull Overpayments collected due to errors in Medically Unnecessary Services ndash 40

bull Incorrectly Coded ndash 35

bull Other ndash 17

bull NoInsufficient Documentation ndash 8

79

Where are we now

bull All RACrsquos completed required provider outreachAccess to Medicare billing data base given to all RAC RAC review methodology

bull Automated Review-Black amp White Issues (current) bull DRG Validation-complex review (current) bull Complex Review for coding errors (current) bull DME Medical Necessity Reviews ndashcomplex review (calendar year

2010) bull Medical Necessity Reviews-complex review (calendar year 2010)

80

RAC Reviews

bull Responsibilities of the Team Leader bull Must learn each insurance provider participating in a RAC or RAC type

program bull What are their operating rulesbull What is their appeal process Time limits

May be different process for each insurance provider bull Develop a response team

Identify who does what when why and alternate bull individual

Build and develop a manual process Review of computerized system

81

Priority Health SCIO Health Analytics

bull httpswwwsciohealthanalyticscomcore-capabilitiespayment-integrityfacility-auditsskilled-nursing-facility-audits

bull Claims for Medicare members treated at Skilled Nursing Facilities are reimbursed based on the patientsrsquo RUG (Resource Utilization Group) score which is determined using the Minimum Data Set (MDS) Using SCIOs robust analytics claims andor providers that merit review are selected for audit SCIOs auditors conduct a detailed review of the complete medical record and associated MDS to determine if the billed RUG score is valid In the event the review determines that an incorrect RUG score was billed SCIOreg provides the valid score reports the reason the change was necessary and calculates the resulting overpayment

82

+ Cheer

Onward and Upward she shall prevail We are here to care for the residents and provide a wonderful

service

13 83

84

References

bull Priority Healthbull Blue Crossbull Medicaidbull Medicare

85

  • Medicare Mange Care amp Medicaid Changes in the New World We Live In
  • Medicaid
  • NEW Medicaid Change MIlogin
  • Blueprint for Health Innovation MI
  • Provider Enrollment Electronic Signature Form Submission Process MSA 15-54
  • Provider Enrollment Electronic Signature Form Submission Process
  • Provider Enrollment Domain Administrator
  • Medicaid Coinsurance Medicare Advantage
  • Slide Number 9
  • Lawsuit DHS Changes on Caregivers
  • TPL Medicaid Change
  • CHAMPS Member Screen
  • LOC dropping off Not Due to MI Health
  • Issues
  • Secure Email Information
  • Medicaid amp Hospice
  • Medicaid
  • Medicaid Medicare Buy In
  • Manage Medicaid
  • Healthy Michigan Residents
  • Healthy Michigan Medicaid Days
  • McLaren Health Plan
  • Manage Medicaid Plans January 1
  • Slide Number 24
  • MI Health Link
  • MI Health Link 2565
  • What are the Names
  • MI Health Dual Eligible
  • MI Health LOC
  • LOC Medicaid
  • Medicaid Redetermination and MHL Enrollment
  • MI Health Link Portals
  • MI Health Authorizations
  • MI Health Issues
  • LOC 02 dropping MI Health Issues
  • PPA Offset
  • LOCD
  • MI Health Issues-New
  • ACO
  • Families Receiving Letters for ACO
  • ACO What is It
  • Payroll Based Journal
  • Slide Number 43
  • If you submit data manually should you also submit it through the XML
  • Staffing Submission Frequently Asked Questions
  • CMS defines
  • Slide Number 47
  • PBJ Medical Director Role
  • PBJ Medical Director Role
  • Dietician
  • Pharmacy Consultant
  • What are the names for the Medicare Number
  • QTSO
  • Medicare Update
  • CMS Final Rule On Returning Credits
  • Over Payment Rule
  • Questions to MAC
  • Questions to MAC
  • Final Rule on Returning Credits
  • Final Rule on Returning Credits
  • Final Rule on Returning Credits
  • Slide Number 62
  • Medicare Advantage Payors
  • Medicare Provider Enrollment Fee
  • Medicare MAC-Higlas
  • Two Midnight Rule
  • Two Midnight Rule
  • Two Midnight Rule
  • InPatient Vs Observation Conthellip
  • Two Midnight Rule
  • Health Data Insights amp Medicare Plus Blue
  • HDI Health Data amp Med Plus Blue
  • Health Data InSight
  • Pepper Reports
  • CGI Technologies and Solutions Inc httpracbcgicomContactInfoaspxst=1
  • CGI Federal RAC
  • How to survive RAC Audit
  • RAC Audits
  • How Did we get here
  • Where are we now
  • RAC Reviews
  • Priority Health SCIO Health Analytics
  • Cheer
  • References
Page 31: Medicare, Mange Care & Medicaid Changes in the New World we live in

Medicaid Redetermination and MHL Enrollmentbull At the time of re-determination for Medicaid financial eligibility the MI

Health Link (MHL) program will not be sending beneficiaries information about this program Beneficiaries who previously opted out will not be passively enrolled according to an email from the MHL staff The MHL staff wrote

bull ldquoThere is currently no MI Health Link enrollment letter sent to beneficiaries when eligibility is re-determined A person who becomes eligible for MI Health Link enrollment may opt-in at any time

bull When Medicaid re-determination takes place the beneficiary remains in the same ICO unless that beneficiary lost Medicaid coverage If the enrollee loses Medicaid coverage and later regains it they are not passively enrolled into MI Health Link The beneficiary may choose to opt back in to the program at that time if desiredrdquo

bull MHL staff did state that about 1500 beneficiaries will be passively enrolled effective January 1 2016 These specific individuals were given normal notice of 60 and 30 days in which to opt-in or opt-out if they so chose No other large scale passive enrollment is scheduled according to the MHL staff 31

MI Health Link Portals

bull Meridian Health Planbull httpwwwmhplancommibull Amerihealthbull httpwwwamerihealthcaritasvipcarepluscomproviderself-service-

toolsindexaspxbull AetnaCoventrybull httpwwwaetnabetterhealthcomMichiganprovidersportalbull Molinabull httpwwwmolinahealthcarecommembersmien-usmemPageshomeaspxbull HAPMidwestbull httpswwwmidwesthealthplancomLoginaspxbull FidelisCentenebull wwwfidelissccommmp 32

MI Health Authorizationsbull We need to watch these authorization that the plans are giving us for the MI

Health program Some plans are assigning a diagnosis for residents in their prior authorizations They are assigning diagnosis that the residents do not even have You need to make sure these are correct diagnosis and if not you need to work with the case managers of the plans to fix the issue The authorization numbers do change

bull Make sure that any resident that is in a MI Health plan that you have a prior authorization All plans are giving different periods authorizing the residents stay in the facility You need to set up a system to make sure you always have a authorization for the period of time you are rendering the service Here is an example of time frame of authorizations

bull Meridian is authorizing 12 monthsbull Aetna is authorizing 3 monthsbull Molina is authorizing 6 monthsbull The authorization numbers need to go on your claims to the payer You need to

put the authorizations in your software and track the dates

33

MI Health Issuesbull We are seeing some issues with MI Health where the resident does not have the correct LOC or it shows

up correct on CHAMPS but ancillary providers such as Dentist and such cannot see it I think we still have some issues with the information crossing between Bridges DHS system CMS and CHAMPS It in return is creating some access of care issues If it is a true LOC issues Facilities with LOC issues need to submit the Medicaid ID numbers to the MSA-MHL-EnrollmentMichigangov box with the subject line Nursing home LOC Issue so they may work to resolve the issues

bull If it becomes an access to care issue email the information to INTEGRATEDCAREmichigangov Remember in these emails only send the Medicaid ID and explain the situation The State will work with the plans to try to fix the process or improve the process

bull We are also seeing with new admission with LOC 015 or 005 that the plans are stating they have 14 days to authorize admission These are resident in the emergency room and possibly be admitted to you for Rehab The hospital will not keep the resident in ER for 14 days and you cannot admit the resident until you have a prior authorization I would recommend when you are told this by the plan that you need to ask to speak to a manager We will have to work through this

bull Ancillary Provider You need to work with your ancillary providers such as Lab Pharmacy X-Ray Physician and such to get the to be credentialed with the plans We are hearing that some of the pharmacies are not participating with the plans this will create issues for you so I would continue to ask these groups to participate

34

LOC 02 dropping MI Health Issuesbull The passive enrollments have occurred in Macomb amp Wayne for

Medicaid dual eligible We are having the same issue we did as in the Southwest MI amp UP with the passive enrollments I am starting to hear from facilities who are checking there CHAMPS member screens that those residents that have opted out (some residents not all) have lost there 02 Make sure you are checking your CHAMPS member screen both for those that were passively enrolled and those that might have lost there 02 Medicaid that opted out

bull Facilities with LOC issues need to submit the Medicaid ID numbers to the (Only MI Health)MSA-MHL-Enrollmentmichigangov box with the subject line Nursing home LOC Issue so they may work to resolve the issues

35

PPA Offset

bull There are no co-pays deductibles or premiums in MI Health Link so there should be no need to offset the PPA with code 25 MI Health Link enrollees can continue to offset their PPA for non-program covered medical expenses (like Vision-Code 27 Dental-Code 28 and Hearing-Code 26) and use the appropriate codes to offset the PPA when billing the health plan for nursing facility services

bull Resident pay PPA when MedicareMedicaid coinsurance

36

LOCDbull Nursing Facility Level of Care Determination (NFLOCD)

bull The MI Health Link health plan will be responsible for conducting the Michigan Medicaid NFLOCD tool for enrollees seeking admission to a nursing facility For existing residents at the time of enrollment the existing NFLOCD will be adopted for capitation payment purposes The health plan will complete a new NFLCOD tool within the first 90 days of enrollment If a nursing facility resident is disenrolled from MI Health Link the nursing facility will be responsible for conducting a new NFLOCD tool in accordance with published Medicaid policy

37

MI Health Issues-New

bull INTEGRATEDCAREmichigangov

bull Email with Insurance Plan issues Case Manager Issues

38

ACOWhat are they

39

Families Receiving Letters for ACO

40

ACO What is It

bull Whats an ACObull Accountable Care Organizations (ACOs) are groups of doctors hospitals

and other health care providers who come together voluntarily to give coordinated high quality care to their Medicare patients

bull The goal of coordinated care is to ensure that patients especially the chronically ill get the right care at the right time while avoiding

unnecessary duplication of services and preventing medical errorsbull When an ACO succeeds both in delivering high-quality care and

spending health care dollars more wisely it will share in the savings it achieves for the Medicare program

41

Payroll Based JournalMandatory on July 1 2016Internet Explorer Version

Internet Explorer v 10 and v 11 will need to operate in compatibility mode

42

43

If you submit data manually should you also submit it through the XML

bull Now you have three options

bull Submit Manually only

bull Submit through the XML only

bull You are able to submit manually and using the XML

44

45

Staffing Submission Frequently Asked Questions

bull ldquoWho are direct care staffrdquo (Who do we submit data for)bull Submission of data for contract staffbull Medical directors and consultantsbull Staff switching roles or tasks throughout the daybull Hours paid vs hours worked ndash Must be verifiablebull Public postingQuality MeasuresFive Starbull Enforcementbull Voluntary submission risks (noneSo register now)

CMS defines

bull 37 job title codes that are required to match employees to the number of hours each direct care function was performed It is important to work with your teams to define the workers that contribute to each job type and how those daily worked hours are recorded and converted to a PBJ submission

bull The PBJ does include some more specific job descriptions than the 671 For example the PBJ system includes job descriptions for RNs with administrative duties and LPNs with administrative duties versus the 671rsquos more general ldquoNurses with Administrative Duties

Page 46

47

PBJ Medical Director Rolebull Physician Leadership

bull Help the facility ensure that patients have appropriate physician coverage and ensure the provision of physician and health care practitioner services and

bull Help the facility develop a process for reviewing physician and health care practitioner credentials

bull Provide specific guidance for physician performance expectations

bull Help the facility ensure that a system is in place for monitoring the performance of health care practitioners and

bull Facilitate feedback to physicians and other health care practitioners on performance and practices

bull Patient Care - Clinical Leadership

bull Participate in administrative decision-making and the development of policies and procedures related to patient care

bull Help develop approve and implement specific clinical practices for the facility to incorporate into its care-related policies and procedures including areas required by laws and regulations

bull Develop procedures and guidance for facility staff regarding contacting practitioners including information gathering and presentation change in condition assessment and when to contact the medical director

bull Review consider andor act upon consultant recommendations as appropriate that affect the facilitys resident care policies and procedures or the care of an individual resident

bull Review respond to and participate in federal state local and other external surveys and inspections and

bull Help review policies and procedures regarding the adequate protection of patients rights advance care planning and other ethical issues48

PBJ Medical Director Rolebull Quality of Care

bull Help the facility establish systems and methods for reviewing the quality and appropriateness of clinical care and other health-related services and provide appropriate feedback and

bull Participate in the facilitys quality improvement process

bull Advise on infection control issues and approve specific infection control policies to be incorporated into facility policies and procedures

bull Help the facility provide a safe and caring environment

bull Help promote employee health and safety and

bull Assist in the development and implementation of employee health policies and programs

bull Education Information and Communication

bull Promote a learning culture within the facility by educating informing and communicating

bull Provide information to help the facility provide care consistent with current standards of practice (defined as approaches to care procedures techniques and treatments that are based on research and or expert consensus and that are contained in current manuals textbooks and or publications or that are accepted adopted or promulgated by recognized organizations or national bodies)

bull Help the facility develop medical information and communication systems with staff patients and families and others

bull Represent the facility to the professional and lay community on medical and patient care issues

bull Maintain knowledge of the changing social regulatory political and economic factors that affect medical and health services of long term care patients and

bull Help establish appropriate relationships with other health care organizations

49

Dietician

bull When the dietary or food services supervisor is other than a registered dietitian the supervisor shall receive routine consultation and technical assistance from a registered dietitian (RD) Consultation time shall not be less than 4 hours every 60 days Additional consultation time may be needed based on the total number of patients incidence of nutrition-related health problems and food service management needs of the facility

50

Pharmacy Consultant

bull At least once per month a licensed pharmacist must perform a drug regimen review (DRR) for each resident The pharmacist must report any irregularities to the attending physician or director of nursing Furthermore these reports must be acted upon

51

What are the names for the Medicare Numberbull OSCAR -Online Survey Certification and Reporting

bull PTAN-PTAN number is assigned by Medicare to authenticate the provider when using the local Medicare Administrative Contractorrsquos (MAC) self-help tools like the IVR internet portal on-line application status etc Provider Transactions Access Number

bull CCN- CMS Certification Number

bull Medicare Number- example 23-

bull All of the above mean the same thing

52

QTSO

bull Once you are logged in the QTSO site bull You will have a state login to the site to access the various site specific

to your facilitybull Installing you will need administrator rights to your network

53

Medicare UpdateWhat are we seeing

54

CMS Final Rule On Returning Credits

httpswwwfederalregistergovarticles201602122016-02789medicare-program-reporting-and-returning-of-overpayments

55

Over Payment Rule

bull Medicare payments for non covered services

bull Medicare payments in excess of the allowable amount for an identified covered service

bull Errors and non reimbursable expenditures in cost reportsbull Duplicate payment

bull Receipt of Medicare payments when another payor had the primary responsibility for payment

56

Questions to MAC

bull Does the Medicare credit balance report change with this overpayment rule

bull No Medicare Credit Balances are still required at the end of each quarter

bull Will that still be the communication to let CMS or the MAC know that we have received an overpayment

bull Submission of Medicare Credit Balance is one form of communicating overpayments to CMS Other methods include submitting a voluntary refund with required claim information or the submission of a standard overpayment form

57

Questions to MAC

bull Will the MAC still deduct from a future RAbull If the recovery of the overpayment includes adjusting a claim then

the overpayment would be netted against future claims payments and reflected on the RA

bull Or will that process change with this new rulebull Process will remain the samebull Will NGS send communication out on thisbull Yes NGS will communicate this once the final rule is communicated

to the MACs by CMS However this could change depending on final CMS instructions

58

Final Rule on Returning Credits

bull Providers will want to immediately update their current policies governing overpayments in order to comply with this new rule which will take effect on March 14 2016

bull Providers and suppliers are required to use reasonable diligence to investigate credible information regarding overpayments through both proactive compliance efforts and reactive investigations

bull If an overpayment is identified then it must be repaid within 60 days An overpayment is identified when a person has or should have through the exercise of reasonable diligence determined that the person received an overpayment and quantified the amount

bull Providers and suppliers have a maximum of 8 months to report and return overpayments ndash up to 6 months to investigate and quantify the overpayment (ie to identify it) and up to 60 days to report and return the overpayment

59

Final Rule on Returning Credits

bull Providers and suppliers are required to report and return all overpayments within a 6-year lookback period

bull The cause and amount of the overpayment is irrelevant for the determination eg it was due to a mistake it was someone elsersquos fault it is a minor amount An overpayment is an overpayment and must be returned

bull Providers and suppliers must make their own determination to which entity to report and return the overpayment ie to the Medicare contractor or using the OIG Self Disclosure Protocol or the CMS Self Referral Disclosure Protocol

60

Final Rule on Returning Credits

bull Providers and suppliers may use the claims adjustment credit balance self-reported refund process or another appropriate process to report and return overpayments At this time there is no standard refund form to use

bull Failure to report and return an overpayment could subject the provider or supplier to False Claims Act liability Civil Monetary Penalties Law liability and exclusion from federal health care programs

61

P S amp R-Accountants will be asking for this information

The location you login into has changed it is now on EIDM EIDM is the acronym for CMS Enterprise Identity Management system which includes Identity Verification Access Management Authorization Assistance Workflow Tools and Identity Lifecycle Management functions

httpswwwcmsgovResearch-Statistics-Data-and-SystemsCMS-Information-TechnologyIACSCMS-Applications-Loginhtml

Go down the page and click on the PSampRSTARThis will take you to the login pagewill look the same as the old P S amp R didChanges Affecting PSampR System Access (Please Read) (posted 01292015)(Updated 5262015)is changingThe system which controls your PSampR user ID (currently IACS)The new system is referred to as EIDMThis will result in a different way to create new accounts or change passwords to existing accountsIf you already have an account in EIDM you may have to use that account for accessing PSampR after the transitionWhen is the change effectiveJune 13 2015What is staying the sameThe internet address for accessing PSampR remains the sameThe PSampR systemfunctionality is NOT changing 62

Medicare Advantage Payorsbull Medicare Advantage payors are pullingdenying payments on admissions if the patient was readmitted within 30 days after discharge The

client believes that the payors systematically denying payments for all readmissions within 30 days They believe this practice denies them due process to address whether the readmissions were justified and not due to a premature discharge of patient The payors seem to want to act like a QIO without having the same accountabilities of the QIO related to determinations of non-payment

bull Heres the QIO process under section 4240 of the QIO Manualbull 4240 - Readmission Review - (Rev 2 07-11-03)bull Readmission review involves admissions to an acute general short-term hospital occurring less than 31 calendar days from the date of

discharge from the same or another acute general short-term hospital (see sect1154(a)(13) and 42 CFR 47671(a)(8)(ii)) Neither the day of discharge nor the day of admission is counted when determining whether a readmission has occurred

bull A Medical Review Proceduresbull Obtain the appropriate medical records for the initial admission and readmission Perform case review on both stays Analyze the cases

specifically to determine whether the patient was prematurely discharged from the first confinement thus causing readmission Perform an analysis of the stay at the first hospital to determine the cause(s) and extent of any problem(s) (eg incomplete or substandard treatment) Consider the information available to the attending physician who discharged the patient from the first confinement Do not base a determination of a premature discharge on information that the physician or provider could not have known or events that could not have been anticipated at the time of discharge

bull Review both the initial admission and the readmission at the same time unless one of them has previously been reviewed In these cases use at a minimum the PRAF case summary of the other admission in addition to the medical record of the case under review

bull C Denialsbull Deny readmissions under the following circumstancesbull If the readmission was medically unnecessarybull If the readmission resulted from a premature discharge from the same hospital orbull If the readmission was a result of circumvention of PPS by the same hospital (see sect4255)bull With the QIO process there is an appeal within the QIO here the hospital is getting no opportunity to challenge the denials

63

Medicare Provider Enrollment Feebull Provider Enrollment Application Fee Amount for CY 2016bull On December 3 CMS issued a notice Provider Enrollment Application

Fee Amount for CY 2016 [CMSndash6066ndashN] Effective January 1 2016 the CY 2016 application fee is $554 for institutional providers that are

bull Initially enrolling in the Medicare or Medicaid program or the Childrens Health Insurance Program (CHIP)

bull Revalidating their Medicare Medicaid or CHIP enrollmentbull Adding a new Medicare practice locationbull This fee is required with any enrollment application submitted from

January 1 through December 31 2016

64

Medicare MAC-Higlas

bull Effective 142016 CMS has implemented a change to begin netting (offsetting) provider money across workloads within a single organization What this means is that any related providers conducting business in two different workloads (example New York and Maine) will have their money applied to any account receivables (AR) with a remaining balance owed to Medicare within both workloads For example Provider ABC is located in New York and is scheduled to receive a payment of $1000 on todays remittance advice Provider XYZ is related to provider ABC but is located in Maine and has ARs with a balance owed of $200 Provider ABCs $1000 payment will have the $200 applied against provider XYZs ARs resulting in a net payment of $800 This will be reflected on the remittance advice by the same PLB code as seen today for offsets for the $200

65

Two Midnight RuleChange January 1 2016 httpswwwcmsgovMedicareMedicare-Fee-for-Service-PaymentHospitalOutpatientPPSHospital-Outpatient-Regulations-and-Notices-ItemsCMS-1633-FChtml

66

Two Midnight Rulebull However effective January 1 2016 CMS will allow exceptions to the

Two-Midnight Benchmark to be determined on a case-by-case basis by the physician responsible for the care of the beneficiary subject to medical review Said differently Part A payment may be appropriate in some circumstances even though there is no expectation by the physician (or qualified ordering practitioner) of a two-midnight stay and one of the two pre-existing categorical exceptions (CMS ldquoinpatient onlyrdquo list and newly initiated mechanical ventilation) does not apply CMS has indicated that this change to the Two Midnight Rule is in response to stakeholder concern and CMSrsquos continued efforts to develop the most appropriate standard for determining Medicare Part A payment

67

Two Midnight Rulebull A new 42 CFR sect4123(a) provides that a patient is considered an

inpatient of a hospitalhellipif formally admitted as an inpatient pursuant to an order for inpatient admission by a physician or other qualified practitionerhellip The physician orders inpatient status when he or she expects the patient to require a stay that crosses at least 2 midnights[10] Stays expected to be shorter than at least two midnights are generally inappropriate for inpatient admission and inpatient payment under Medicare Part A unless the surgical procedure is specified by Medicare as inpatient only under sect41922(n)[11] The physicians expectationhellipshould be based on such complex medical factors as patient history and comorbidities the severity of signs and symptoms current medical needs and the risk of an adverse event[12] The physician order is part of physician certification of the medical necessity of hospital inpatient serviceshellip[13]

68

InPatient Vs Observation Conthellip

bull Physician certification which begins with an order for inpatient admission requires the physician to certify the reasons for the hospitalization the estimated time the patient will remain in the hospital and plans for post-hospital care if appropriate[14] The certification must be completed signed and documented in the medical record prior to discharge[15]

bull A physicians admission order has no presumptive weight and both the admission order and the physician certification will be evaluated in the context of the evidence in the medical record[16] CMS intends to provide additional information about what evidence in the medical record means in future instructions and manual revisions[17]

69

Two Midnight Rulebull Although the new case-by-case exception appears to be inherently

subjective to a certain extent CMS states that the following factors (among others) would be relevant to determining whether a patient requires inpatient admission under the expanded policy

bull The severity of the signs and symptoms exhibited by the patient bull The medical predictability of something adverse happening to the patient

and bull The need for diagnostic studies that appropriately are outpatient services

(that is their performance does not ordinarily require the patient to remain at the hospital for 24 hours or more)

bull CMS also notes that an inpatient admission (and Part A payment) should be ldquorare and unusualrdquo for minor surgical procedures or other treatment that is expected to keep the patient in the hospital ldquofor only a few hoursrdquo or for a period of time that ldquodoes not span at least overnightrdquo (thus a subset of stays not meeting the Two Midnight Benchmark) CMS indicates that such cases will be prioritized for medical review

70

Health Data Insights amp Medicare Plus Blue

RAC (Retrospective Audits)

71

HDI Health Data amp Med Plus Blue

bull httpwwwhealthdatainsightscombull Blue Cross Medicare Advantage Auditsbull Facilities seeing 10 to 15 requests for Medical Recordsbull In January amp Feburarybull Selected Health Data Insights because they were a premier Audit

Vendor for CMS Recovery Audit Contractor (RAC) demonstration Project They are a audit vendor for Humana

bull Providers not sending Medical Record will get technical denial and lose payments

72

Health Data InSight

bull In 2010 they began the Hospital Reviewbull Medicare Advantage encounter datandashCMS oversight of data integrity OIG

2016bull We will review CMSs oversight of MA encounter data validation and assess

the extent to which CMSrsquos Integrated Data Repository contains timely valid and complete MA encounter data In 2012 CMS began collecting from MA organizations a more comprehensive set of encounter data reflecting the items and services provided to MA plan enrollees Prior CMS and OIG audits have indicated vulnerabilities in the accuracy of data reporting by MA organizations Realizing the potential benefits of the MA encounter data for payment and program integrity oversight is contingent upon the datarsquos completeness validity and timeliness (OEI 03-15-00060 expected issue date FY 2017)

73

Pepper Reports

bull httpswwwpepperresourcesorg

bull Program for Evaluating Payment Patterns Electronic Report ( PEPPER)

bull Annually on or about April 18 2016 will be released

bull Pepper Portal httpssecurefiletmforg

74

CGI Technologies and Solutions Inc httpracbcgicomContactInfoaspxst=1

bull Indiana bull Michiganbull Minnesotabull Illinoisbull Kentuckybull Ohiobull Wisconsin CGI Technologies and Solutions Incbull For general and administrative questions regarding client service outreach

quality assurance or project-specific issues contactbull 1877316RACB (7222)bull Email racbcgicom Tamara Tate Tamaratatecmshhsgovbull 4107861288

75

CGI Federal RAC

bull CGI Federal RAC Region Bbull Email racbcgicombull Phone 1-877-316-RACB (7222)bull Mailing Addressbull Send medical records as followsbull Medical records for Indiana Illinois Kentucky Michigan Ohio Wisconsin

Minnesota DME and Home Health CGI Federal Inc Attn RACB Imaging Dept 1001 Lakeside Ave Suite 800 Cleveland OH 44114

bull If submitting paper records please send medical records as follows For Therapy Reviews CGI Federal Inc Attn RACB Imaging 1001 Lakeside Avenue Suite 800 Cleveland OH 44114

76

How to survive RAC Audit

bull National health expenditures totaled $1679 Billion in 2003 bull National health expenditures were 153 of GROSS Domestic Product

(GDP) in 2003 bull Health care cost increasing at +9 per year bull Doomsday predictions of Medicare running out bull Congressional Action

77

RAC Audits

bull Medicare Modernization Act (MMA) of 2003Mandated a three year audit demonstration project 2005-2008

bull Appoint audit contractors to review Medicare billings for proper coding DRG assignment and medical necessity

bull Audits will apply to all health care providers (hospitals physicians homecare dme etc)

bull Audit contractors to be paid on a contingency basis a percentage of overpayments recovered

78

How Did we get here

bull Overpayments collected due to errors in Medically Unnecessary Services ndash 40

bull Incorrectly Coded ndash 35

bull Other ndash 17

bull NoInsufficient Documentation ndash 8

79

Where are we now

bull All RACrsquos completed required provider outreachAccess to Medicare billing data base given to all RAC RAC review methodology

bull Automated Review-Black amp White Issues (current) bull DRG Validation-complex review (current) bull Complex Review for coding errors (current) bull DME Medical Necessity Reviews ndashcomplex review (calendar year

2010) bull Medical Necessity Reviews-complex review (calendar year 2010)

80

RAC Reviews

bull Responsibilities of the Team Leader bull Must learn each insurance provider participating in a RAC or RAC type

program bull What are their operating rulesbull What is their appeal process Time limits

May be different process for each insurance provider bull Develop a response team

Identify who does what when why and alternate bull individual

Build and develop a manual process Review of computerized system

81

Priority Health SCIO Health Analytics

bull httpswwwsciohealthanalyticscomcore-capabilitiespayment-integrityfacility-auditsskilled-nursing-facility-audits

bull Claims for Medicare members treated at Skilled Nursing Facilities are reimbursed based on the patientsrsquo RUG (Resource Utilization Group) score which is determined using the Minimum Data Set (MDS) Using SCIOs robust analytics claims andor providers that merit review are selected for audit SCIOs auditors conduct a detailed review of the complete medical record and associated MDS to determine if the billed RUG score is valid In the event the review determines that an incorrect RUG score was billed SCIOreg provides the valid score reports the reason the change was necessary and calculates the resulting overpayment

82

+ Cheer

Onward and Upward she shall prevail We are here to care for the residents and provide a wonderful

service

13 83

84

References

bull Priority Healthbull Blue Crossbull Medicaidbull Medicare

85

  • Medicare Mange Care amp Medicaid Changes in the New World We Live In
  • Medicaid
  • NEW Medicaid Change MIlogin
  • Blueprint for Health Innovation MI
  • Provider Enrollment Electronic Signature Form Submission Process MSA 15-54
  • Provider Enrollment Electronic Signature Form Submission Process
  • Provider Enrollment Domain Administrator
  • Medicaid Coinsurance Medicare Advantage
  • Slide Number 9
  • Lawsuit DHS Changes on Caregivers
  • TPL Medicaid Change
  • CHAMPS Member Screen
  • LOC dropping off Not Due to MI Health
  • Issues
  • Secure Email Information
  • Medicaid amp Hospice
  • Medicaid
  • Medicaid Medicare Buy In
  • Manage Medicaid
  • Healthy Michigan Residents
  • Healthy Michigan Medicaid Days
  • McLaren Health Plan
  • Manage Medicaid Plans January 1
  • Slide Number 24
  • MI Health Link
  • MI Health Link 2565
  • What are the Names
  • MI Health Dual Eligible
  • MI Health LOC
  • LOC Medicaid
  • Medicaid Redetermination and MHL Enrollment
  • MI Health Link Portals
  • MI Health Authorizations
  • MI Health Issues
  • LOC 02 dropping MI Health Issues
  • PPA Offset
  • LOCD
  • MI Health Issues-New
  • ACO
  • Families Receiving Letters for ACO
  • ACO What is It
  • Payroll Based Journal
  • Slide Number 43
  • If you submit data manually should you also submit it through the XML
  • Staffing Submission Frequently Asked Questions
  • CMS defines
  • Slide Number 47
  • PBJ Medical Director Role
  • PBJ Medical Director Role
  • Dietician
  • Pharmacy Consultant
  • What are the names for the Medicare Number
  • QTSO
  • Medicare Update
  • CMS Final Rule On Returning Credits
  • Over Payment Rule
  • Questions to MAC
  • Questions to MAC
  • Final Rule on Returning Credits
  • Final Rule on Returning Credits
  • Final Rule on Returning Credits
  • Slide Number 62
  • Medicare Advantage Payors
  • Medicare Provider Enrollment Fee
  • Medicare MAC-Higlas
  • Two Midnight Rule
  • Two Midnight Rule
  • Two Midnight Rule
  • InPatient Vs Observation Conthellip
  • Two Midnight Rule
  • Health Data Insights amp Medicare Plus Blue
  • HDI Health Data amp Med Plus Blue
  • Health Data InSight
  • Pepper Reports
  • CGI Technologies and Solutions Inc httpracbcgicomContactInfoaspxst=1
  • CGI Federal RAC
  • How to survive RAC Audit
  • RAC Audits
  • How Did we get here
  • Where are we now
  • RAC Reviews
  • Priority Health SCIO Health Analytics
  • Cheer
  • References
Page 32: Medicare, Mange Care & Medicaid Changes in the New World we live in

MI Health Link Portals

bull Meridian Health Planbull httpwwwmhplancommibull Amerihealthbull httpwwwamerihealthcaritasvipcarepluscomproviderself-service-

toolsindexaspxbull AetnaCoventrybull httpwwwaetnabetterhealthcomMichiganprovidersportalbull Molinabull httpwwwmolinahealthcarecommembersmien-usmemPageshomeaspxbull HAPMidwestbull httpswwwmidwesthealthplancomLoginaspxbull FidelisCentenebull wwwfidelissccommmp 32

MI Health Authorizationsbull We need to watch these authorization that the plans are giving us for the MI

Health program Some plans are assigning a diagnosis for residents in their prior authorizations They are assigning diagnosis that the residents do not even have You need to make sure these are correct diagnosis and if not you need to work with the case managers of the plans to fix the issue The authorization numbers do change

bull Make sure that any resident that is in a MI Health plan that you have a prior authorization All plans are giving different periods authorizing the residents stay in the facility You need to set up a system to make sure you always have a authorization for the period of time you are rendering the service Here is an example of time frame of authorizations

bull Meridian is authorizing 12 monthsbull Aetna is authorizing 3 monthsbull Molina is authorizing 6 monthsbull The authorization numbers need to go on your claims to the payer You need to

put the authorizations in your software and track the dates

33

MI Health Issuesbull We are seeing some issues with MI Health where the resident does not have the correct LOC or it shows

up correct on CHAMPS but ancillary providers such as Dentist and such cannot see it I think we still have some issues with the information crossing between Bridges DHS system CMS and CHAMPS It in return is creating some access of care issues If it is a true LOC issues Facilities with LOC issues need to submit the Medicaid ID numbers to the MSA-MHL-EnrollmentMichigangov box with the subject line Nursing home LOC Issue so they may work to resolve the issues

bull If it becomes an access to care issue email the information to INTEGRATEDCAREmichigangov Remember in these emails only send the Medicaid ID and explain the situation The State will work with the plans to try to fix the process or improve the process

bull We are also seeing with new admission with LOC 015 or 005 that the plans are stating they have 14 days to authorize admission These are resident in the emergency room and possibly be admitted to you for Rehab The hospital will not keep the resident in ER for 14 days and you cannot admit the resident until you have a prior authorization I would recommend when you are told this by the plan that you need to ask to speak to a manager We will have to work through this

bull Ancillary Provider You need to work with your ancillary providers such as Lab Pharmacy X-Ray Physician and such to get the to be credentialed with the plans We are hearing that some of the pharmacies are not participating with the plans this will create issues for you so I would continue to ask these groups to participate

34

LOC 02 dropping MI Health Issuesbull The passive enrollments have occurred in Macomb amp Wayne for

Medicaid dual eligible We are having the same issue we did as in the Southwest MI amp UP with the passive enrollments I am starting to hear from facilities who are checking there CHAMPS member screens that those residents that have opted out (some residents not all) have lost there 02 Make sure you are checking your CHAMPS member screen both for those that were passively enrolled and those that might have lost there 02 Medicaid that opted out

bull Facilities with LOC issues need to submit the Medicaid ID numbers to the (Only MI Health)MSA-MHL-Enrollmentmichigangov box with the subject line Nursing home LOC Issue so they may work to resolve the issues

35

PPA Offset

bull There are no co-pays deductibles or premiums in MI Health Link so there should be no need to offset the PPA with code 25 MI Health Link enrollees can continue to offset their PPA for non-program covered medical expenses (like Vision-Code 27 Dental-Code 28 and Hearing-Code 26) and use the appropriate codes to offset the PPA when billing the health plan for nursing facility services

bull Resident pay PPA when MedicareMedicaid coinsurance

36

LOCDbull Nursing Facility Level of Care Determination (NFLOCD)

bull The MI Health Link health plan will be responsible for conducting the Michigan Medicaid NFLOCD tool for enrollees seeking admission to a nursing facility For existing residents at the time of enrollment the existing NFLOCD will be adopted for capitation payment purposes The health plan will complete a new NFLCOD tool within the first 90 days of enrollment If a nursing facility resident is disenrolled from MI Health Link the nursing facility will be responsible for conducting a new NFLOCD tool in accordance with published Medicaid policy

37

MI Health Issues-New

bull INTEGRATEDCAREmichigangov

bull Email with Insurance Plan issues Case Manager Issues

38

ACOWhat are they

39

Families Receiving Letters for ACO

40

ACO What is It

bull Whats an ACObull Accountable Care Organizations (ACOs) are groups of doctors hospitals

and other health care providers who come together voluntarily to give coordinated high quality care to their Medicare patients

bull The goal of coordinated care is to ensure that patients especially the chronically ill get the right care at the right time while avoiding

unnecessary duplication of services and preventing medical errorsbull When an ACO succeeds both in delivering high-quality care and

spending health care dollars more wisely it will share in the savings it achieves for the Medicare program

41

Payroll Based JournalMandatory on July 1 2016Internet Explorer Version

Internet Explorer v 10 and v 11 will need to operate in compatibility mode

42

43

If you submit data manually should you also submit it through the XML

bull Now you have three options

bull Submit Manually only

bull Submit through the XML only

bull You are able to submit manually and using the XML

44

45

Staffing Submission Frequently Asked Questions

bull ldquoWho are direct care staffrdquo (Who do we submit data for)bull Submission of data for contract staffbull Medical directors and consultantsbull Staff switching roles or tasks throughout the daybull Hours paid vs hours worked ndash Must be verifiablebull Public postingQuality MeasuresFive Starbull Enforcementbull Voluntary submission risks (noneSo register now)

CMS defines

bull 37 job title codes that are required to match employees to the number of hours each direct care function was performed It is important to work with your teams to define the workers that contribute to each job type and how those daily worked hours are recorded and converted to a PBJ submission

bull The PBJ does include some more specific job descriptions than the 671 For example the PBJ system includes job descriptions for RNs with administrative duties and LPNs with administrative duties versus the 671rsquos more general ldquoNurses with Administrative Duties

Page 46

47

PBJ Medical Director Rolebull Physician Leadership

bull Help the facility ensure that patients have appropriate physician coverage and ensure the provision of physician and health care practitioner services and

bull Help the facility develop a process for reviewing physician and health care practitioner credentials

bull Provide specific guidance for physician performance expectations

bull Help the facility ensure that a system is in place for monitoring the performance of health care practitioners and

bull Facilitate feedback to physicians and other health care practitioners on performance and practices

bull Patient Care - Clinical Leadership

bull Participate in administrative decision-making and the development of policies and procedures related to patient care

bull Help develop approve and implement specific clinical practices for the facility to incorporate into its care-related policies and procedures including areas required by laws and regulations

bull Develop procedures and guidance for facility staff regarding contacting practitioners including information gathering and presentation change in condition assessment and when to contact the medical director

bull Review consider andor act upon consultant recommendations as appropriate that affect the facilitys resident care policies and procedures or the care of an individual resident

bull Review respond to and participate in federal state local and other external surveys and inspections and

bull Help review policies and procedures regarding the adequate protection of patients rights advance care planning and other ethical issues48

PBJ Medical Director Rolebull Quality of Care

bull Help the facility establish systems and methods for reviewing the quality and appropriateness of clinical care and other health-related services and provide appropriate feedback and

bull Participate in the facilitys quality improvement process

bull Advise on infection control issues and approve specific infection control policies to be incorporated into facility policies and procedures

bull Help the facility provide a safe and caring environment

bull Help promote employee health and safety and

bull Assist in the development and implementation of employee health policies and programs

bull Education Information and Communication

bull Promote a learning culture within the facility by educating informing and communicating

bull Provide information to help the facility provide care consistent with current standards of practice (defined as approaches to care procedures techniques and treatments that are based on research and or expert consensus and that are contained in current manuals textbooks and or publications or that are accepted adopted or promulgated by recognized organizations or national bodies)

bull Help the facility develop medical information and communication systems with staff patients and families and others

bull Represent the facility to the professional and lay community on medical and patient care issues

bull Maintain knowledge of the changing social regulatory political and economic factors that affect medical and health services of long term care patients and

bull Help establish appropriate relationships with other health care organizations

49

Dietician

bull When the dietary or food services supervisor is other than a registered dietitian the supervisor shall receive routine consultation and technical assistance from a registered dietitian (RD) Consultation time shall not be less than 4 hours every 60 days Additional consultation time may be needed based on the total number of patients incidence of nutrition-related health problems and food service management needs of the facility

50

Pharmacy Consultant

bull At least once per month a licensed pharmacist must perform a drug regimen review (DRR) for each resident The pharmacist must report any irregularities to the attending physician or director of nursing Furthermore these reports must be acted upon

51

What are the names for the Medicare Numberbull OSCAR -Online Survey Certification and Reporting

bull PTAN-PTAN number is assigned by Medicare to authenticate the provider when using the local Medicare Administrative Contractorrsquos (MAC) self-help tools like the IVR internet portal on-line application status etc Provider Transactions Access Number

bull CCN- CMS Certification Number

bull Medicare Number- example 23-

bull All of the above mean the same thing

52

QTSO

bull Once you are logged in the QTSO site bull You will have a state login to the site to access the various site specific

to your facilitybull Installing you will need administrator rights to your network

53

Medicare UpdateWhat are we seeing

54

CMS Final Rule On Returning Credits

httpswwwfederalregistergovarticles201602122016-02789medicare-program-reporting-and-returning-of-overpayments

55

Over Payment Rule

bull Medicare payments for non covered services

bull Medicare payments in excess of the allowable amount for an identified covered service

bull Errors and non reimbursable expenditures in cost reportsbull Duplicate payment

bull Receipt of Medicare payments when another payor had the primary responsibility for payment

56

Questions to MAC

bull Does the Medicare credit balance report change with this overpayment rule

bull No Medicare Credit Balances are still required at the end of each quarter

bull Will that still be the communication to let CMS or the MAC know that we have received an overpayment

bull Submission of Medicare Credit Balance is one form of communicating overpayments to CMS Other methods include submitting a voluntary refund with required claim information or the submission of a standard overpayment form

57

Questions to MAC

bull Will the MAC still deduct from a future RAbull If the recovery of the overpayment includes adjusting a claim then

the overpayment would be netted against future claims payments and reflected on the RA

bull Or will that process change with this new rulebull Process will remain the samebull Will NGS send communication out on thisbull Yes NGS will communicate this once the final rule is communicated

to the MACs by CMS However this could change depending on final CMS instructions

58

Final Rule on Returning Credits

bull Providers will want to immediately update their current policies governing overpayments in order to comply with this new rule which will take effect on March 14 2016

bull Providers and suppliers are required to use reasonable diligence to investigate credible information regarding overpayments through both proactive compliance efforts and reactive investigations

bull If an overpayment is identified then it must be repaid within 60 days An overpayment is identified when a person has or should have through the exercise of reasonable diligence determined that the person received an overpayment and quantified the amount

bull Providers and suppliers have a maximum of 8 months to report and return overpayments ndash up to 6 months to investigate and quantify the overpayment (ie to identify it) and up to 60 days to report and return the overpayment

59

Final Rule on Returning Credits

bull Providers and suppliers are required to report and return all overpayments within a 6-year lookback period

bull The cause and amount of the overpayment is irrelevant for the determination eg it was due to a mistake it was someone elsersquos fault it is a minor amount An overpayment is an overpayment and must be returned

bull Providers and suppliers must make their own determination to which entity to report and return the overpayment ie to the Medicare contractor or using the OIG Self Disclosure Protocol or the CMS Self Referral Disclosure Protocol

60

Final Rule on Returning Credits

bull Providers and suppliers may use the claims adjustment credit balance self-reported refund process or another appropriate process to report and return overpayments At this time there is no standard refund form to use

bull Failure to report and return an overpayment could subject the provider or supplier to False Claims Act liability Civil Monetary Penalties Law liability and exclusion from federal health care programs

61

P S amp R-Accountants will be asking for this information

The location you login into has changed it is now on EIDM EIDM is the acronym for CMS Enterprise Identity Management system which includes Identity Verification Access Management Authorization Assistance Workflow Tools and Identity Lifecycle Management functions

httpswwwcmsgovResearch-Statistics-Data-and-SystemsCMS-Information-TechnologyIACSCMS-Applications-Loginhtml

Go down the page and click on the PSampRSTARThis will take you to the login pagewill look the same as the old P S amp R didChanges Affecting PSampR System Access (Please Read) (posted 01292015)(Updated 5262015)is changingThe system which controls your PSampR user ID (currently IACS)The new system is referred to as EIDMThis will result in a different way to create new accounts or change passwords to existing accountsIf you already have an account in EIDM you may have to use that account for accessing PSampR after the transitionWhen is the change effectiveJune 13 2015What is staying the sameThe internet address for accessing PSampR remains the sameThe PSampR systemfunctionality is NOT changing 62

Medicare Advantage Payorsbull Medicare Advantage payors are pullingdenying payments on admissions if the patient was readmitted within 30 days after discharge The

client believes that the payors systematically denying payments for all readmissions within 30 days They believe this practice denies them due process to address whether the readmissions were justified and not due to a premature discharge of patient The payors seem to want to act like a QIO without having the same accountabilities of the QIO related to determinations of non-payment

bull Heres the QIO process under section 4240 of the QIO Manualbull 4240 - Readmission Review - (Rev 2 07-11-03)bull Readmission review involves admissions to an acute general short-term hospital occurring less than 31 calendar days from the date of

discharge from the same or another acute general short-term hospital (see sect1154(a)(13) and 42 CFR 47671(a)(8)(ii)) Neither the day of discharge nor the day of admission is counted when determining whether a readmission has occurred

bull A Medical Review Proceduresbull Obtain the appropriate medical records for the initial admission and readmission Perform case review on both stays Analyze the cases

specifically to determine whether the patient was prematurely discharged from the first confinement thus causing readmission Perform an analysis of the stay at the first hospital to determine the cause(s) and extent of any problem(s) (eg incomplete or substandard treatment) Consider the information available to the attending physician who discharged the patient from the first confinement Do not base a determination of a premature discharge on information that the physician or provider could not have known or events that could not have been anticipated at the time of discharge

bull Review both the initial admission and the readmission at the same time unless one of them has previously been reviewed In these cases use at a minimum the PRAF case summary of the other admission in addition to the medical record of the case under review

bull C Denialsbull Deny readmissions under the following circumstancesbull If the readmission was medically unnecessarybull If the readmission resulted from a premature discharge from the same hospital orbull If the readmission was a result of circumvention of PPS by the same hospital (see sect4255)bull With the QIO process there is an appeal within the QIO here the hospital is getting no opportunity to challenge the denials

63

Medicare Provider Enrollment Feebull Provider Enrollment Application Fee Amount for CY 2016bull On December 3 CMS issued a notice Provider Enrollment Application

Fee Amount for CY 2016 [CMSndash6066ndashN] Effective January 1 2016 the CY 2016 application fee is $554 for institutional providers that are

bull Initially enrolling in the Medicare or Medicaid program or the Childrens Health Insurance Program (CHIP)

bull Revalidating their Medicare Medicaid or CHIP enrollmentbull Adding a new Medicare practice locationbull This fee is required with any enrollment application submitted from

January 1 through December 31 2016

64

Medicare MAC-Higlas

bull Effective 142016 CMS has implemented a change to begin netting (offsetting) provider money across workloads within a single organization What this means is that any related providers conducting business in two different workloads (example New York and Maine) will have their money applied to any account receivables (AR) with a remaining balance owed to Medicare within both workloads For example Provider ABC is located in New York and is scheduled to receive a payment of $1000 on todays remittance advice Provider XYZ is related to provider ABC but is located in Maine and has ARs with a balance owed of $200 Provider ABCs $1000 payment will have the $200 applied against provider XYZs ARs resulting in a net payment of $800 This will be reflected on the remittance advice by the same PLB code as seen today for offsets for the $200

65

Two Midnight RuleChange January 1 2016 httpswwwcmsgovMedicareMedicare-Fee-for-Service-PaymentHospitalOutpatientPPSHospital-Outpatient-Regulations-and-Notices-ItemsCMS-1633-FChtml

66

Two Midnight Rulebull However effective January 1 2016 CMS will allow exceptions to the

Two-Midnight Benchmark to be determined on a case-by-case basis by the physician responsible for the care of the beneficiary subject to medical review Said differently Part A payment may be appropriate in some circumstances even though there is no expectation by the physician (or qualified ordering practitioner) of a two-midnight stay and one of the two pre-existing categorical exceptions (CMS ldquoinpatient onlyrdquo list and newly initiated mechanical ventilation) does not apply CMS has indicated that this change to the Two Midnight Rule is in response to stakeholder concern and CMSrsquos continued efforts to develop the most appropriate standard for determining Medicare Part A payment

67

Two Midnight Rulebull A new 42 CFR sect4123(a) provides that a patient is considered an

inpatient of a hospitalhellipif formally admitted as an inpatient pursuant to an order for inpatient admission by a physician or other qualified practitionerhellip The physician orders inpatient status when he or she expects the patient to require a stay that crosses at least 2 midnights[10] Stays expected to be shorter than at least two midnights are generally inappropriate for inpatient admission and inpatient payment under Medicare Part A unless the surgical procedure is specified by Medicare as inpatient only under sect41922(n)[11] The physicians expectationhellipshould be based on such complex medical factors as patient history and comorbidities the severity of signs and symptoms current medical needs and the risk of an adverse event[12] The physician order is part of physician certification of the medical necessity of hospital inpatient serviceshellip[13]

68

InPatient Vs Observation Conthellip

bull Physician certification which begins with an order for inpatient admission requires the physician to certify the reasons for the hospitalization the estimated time the patient will remain in the hospital and plans for post-hospital care if appropriate[14] The certification must be completed signed and documented in the medical record prior to discharge[15]

bull A physicians admission order has no presumptive weight and both the admission order and the physician certification will be evaluated in the context of the evidence in the medical record[16] CMS intends to provide additional information about what evidence in the medical record means in future instructions and manual revisions[17]

69

Two Midnight Rulebull Although the new case-by-case exception appears to be inherently

subjective to a certain extent CMS states that the following factors (among others) would be relevant to determining whether a patient requires inpatient admission under the expanded policy

bull The severity of the signs and symptoms exhibited by the patient bull The medical predictability of something adverse happening to the patient

and bull The need for diagnostic studies that appropriately are outpatient services

(that is their performance does not ordinarily require the patient to remain at the hospital for 24 hours or more)

bull CMS also notes that an inpatient admission (and Part A payment) should be ldquorare and unusualrdquo for minor surgical procedures or other treatment that is expected to keep the patient in the hospital ldquofor only a few hoursrdquo or for a period of time that ldquodoes not span at least overnightrdquo (thus a subset of stays not meeting the Two Midnight Benchmark) CMS indicates that such cases will be prioritized for medical review

70

Health Data Insights amp Medicare Plus Blue

RAC (Retrospective Audits)

71

HDI Health Data amp Med Plus Blue

bull httpwwwhealthdatainsightscombull Blue Cross Medicare Advantage Auditsbull Facilities seeing 10 to 15 requests for Medical Recordsbull In January amp Feburarybull Selected Health Data Insights because they were a premier Audit

Vendor for CMS Recovery Audit Contractor (RAC) demonstration Project They are a audit vendor for Humana

bull Providers not sending Medical Record will get technical denial and lose payments

72

Health Data InSight

bull In 2010 they began the Hospital Reviewbull Medicare Advantage encounter datandashCMS oversight of data integrity OIG

2016bull We will review CMSs oversight of MA encounter data validation and assess

the extent to which CMSrsquos Integrated Data Repository contains timely valid and complete MA encounter data In 2012 CMS began collecting from MA organizations a more comprehensive set of encounter data reflecting the items and services provided to MA plan enrollees Prior CMS and OIG audits have indicated vulnerabilities in the accuracy of data reporting by MA organizations Realizing the potential benefits of the MA encounter data for payment and program integrity oversight is contingent upon the datarsquos completeness validity and timeliness (OEI 03-15-00060 expected issue date FY 2017)

73

Pepper Reports

bull httpswwwpepperresourcesorg

bull Program for Evaluating Payment Patterns Electronic Report ( PEPPER)

bull Annually on or about April 18 2016 will be released

bull Pepper Portal httpssecurefiletmforg

74

CGI Technologies and Solutions Inc httpracbcgicomContactInfoaspxst=1

bull Indiana bull Michiganbull Minnesotabull Illinoisbull Kentuckybull Ohiobull Wisconsin CGI Technologies and Solutions Incbull For general and administrative questions regarding client service outreach

quality assurance or project-specific issues contactbull 1877316RACB (7222)bull Email racbcgicom Tamara Tate Tamaratatecmshhsgovbull 4107861288

75

CGI Federal RAC

bull CGI Federal RAC Region Bbull Email racbcgicombull Phone 1-877-316-RACB (7222)bull Mailing Addressbull Send medical records as followsbull Medical records for Indiana Illinois Kentucky Michigan Ohio Wisconsin

Minnesota DME and Home Health CGI Federal Inc Attn RACB Imaging Dept 1001 Lakeside Ave Suite 800 Cleveland OH 44114

bull If submitting paper records please send medical records as follows For Therapy Reviews CGI Federal Inc Attn RACB Imaging 1001 Lakeside Avenue Suite 800 Cleveland OH 44114

76

How to survive RAC Audit

bull National health expenditures totaled $1679 Billion in 2003 bull National health expenditures were 153 of GROSS Domestic Product

(GDP) in 2003 bull Health care cost increasing at +9 per year bull Doomsday predictions of Medicare running out bull Congressional Action

77

RAC Audits

bull Medicare Modernization Act (MMA) of 2003Mandated a three year audit demonstration project 2005-2008

bull Appoint audit contractors to review Medicare billings for proper coding DRG assignment and medical necessity

bull Audits will apply to all health care providers (hospitals physicians homecare dme etc)

bull Audit contractors to be paid on a contingency basis a percentage of overpayments recovered

78

How Did we get here

bull Overpayments collected due to errors in Medically Unnecessary Services ndash 40

bull Incorrectly Coded ndash 35

bull Other ndash 17

bull NoInsufficient Documentation ndash 8

79

Where are we now

bull All RACrsquos completed required provider outreachAccess to Medicare billing data base given to all RAC RAC review methodology

bull Automated Review-Black amp White Issues (current) bull DRG Validation-complex review (current) bull Complex Review for coding errors (current) bull DME Medical Necessity Reviews ndashcomplex review (calendar year

2010) bull Medical Necessity Reviews-complex review (calendar year 2010)

80

RAC Reviews

bull Responsibilities of the Team Leader bull Must learn each insurance provider participating in a RAC or RAC type

program bull What are their operating rulesbull What is their appeal process Time limits

May be different process for each insurance provider bull Develop a response team

Identify who does what when why and alternate bull individual

Build and develop a manual process Review of computerized system

81

Priority Health SCIO Health Analytics

bull httpswwwsciohealthanalyticscomcore-capabilitiespayment-integrityfacility-auditsskilled-nursing-facility-audits

bull Claims for Medicare members treated at Skilled Nursing Facilities are reimbursed based on the patientsrsquo RUG (Resource Utilization Group) score which is determined using the Minimum Data Set (MDS) Using SCIOs robust analytics claims andor providers that merit review are selected for audit SCIOs auditors conduct a detailed review of the complete medical record and associated MDS to determine if the billed RUG score is valid In the event the review determines that an incorrect RUG score was billed SCIOreg provides the valid score reports the reason the change was necessary and calculates the resulting overpayment

82

+ Cheer

Onward and Upward she shall prevail We are here to care for the residents and provide a wonderful

service

13 83

84

References

bull Priority Healthbull Blue Crossbull Medicaidbull Medicare

85

  • Medicare Mange Care amp Medicaid Changes in the New World We Live In
  • Medicaid
  • NEW Medicaid Change MIlogin
  • Blueprint for Health Innovation MI
  • Provider Enrollment Electronic Signature Form Submission Process MSA 15-54
  • Provider Enrollment Electronic Signature Form Submission Process
  • Provider Enrollment Domain Administrator
  • Medicaid Coinsurance Medicare Advantage
  • Slide Number 9
  • Lawsuit DHS Changes on Caregivers
  • TPL Medicaid Change
  • CHAMPS Member Screen
  • LOC dropping off Not Due to MI Health
  • Issues
  • Secure Email Information
  • Medicaid amp Hospice
  • Medicaid
  • Medicaid Medicare Buy In
  • Manage Medicaid
  • Healthy Michigan Residents
  • Healthy Michigan Medicaid Days
  • McLaren Health Plan
  • Manage Medicaid Plans January 1
  • Slide Number 24
  • MI Health Link
  • MI Health Link 2565
  • What are the Names
  • MI Health Dual Eligible
  • MI Health LOC
  • LOC Medicaid
  • Medicaid Redetermination and MHL Enrollment
  • MI Health Link Portals
  • MI Health Authorizations
  • MI Health Issues
  • LOC 02 dropping MI Health Issues
  • PPA Offset
  • LOCD
  • MI Health Issues-New
  • ACO
  • Families Receiving Letters for ACO
  • ACO What is It
  • Payroll Based Journal
  • Slide Number 43
  • If you submit data manually should you also submit it through the XML
  • Staffing Submission Frequently Asked Questions
  • CMS defines
  • Slide Number 47
  • PBJ Medical Director Role
  • PBJ Medical Director Role
  • Dietician
  • Pharmacy Consultant
  • What are the names for the Medicare Number
  • QTSO
  • Medicare Update
  • CMS Final Rule On Returning Credits
  • Over Payment Rule
  • Questions to MAC
  • Questions to MAC
  • Final Rule on Returning Credits
  • Final Rule on Returning Credits
  • Final Rule on Returning Credits
  • Slide Number 62
  • Medicare Advantage Payors
  • Medicare Provider Enrollment Fee
  • Medicare MAC-Higlas
  • Two Midnight Rule
  • Two Midnight Rule
  • Two Midnight Rule
  • InPatient Vs Observation Conthellip
  • Two Midnight Rule
  • Health Data Insights amp Medicare Plus Blue
  • HDI Health Data amp Med Plus Blue
  • Health Data InSight
  • Pepper Reports
  • CGI Technologies and Solutions Inc httpracbcgicomContactInfoaspxst=1
  • CGI Federal RAC
  • How to survive RAC Audit
  • RAC Audits
  • How Did we get here
  • Where are we now
  • RAC Reviews
  • Priority Health SCIO Health Analytics
  • Cheer
  • References
Page 33: Medicare, Mange Care & Medicaid Changes in the New World we live in

MI Health Authorizationsbull We need to watch these authorization that the plans are giving us for the MI

Health program Some plans are assigning a diagnosis for residents in their prior authorizations They are assigning diagnosis that the residents do not even have You need to make sure these are correct diagnosis and if not you need to work with the case managers of the plans to fix the issue The authorization numbers do change

bull Make sure that any resident that is in a MI Health plan that you have a prior authorization All plans are giving different periods authorizing the residents stay in the facility You need to set up a system to make sure you always have a authorization for the period of time you are rendering the service Here is an example of time frame of authorizations

bull Meridian is authorizing 12 monthsbull Aetna is authorizing 3 monthsbull Molina is authorizing 6 monthsbull The authorization numbers need to go on your claims to the payer You need to

put the authorizations in your software and track the dates

33

MI Health Issuesbull We are seeing some issues with MI Health where the resident does not have the correct LOC or it shows

up correct on CHAMPS but ancillary providers such as Dentist and such cannot see it I think we still have some issues with the information crossing between Bridges DHS system CMS and CHAMPS It in return is creating some access of care issues If it is a true LOC issues Facilities with LOC issues need to submit the Medicaid ID numbers to the MSA-MHL-EnrollmentMichigangov box with the subject line Nursing home LOC Issue so they may work to resolve the issues

bull If it becomes an access to care issue email the information to INTEGRATEDCAREmichigangov Remember in these emails only send the Medicaid ID and explain the situation The State will work with the plans to try to fix the process or improve the process

bull We are also seeing with new admission with LOC 015 or 005 that the plans are stating they have 14 days to authorize admission These are resident in the emergency room and possibly be admitted to you for Rehab The hospital will not keep the resident in ER for 14 days and you cannot admit the resident until you have a prior authorization I would recommend when you are told this by the plan that you need to ask to speak to a manager We will have to work through this

bull Ancillary Provider You need to work with your ancillary providers such as Lab Pharmacy X-Ray Physician and such to get the to be credentialed with the plans We are hearing that some of the pharmacies are not participating with the plans this will create issues for you so I would continue to ask these groups to participate

34

LOC 02 dropping MI Health Issuesbull The passive enrollments have occurred in Macomb amp Wayne for

Medicaid dual eligible We are having the same issue we did as in the Southwest MI amp UP with the passive enrollments I am starting to hear from facilities who are checking there CHAMPS member screens that those residents that have opted out (some residents not all) have lost there 02 Make sure you are checking your CHAMPS member screen both for those that were passively enrolled and those that might have lost there 02 Medicaid that opted out

bull Facilities with LOC issues need to submit the Medicaid ID numbers to the (Only MI Health)MSA-MHL-Enrollmentmichigangov box with the subject line Nursing home LOC Issue so they may work to resolve the issues

35

PPA Offset

bull There are no co-pays deductibles or premiums in MI Health Link so there should be no need to offset the PPA with code 25 MI Health Link enrollees can continue to offset their PPA for non-program covered medical expenses (like Vision-Code 27 Dental-Code 28 and Hearing-Code 26) and use the appropriate codes to offset the PPA when billing the health plan for nursing facility services

bull Resident pay PPA when MedicareMedicaid coinsurance

36

LOCDbull Nursing Facility Level of Care Determination (NFLOCD)

bull The MI Health Link health plan will be responsible for conducting the Michigan Medicaid NFLOCD tool for enrollees seeking admission to a nursing facility For existing residents at the time of enrollment the existing NFLOCD will be adopted for capitation payment purposes The health plan will complete a new NFLCOD tool within the first 90 days of enrollment If a nursing facility resident is disenrolled from MI Health Link the nursing facility will be responsible for conducting a new NFLOCD tool in accordance with published Medicaid policy

37

MI Health Issues-New

bull INTEGRATEDCAREmichigangov

bull Email with Insurance Plan issues Case Manager Issues

38

ACOWhat are they

39

Families Receiving Letters for ACO

40

ACO What is It

bull Whats an ACObull Accountable Care Organizations (ACOs) are groups of doctors hospitals

and other health care providers who come together voluntarily to give coordinated high quality care to their Medicare patients

bull The goal of coordinated care is to ensure that patients especially the chronically ill get the right care at the right time while avoiding

unnecessary duplication of services and preventing medical errorsbull When an ACO succeeds both in delivering high-quality care and

spending health care dollars more wisely it will share in the savings it achieves for the Medicare program

41

Payroll Based JournalMandatory on July 1 2016Internet Explorer Version

Internet Explorer v 10 and v 11 will need to operate in compatibility mode

42

43

If you submit data manually should you also submit it through the XML

bull Now you have three options

bull Submit Manually only

bull Submit through the XML only

bull You are able to submit manually and using the XML

44

45

Staffing Submission Frequently Asked Questions

bull ldquoWho are direct care staffrdquo (Who do we submit data for)bull Submission of data for contract staffbull Medical directors and consultantsbull Staff switching roles or tasks throughout the daybull Hours paid vs hours worked ndash Must be verifiablebull Public postingQuality MeasuresFive Starbull Enforcementbull Voluntary submission risks (noneSo register now)

CMS defines

bull 37 job title codes that are required to match employees to the number of hours each direct care function was performed It is important to work with your teams to define the workers that contribute to each job type and how those daily worked hours are recorded and converted to a PBJ submission

bull The PBJ does include some more specific job descriptions than the 671 For example the PBJ system includes job descriptions for RNs with administrative duties and LPNs with administrative duties versus the 671rsquos more general ldquoNurses with Administrative Duties

Page 46

47

PBJ Medical Director Rolebull Physician Leadership

bull Help the facility ensure that patients have appropriate physician coverage and ensure the provision of physician and health care practitioner services and

bull Help the facility develop a process for reviewing physician and health care practitioner credentials

bull Provide specific guidance for physician performance expectations

bull Help the facility ensure that a system is in place for monitoring the performance of health care practitioners and

bull Facilitate feedback to physicians and other health care practitioners on performance and practices

bull Patient Care - Clinical Leadership

bull Participate in administrative decision-making and the development of policies and procedures related to patient care

bull Help develop approve and implement specific clinical practices for the facility to incorporate into its care-related policies and procedures including areas required by laws and regulations

bull Develop procedures and guidance for facility staff regarding contacting practitioners including information gathering and presentation change in condition assessment and when to contact the medical director

bull Review consider andor act upon consultant recommendations as appropriate that affect the facilitys resident care policies and procedures or the care of an individual resident

bull Review respond to and participate in federal state local and other external surveys and inspections and

bull Help review policies and procedures regarding the adequate protection of patients rights advance care planning and other ethical issues48

PBJ Medical Director Rolebull Quality of Care

bull Help the facility establish systems and methods for reviewing the quality and appropriateness of clinical care and other health-related services and provide appropriate feedback and

bull Participate in the facilitys quality improvement process

bull Advise on infection control issues and approve specific infection control policies to be incorporated into facility policies and procedures

bull Help the facility provide a safe and caring environment

bull Help promote employee health and safety and

bull Assist in the development and implementation of employee health policies and programs

bull Education Information and Communication

bull Promote a learning culture within the facility by educating informing and communicating

bull Provide information to help the facility provide care consistent with current standards of practice (defined as approaches to care procedures techniques and treatments that are based on research and or expert consensus and that are contained in current manuals textbooks and or publications or that are accepted adopted or promulgated by recognized organizations or national bodies)

bull Help the facility develop medical information and communication systems with staff patients and families and others

bull Represent the facility to the professional and lay community on medical and patient care issues

bull Maintain knowledge of the changing social regulatory political and economic factors that affect medical and health services of long term care patients and

bull Help establish appropriate relationships with other health care organizations

49

Dietician

bull When the dietary or food services supervisor is other than a registered dietitian the supervisor shall receive routine consultation and technical assistance from a registered dietitian (RD) Consultation time shall not be less than 4 hours every 60 days Additional consultation time may be needed based on the total number of patients incidence of nutrition-related health problems and food service management needs of the facility

50

Pharmacy Consultant

bull At least once per month a licensed pharmacist must perform a drug regimen review (DRR) for each resident The pharmacist must report any irregularities to the attending physician or director of nursing Furthermore these reports must be acted upon

51

What are the names for the Medicare Numberbull OSCAR -Online Survey Certification and Reporting

bull PTAN-PTAN number is assigned by Medicare to authenticate the provider when using the local Medicare Administrative Contractorrsquos (MAC) self-help tools like the IVR internet portal on-line application status etc Provider Transactions Access Number

bull CCN- CMS Certification Number

bull Medicare Number- example 23-

bull All of the above mean the same thing

52

QTSO

bull Once you are logged in the QTSO site bull You will have a state login to the site to access the various site specific

to your facilitybull Installing you will need administrator rights to your network

53

Medicare UpdateWhat are we seeing

54

CMS Final Rule On Returning Credits

httpswwwfederalregistergovarticles201602122016-02789medicare-program-reporting-and-returning-of-overpayments

55

Over Payment Rule

bull Medicare payments for non covered services

bull Medicare payments in excess of the allowable amount for an identified covered service

bull Errors and non reimbursable expenditures in cost reportsbull Duplicate payment

bull Receipt of Medicare payments when another payor had the primary responsibility for payment

56

Questions to MAC

bull Does the Medicare credit balance report change with this overpayment rule

bull No Medicare Credit Balances are still required at the end of each quarter

bull Will that still be the communication to let CMS or the MAC know that we have received an overpayment

bull Submission of Medicare Credit Balance is one form of communicating overpayments to CMS Other methods include submitting a voluntary refund with required claim information or the submission of a standard overpayment form

57

Questions to MAC

bull Will the MAC still deduct from a future RAbull If the recovery of the overpayment includes adjusting a claim then

the overpayment would be netted against future claims payments and reflected on the RA

bull Or will that process change with this new rulebull Process will remain the samebull Will NGS send communication out on thisbull Yes NGS will communicate this once the final rule is communicated

to the MACs by CMS However this could change depending on final CMS instructions

58

Final Rule on Returning Credits

bull Providers will want to immediately update their current policies governing overpayments in order to comply with this new rule which will take effect on March 14 2016

bull Providers and suppliers are required to use reasonable diligence to investigate credible information regarding overpayments through both proactive compliance efforts and reactive investigations

bull If an overpayment is identified then it must be repaid within 60 days An overpayment is identified when a person has or should have through the exercise of reasonable diligence determined that the person received an overpayment and quantified the amount

bull Providers and suppliers have a maximum of 8 months to report and return overpayments ndash up to 6 months to investigate and quantify the overpayment (ie to identify it) and up to 60 days to report and return the overpayment

59

Final Rule on Returning Credits

bull Providers and suppliers are required to report and return all overpayments within a 6-year lookback period

bull The cause and amount of the overpayment is irrelevant for the determination eg it was due to a mistake it was someone elsersquos fault it is a minor amount An overpayment is an overpayment and must be returned

bull Providers and suppliers must make their own determination to which entity to report and return the overpayment ie to the Medicare contractor or using the OIG Self Disclosure Protocol or the CMS Self Referral Disclosure Protocol

60

Final Rule on Returning Credits

bull Providers and suppliers may use the claims adjustment credit balance self-reported refund process or another appropriate process to report and return overpayments At this time there is no standard refund form to use

bull Failure to report and return an overpayment could subject the provider or supplier to False Claims Act liability Civil Monetary Penalties Law liability and exclusion from federal health care programs

61

P S amp R-Accountants will be asking for this information

The location you login into has changed it is now on EIDM EIDM is the acronym for CMS Enterprise Identity Management system which includes Identity Verification Access Management Authorization Assistance Workflow Tools and Identity Lifecycle Management functions

httpswwwcmsgovResearch-Statistics-Data-and-SystemsCMS-Information-TechnologyIACSCMS-Applications-Loginhtml

Go down the page and click on the PSampRSTARThis will take you to the login pagewill look the same as the old P S amp R didChanges Affecting PSampR System Access (Please Read) (posted 01292015)(Updated 5262015)is changingThe system which controls your PSampR user ID (currently IACS)The new system is referred to as EIDMThis will result in a different way to create new accounts or change passwords to existing accountsIf you already have an account in EIDM you may have to use that account for accessing PSampR after the transitionWhen is the change effectiveJune 13 2015What is staying the sameThe internet address for accessing PSampR remains the sameThe PSampR systemfunctionality is NOT changing 62

Medicare Advantage Payorsbull Medicare Advantage payors are pullingdenying payments on admissions if the patient was readmitted within 30 days after discharge The

client believes that the payors systematically denying payments for all readmissions within 30 days They believe this practice denies them due process to address whether the readmissions were justified and not due to a premature discharge of patient The payors seem to want to act like a QIO without having the same accountabilities of the QIO related to determinations of non-payment

bull Heres the QIO process under section 4240 of the QIO Manualbull 4240 - Readmission Review - (Rev 2 07-11-03)bull Readmission review involves admissions to an acute general short-term hospital occurring less than 31 calendar days from the date of

discharge from the same or another acute general short-term hospital (see sect1154(a)(13) and 42 CFR 47671(a)(8)(ii)) Neither the day of discharge nor the day of admission is counted when determining whether a readmission has occurred

bull A Medical Review Proceduresbull Obtain the appropriate medical records for the initial admission and readmission Perform case review on both stays Analyze the cases

specifically to determine whether the patient was prematurely discharged from the first confinement thus causing readmission Perform an analysis of the stay at the first hospital to determine the cause(s) and extent of any problem(s) (eg incomplete or substandard treatment) Consider the information available to the attending physician who discharged the patient from the first confinement Do not base a determination of a premature discharge on information that the physician or provider could not have known or events that could not have been anticipated at the time of discharge

bull Review both the initial admission and the readmission at the same time unless one of them has previously been reviewed In these cases use at a minimum the PRAF case summary of the other admission in addition to the medical record of the case under review

bull C Denialsbull Deny readmissions under the following circumstancesbull If the readmission was medically unnecessarybull If the readmission resulted from a premature discharge from the same hospital orbull If the readmission was a result of circumvention of PPS by the same hospital (see sect4255)bull With the QIO process there is an appeal within the QIO here the hospital is getting no opportunity to challenge the denials

63

Medicare Provider Enrollment Feebull Provider Enrollment Application Fee Amount for CY 2016bull On December 3 CMS issued a notice Provider Enrollment Application

Fee Amount for CY 2016 [CMSndash6066ndashN] Effective January 1 2016 the CY 2016 application fee is $554 for institutional providers that are

bull Initially enrolling in the Medicare or Medicaid program or the Childrens Health Insurance Program (CHIP)

bull Revalidating their Medicare Medicaid or CHIP enrollmentbull Adding a new Medicare practice locationbull This fee is required with any enrollment application submitted from

January 1 through December 31 2016

64

Medicare MAC-Higlas

bull Effective 142016 CMS has implemented a change to begin netting (offsetting) provider money across workloads within a single organization What this means is that any related providers conducting business in two different workloads (example New York and Maine) will have their money applied to any account receivables (AR) with a remaining balance owed to Medicare within both workloads For example Provider ABC is located in New York and is scheduled to receive a payment of $1000 on todays remittance advice Provider XYZ is related to provider ABC but is located in Maine and has ARs with a balance owed of $200 Provider ABCs $1000 payment will have the $200 applied against provider XYZs ARs resulting in a net payment of $800 This will be reflected on the remittance advice by the same PLB code as seen today for offsets for the $200

65

Two Midnight RuleChange January 1 2016 httpswwwcmsgovMedicareMedicare-Fee-for-Service-PaymentHospitalOutpatientPPSHospital-Outpatient-Regulations-and-Notices-ItemsCMS-1633-FChtml

66

Two Midnight Rulebull However effective January 1 2016 CMS will allow exceptions to the

Two-Midnight Benchmark to be determined on a case-by-case basis by the physician responsible for the care of the beneficiary subject to medical review Said differently Part A payment may be appropriate in some circumstances even though there is no expectation by the physician (or qualified ordering practitioner) of a two-midnight stay and one of the two pre-existing categorical exceptions (CMS ldquoinpatient onlyrdquo list and newly initiated mechanical ventilation) does not apply CMS has indicated that this change to the Two Midnight Rule is in response to stakeholder concern and CMSrsquos continued efforts to develop the most appropriate standard for determining Medicare Part A payment

67

Two Midnight Rulebull A new 42 CFR sect4123(a) provides that a patient is considered an

inpatient of a hospitalhellipif formally admitted as an inpatient pursuant to an order for inpatient admission by a physician or other qualified practitionerhellip The physician orders inpatient status when he or she expects the patient to require a stay that crosses at least 2 midnights[10] Stays expected to be shorter than at least two midnights are generally inappropriate for inpatient admission and inpatient payment under Medicare Part A unless the surgical procedure is specified by Medicare as inpatient only under sect41922(n)[11] The physicians expectationhellipshould be based on such complex medical factors as patient history and comorbidities the severity of signs and symptoms current medical needs and the risk of an adverse event[12] The physician order is part of physician certification of the medical necessity of hospital inpatient serviceshellip[13]

68

InPatient Vs Observation Conthellip

bull Physician certification which begins with an order for inpatient admission requires the physician to certify the reasons for the hospitalization the estimated time the patient will remain in the hospital and plans for post-hospital care if appropriate[14] The certification must be completed signed and documented in the medical record prior to discharge[15]

bull A physicians admission order has no presumptive weight and both the admission order and the physician certification will be evaluated in the context of the evidence in the medical record[16] CMS intends to provide additional information about what evidence in the medical record means in future instructions and manual revisions[17]

69

Two Midnight Rulebull Although the new case-by-case exception appears to be inherently

subjective to a certain extent CMS states that the following factors (among others) would be relevant to determining whether a patient requires inpatient admission under the expanded policy

bull The severity of the signs and symptoms exhibited by the patient bull The medical predictability of something adverse happening to the patient

and bull The need for diagnostic studies that appropriately are outpatient services

(that is their performance does not ordinarily require the patient to remain at the hospital for 24 hours or more)

bull CMS also notes that an inpatient admission (and Part A payment) should be ldquorare and unusualrdquo for minor surgical procedures or other treatment that is expected to keep the patient in the hospital ldquofor only a few hoursrdquo or for a period of time that ldquodoes not span at least overnightrdquo (thus a subset of stays not meeting the Two Midnight Benchmark) CMS indicates that such cases will be prioritized for medical review

70

Health Data Insights amp Medicare Plus Blue

RAC (Retrospective Audits)

71

HDI Health Data amp Med Plus Blue

bull httpwwwhealthdatainsightscombull Blue Cross Medicare Advantage Auditsbull Facilities seeing 10 to 15 requests for Medical Recordsbull In January amp Feburarybull Selected Health Data Insights because they were a premier Audit

Vendor for CMS Recovery Audit Contractor (RAC) demonstration Project They are a audit vendor for Humana

bull Providers not sending Medical Record will get technical denial and lose payments

72

Health Data InSight

bull In 2010 they began the Hospital Reviewbull Medicare Advantage encounter datandashCMS oversight of data integrity OIG

2016bull We will review CMSs oversight of MA encounter data validation and assess

the extent to which CMSrsquos Integrated Data Repository contains timely valid and complete MA encounter data In 2012 CMS began collecting from MA organizations a more comprehensive set of encounter data reflecting the items and services provided to MA plan enrollees Prior CMS and OIG audits have indicated vulnerabilities in the accuracy of data reporting by MA organizations Realizing the potential benefits of the MA encounter data for payment and program integrity oversight is contingent upon the datarsquos completeness validity and timeliness (OEI 03-15-00060 expected issue date FY 2017)

73

Pepper Reports

bull httpswwwpepperresourcesorg

bull Program for Evaluating Payment Patterns Electronic Report ( PEPPER)

bull Annually on or about April 18 2016 will be released

bull Pepper Portal httpssecurefiletmforg

74

CGI Technologies and Solutions Inc httpracbcgicomContactInfoaspxst=1

bull Indiana bull Michiganbull Minnesotabull Illinoisbull Kentuckybull Ohiobull Wisconsin CGI Technologies and Solutions Incbull For general and administrative questions regarding client service outreach

quality assurance or project-specific issues contactbull 1877316RACB (7222)bull Email racbcgicom Tamara Tate Tamaratatecmshhsgovbull 4107861288

75

CGI Federal RAC

bull CGI Federal RAC Region Bbull Email racbcgicombull Phone 1-877-316-RACB (7222)bull Mailing Addressbull Send medical records as followsbull Medical records for Indiana Illinois Kentucky Michigan Ohio Wisconsin

Minnesota DME and Home Health CGI Federal Inc Attn RACB Imaging Dept 1001 Lakeside Ave Suite 800 Cleveland OH 44114

bull If submitting paper records please send medical records as follows For Therapy Reviews CGI Federal Inc Attn RACB Imaging 1001 Lakeside Avenue Suite 800 Cleveland OH 44114

76

How to survive RAC Audit

bull National health expenditures totaled $1679 Billion in 2003 bull National health expenditures were 153 of GROSS Domestic Product

(GDP) in 2003 bull Health care cost increasing at +9 per year bull Doomsday predictions of Medicare running out bull Congressional Action

77

RAC Audits

bull Medicare Modernization Act (MMA) of 2003Mandated a three year audit demonstration project 2005-2008

bull Appoint audit contractors to review Medicare billings for proper coding DRG assignment and medical necessity

bull Audits will apply to all health care providers (hospitals physicians homecare dme etc)

bull Audit contractors to be paid on a contingency basis a percentage of overpayments recovered

78

How Did we get here

bull Overpayments collected due to errors in Medically Unnecessary Services ndash 40

bull Incorrectly Coded ndash 35

bull Other ndash 17

bull NoInsufficient Documentation ndash 8

79

Where are we now

bull All RACrsquos completed required provider outreachAccess to Medicare billing data base given to all RAC RAC review methodology

bull Automated Review-Black amp White Issues (current) bull DRG Validation-complex review (current) bull Complex Review for coding errors (current) bull DME Medical Necessity Reviews ndashcomplex review (calendar year

2010) bull Medical Necessity Reviews-complex review (calendar year 2010)

80

RAC Reviews

bull Responsibilities of the Team Leader bull Must learn each insurance provider participating in a RAC or RAC type

program bull What are their operating rulesbull What is their appeal process Time limits

May be different process for each insurance provider bull Develop a response team

Identify who does what when why and alternate bull individual

Build and develop a manual process Review of computerized system

81

Priority Health SCIO Health Analytics

bull httpswwwsciohealthanalyticscomcore-capabilitiespayment-integrityfacility-auditsskilled-nursing-facility-audits

bull Claims for Medicare members treated at Skilled Nursing Facilities are reimbursed based on the patientsrsquo RUG (Resource Utilization Group) score which is determined using the Minimum Data Set (MDS) Using SCIOs robust analytics claims andor providers that merit review are selected for audit SCIOs auditors conduct a detailed review of the complete medical record and associated MDS to determine if the billed RUG score is valid In the event the review determines that an incorrect RUG score was billed SCIOreg provides the valid score reports the reason the change was necessary and calculates the resulting overpayment

82

+ Cheer

Onward and Upward she shall prevail We are here to care for the residents and provide a wonderful

service

13 83

84

References

bull Priority Healthbull Blue Crossbull Medicaidbull Medicare

85

  • Medicare Mange Care amp Medicaid Changes in the New World We Live In
  • Medicaid
  • NEW Medicaid Change MIlogin
  • Blueprint for Health Innovation MI
  • Provider Enrollment Electronic Signature Form Submission Process MSA 15-54
  • Provider Enrollment Electronic Signature Form Submission Process
  • Provider Enrollment Domain Administrator
  • Medicaid Coinsurance Medicare Advantage
  • Slide Number 9
  • Lawsuit DHS Changes on Caregivers
  • TPL Medicaid Change
  • CHAMPS Member Screen
  • LOC dropping off Not Due to MI Health
  • Issues
  • Secure Email Information
  • Medicaid amp Hospice
  • Medicaid
  • Medicaid Medicare Buy In
  • Manage Medicaid
  • Healthy Michigan Residents
  • Healthy Michigan Medicaid Days
  • McLaren Health Plan
  • Manage Medicaid Plans January 1
  • Slide Number 24
  • MI Health Link
  • MI Health Link 2565
  • What are the Names
  • MI Health Dual Eligible
  • MI Health LOC
  • LOC Medicaid
  • Medicaid Redetermination and MHL Enrollment
  • MI Health Link Portals
  • MI Health Authorizations
  • MI Health Issues
  • LOC 02 dropping MI Health Issues
  • PPA Offset
  • LOCD
  • MI Health Issues-New
  • ACO
  • Families Receiving Letters for ACO
  • ACO What is It
  • Payroll Based Journal
  • Slide Number 43
  • If you submit data manually should you also submit it through the XML
  • Staffing Submission Frequently Asked Questions
  • CMS defines
  • Slide Number 47
  • PBJ Medical Director Role
  • PBJ Medical Director Role
  • Dietician
  • Pharmacy Consultant
  • What are the names for the Medicare Number
  • QTSO
  • Medicare Update
  • CMS Final Rule On Returning Credits
  • Over Payment Rule
  • Questions to MAC
  • Questions to MAC
  • Final Rule on Returning Credits
  • Final Rule on Returning Credits
  • Final Rule on Returning Credits
  • Slide Number 62
  • Medicare Advantage Payors
  • Medicare Provider Enrollment Fee
  • Medicare MAC-Higlas
  • Two Midnight Rule
  • Two Midnight Rule
  • Two Midnight Rule
  • InPatient Vs Observation Conthellip
  • Two Midnight Rule
  • Health Data Insights amp Medicare Plus Blue
  • HDI Health Data amp Med Plus Blue
  • Health Data InSight
  • Pepper Reports
  • CGI Technologies and Solutions Inc httpracbcgicomContactInfoaspxst=1
  • CGI Federal RAC
  • How to survive RAC Audit
  • RAC Audits
  • How Did we get here
  • Where are we now
  • RAC Reviews
  • Priority Health SCIO Health Analytics
  • Cheer
  • References
Page 34: Medicare, Mange Care & Medicaid Changes in the New World we live in

MI Health Issuesbull We are seeing some issues with MI Health where the resident does not have the correct LOC or it shows

up correct on CHAMPS but ancillary providers such as Dentist and such cannot see it I think we still have some issues with the information crossing between Bridges DHS system CMS and CHAMPS It in return is creating some access of care issues If it is a true LOC issues Facilities with LOC issues need to submit the Medicaid ID numbers to the MSA-MHL-EnrollmentMichigangov box with the subject line Nursing home LOC Issue so they may work to resolve the issues

bull If it becomes an access to care issue email the information to INTEGRATEDCAREmichigangov Remember in these emails only send the Medicaid ID and explain the situation The State will work with the plans to try to fix the process or improve the process

bull We are also seeing with new admission with LOC 015 or 005 that the plans are stating they have 14 days to authorize admission These are resident in the emergency room and possibly be admitted to you for Rehab The hospital will not keep the resident in ER for 14 days and you cannot admit the resident until you have a prior authorization I would recommend when you are told this by the plan that you need to ask to speak to a manager We will have to work through this

bull Ancillary Provider You need to work with your ancillary providers such as Lab Pharmacy X-Ray Physician and such to get the to be credentialed with the plans We are hearing that some of the pharmacies are not participating with the plans this will create issues for you so I would continue to ask these groups to participate

34

LOC 02 dropping MI Health Issuesbull The passive enrollments have occurred in Macomb amp Wayne for

Medicaid dual eligible We are having the same issue we did as in the Southwest MI amp UP with the passive enrollments I am starting to hear from facilities who are checking there CHAMPS member screens that those residents that have opted out (some residents not all) have lost there 02 Make sure you are checking your CHAMPS member screen both for those that were passively enrolled and those that might have lost there 02 Medicaid that opted out

bull Facilities with LOC issues need to submit the Medicaid ID numbers to the (Only MI Health)MSA-MHL-Enrollmentmichigangov box with the subject line Nursing home LOC Issue so they may work to resolve the issues

35

PPA Offset

bull There are no co-pays deductibles or premiums in MI Health Link so there should be no need to offset the PPA with code 25 MI Health Link enrollees can continue to offset their PPA for non-program covered medical expenses (like Vision-Code 27 Dental-Code 28 and Hearing-Code 26) and use the appropriate codes to offset the PPA when billing the health plan for nursing facility services

bull Resident pay PPA when MedicareMedicaid coinsurance

36

LOCDbull Nursing Facility Level of Care Determination (NFLOCD)

bull The MI Health Link health plan will be responsible for conducting the Michigan Medicaid NFLOCD tool for enrollees seeking admission to a nursing facility For existing residents at the time of enrollment the existing NFLOCD will be adopted for capitation payment purposes The health plan will complete a new NFLCOD tool within the first 90 days of enrollment If a nursing facility resident is disenrolled from MI Health Link the nursing facility will be responsible for conducting a new NFLOCD tool in accordance with published Medicaid policy

37

MI Health Issues-New

bull INTEGRATEDCAREmichigangov

bull Email with Insurance Plan issues Case Manager Issues

38

ACOWhat are they

39

Families Receiving Letters for ACO

40

ACO What is It

bull Whats an ACObull Accountable Care Organizations (ACOs) are groups of doctors hospitals

and other health care providers who come together voluntarily to give coordinated high quality care to their Medicare patients

bull The goal of coordinated care is to ensure that patients especially the chronically ill get the right care at the right time while avoiding

unnecessary duplication of services and preventing medical errorsbull When an ACO succeeds both in delivering high-quality care and

spending health care dollars more wisely it will share in the savings it achieves for the Medicare program

41

Payroll Based JournalMandatory on July 1 2016Internet Explorer Version

Internet Explorer v 10 and v 11 will need to operate in compatibility mode

42

43

If you submit data manually should you also submit it through the XML

bull Now you have three options

bull Submit Manually only

bull Submit through the XML only

bull You are able to submit manually and using the XML

44

45

Staffing Submission Frequently Asked Questions

bull ldquoWho are direct care staffrdquo (Who do we submit data for)bull Submission of data for contract staffbull Medical directors and consultantsbull Staff switching roles or tasks throughout the daybull Hours paid vs hours worked ndash Must be verifiablebull Public postingQuality MeasuresFive Starbull Enforcementbull Voluntary submission risks (noneSo register now)

CMS defines

bull 37 job title codes that are required to match employees to the number of hours each direct care function was performed It is important to work with your teams to define the workers that contribute to each job type and how those daily worked hours are recorded and converted to a PBJ submission

bull The PBJ does include some more specific job descriptions than the 671 For example the PBJ system includes job descriptions for RNs with administrative duties and LPNs with administrative duties versus the 671rsquos more general ldquoNurses with Administrative Duties

Page 46

47

PBJ Medical Director Rolebull Physician Leadership

bull Help the facility ensure that patients have appropriate physician coverage and ensure the provision of physician and health care practitioner services and

bull Help the facility develop a process for reviewing physician and health care practitioner credentials

bull Provide specific guidance for physician performance expectations

bull Help the facility ensure that a system is in place for monitoring the performance of health care practitioners and

bull Facilitate feedback to physicians and other health care practitioners on performance and practices

bull Patient Care - Clinical Leadership

bull Participate in administrative decision-making and the development of policies and procedures related to patient care

bull Help develop approve and implement specific clinical practices for the facility to incorporate into its care-related policies and procedures including areas required by laws and regulations

bull Develop procedures and guidance for facility staff regarding contacting practitioners including information gathering and presentation change in condition assessment and when to contact the medical director

bull Review consider andor act upon consultant recommendations as appropriate that affect the facilitys resident care policies and procedures or the care of an individual resident

bull Review respond to and participate in federal state local and other external surveys and inspections and

bull Help review policies and procedures regarding the adequate protection of patients rights advance care planning and other ethical issues48

PBJ Medical Director Rolebull Quality of Care

bull Help the facility establish systems and methods for reviewing the quality and appropriateness of clinical care and other health-related services and provide appropriate feedback and

bull Participate in the facilitys quality improvement process

bull Advise on infection control issues and approve specific infection control policies to be incorporated into facility policies and procedures

bull Help the facility provide a safe and caring environment

bull Help promote employee health and safety and

bull Assist in the development and implementation of employee health policies and programs

bull Education Information and Communication

bull Promote a learning culture within the facility by educating informing and communicating

bull Provide information to help the facility provide care consistent with current standards of practice (defined as approaches to care procedures techniques and treatments that are based on research and or expert consensus and that are contained in current manuals textbooks and or publications or that are accepted adopted or promulgated by recognized organizations or national bodies)

bull Help the facility develop medical information and communication systems with staff patients and families and others

bull Represent the facility to the professional and lay community on medical and patient care issues

bull Maintain knowledge of the changing social regulatory political and economic factors that affect medical and health services of long term care patients and

bull Help establish appropriate relationships with other health care organizations

49

Dietician

bull When the dietary or food services supervisor is other than a registered dietitian the supervisor shall receive routine consultation and technical assistance from a registered dietitian (RD) Consultation time shall not be less than 4 hours every 60 days Additional consultation time may be needed based on the total number of patients incidence of nutrition-related health problems and food service management needs of the facility

50

Pharmacy Consultant

bull At least once per month a licensed pharmacist must perform a drug regimen review (DRR) for each resident The pharmacist must report any irregularities to the attending physician or director of nursing Furthermore these reports must be acted upon

51

What are the names for the Medicare Numberbull OSCAR -Online Survey Certification and Reporting

bull PTAN-PTAN number is assigned by Medicare to authenticate the provider when using the local Medicare Administrative Contractorrsquos (MAC) self-help tools like the IVR internet portal on-line application status etc Provider Transactions Access Number

bull CCN- CMS Certification Number

bull Medicare Number- example 23-

bull All of the above mean the same thing

52

QTSO

bull Once you are logged in the QTSO site bull You will have a state login to the site to access the various site specific

to your facilitybull Installing you will need administrator rights to your network

53

Medicare UpdateWhat are we seeing

54

CMS Final Rule On Returning Credits

httpswwwfederalregistergovarticles201602122016-02789medicare-program-reporting-and-returning-of-overpayments

55

Over Payment Rule

bull Medicare payments for non covered services

bull Medicare payments in excess of the allowable amount for an identified covered service

bull Errors and non reimbursable expenditures in cost reportsbull Duplicate payment

bull Receipt of Medicare payments when another payor had the primary responsibility for payment

56

Questions to MAC

bull Does the Medicare credit balance report change with this overpayment rule

bull No Medicare Credit Balances are still required at the end of each quarter

bull Will that still be the communication to let CMS or the MAC know that we have received an overpayment

bull Submission of Medicare Credit Balance is one form of communicating overpayments to CMS Other methods include submitting a voluntary refund with required claim information or the submission of a standard overpayment form

57

Questions to MAC

bull Will the MAC still deduct from a future RAbull If the recovery of the overpayment includes adjusting a claim then

the overpayment would be netted against future claims payments and reflected on the RA

bull Or will that process change with this new rulebull Process will remain the samebull Will NGS send communication out on thisbull Yes NGS will communicate this once the final rule is communicated

to the MACs by CMS However this could change depending on final CMS instructions

58

Final Rule on Returning Credits

bull Providers will want to immediately update their current policies governing overpayments in order to comply with this new rule which will take effect on March 14 2016

bull Providers and suppliers are required to use reasonable diligence to investigate credible information regarding overpayments through both proactive compliance efforts and reactive investigations

bull If an overpayment is identified then it must be repaid within 60 days An overpayment is identified when a person has or should have through the exercise of reasonable diligence determined that the person received an overpayment and quantified the amount

bull Providers and suppliers have a maximum of 8 months to report and return overpayments ndash up to 6 months to investigate and quantify the overpayment (ie to identify it) and up to 60 days to report and return the overpayment

59

Final Rule on Returning Credits

bull Providers and suppliers are required to report and return all overpayments within a 6-year lookback period

bull The cause and amount of the overpayment is irrelevant for the determination eg it was due to a mistake it was someone elsersquos fault it is a minor amount An overpayment is an overpayment and must be returned

bull Providers and suppliers must make their own determination to which entity to report and return the overpayment ie to the Medicare contractor or using the OIG Self Disclosure Protocol or the CMS Self Referral Disclosure Protocol

60

Final Rule on Returning Credits

bull Providers and suppliers may use the claims adjustment credit balance self-reported refund process or another appropriate process to report and return overpayments At this time there is no standard refund form to use

bull Failure to report and return an overpayment could subject the provider or supplier to False Claims Act liability Civil Monetary Penalties Law liability and exclusion from federal health care programs

61

P S amp R-Accountants will be asking for this information

The location you login into has changed it is now on EIDM EIDM is the acronym for CMS Enterprise Identity Management system which includes Identity Verification Access Management Authorization Assistance Workflow Tools and Identity Lifecycle Management functions

httpswwwcmsgovResearch-Statistics-Data-and-SystemsCMS-Information-TechnologyIACSCMS-Applications-Loginhtml

Go down the page and click on the PSampRSTARThis will take you to the login pagewill look the same as the old P S amp R didChanges Affecting PSampR System Access (Please Read) (posted 01292015)(Updated 5262015)is changingThe system which controls your PSampR user ID (currently IACS)The new system is referred to as EIDMThis will result in a different way to create new accounts or change passwords to existing accountsIf you already have an account in EIDM you may have to use that account for accessing PSampR after the transitionWhen is the change effectiveJune 13 2015What is staying the sameThe internet address for accessing PSampR remains the sameThe PSampR systemfunctionality is NOT changing 62

Medicare Advantage Payorsbull Medicare Advantage payors are pullingdenying payments on admissions if the patient was readmitted within 30 days after discharge The

client believes that the payors systematically denying payments for all readmissions within 30 days They believe this practice denies them due process to address whether the readmissions were justified and not due to a premature discharge of patient The payors seem to want to act like a QIO without having the same accountabilities of the QIO related to determinations of non-payment

bull Heres the QIO process under section 4240 of the QIO Manualbull 4240 - Readmission Review - (Rev 2 07-11-03)bull Readmission review involves admissions to an acute general short-term hospital occurring less than 31 calendar days from the date of

discharge from the same or another acute general short-term hospital (see sect1154(a)(13) and 42 CFR 47671(a)(8)(ii)) Neither the day of discharge nor the day of admission is counted when determining whether a readmission has occurred

bull A Medical Review Proceduresbull Obtain the appropriate medical records for the initial admission and readmission Perform case review on both stays Analyze the cases

specifically to determine whether the patient was prematurely discharged from the first confinement thus causing readmission Perform an analysis of the stay at the first hospital to determine the cause(s) and extent of any problem(s) (eg incomplete or substandard treatment) Consider the information available to the attending physician who discharged the patient from the first confinement Do not base a determination of a premature discharge on information that the physician or provider could not have known or events that could not have been anticipated at the time of discharge

bull Review both the initial admission and the readmission at the same time unless one of them has previously been reviewed In these cases use at a minimum the PRAF case summary of the other admission in addition to the medical record of the case under review

bull C Denialsbull Deny readmissions under the following circumstancesbull If the readmission was medically unnecessarybull If the readmission resulted from a premature discharge from the same hospital orbull If the readmission was a result of circumvention of PPS by the same hospital (see sect4255)bull With the QIO process there is an appeal within the QIO here the hospital is getting no opportunity to challenge the denials

63

Medicare Provider Enrollment Feebull Provider Enrollment Application Fee Amount for CY 2016bull On December 3 CMS issued a notice Provider Enrollment Application

Fee Amount for CY 2016 [CMSndash6066ndashN] Effective January 1 2016 the CY 2016 application fee is $554 for institutional providers that are

bull Initially enrolling in the Medicare or Medicaid program or the Childrens Health Insurance Program (CHIP)

bull Revalidating their Medicare Medicaid or CHIP enrollmentbull Adding a new Medicare practice locationbull This fee is required with any enrollment application submitted from

January 1 through December 31 2016

64

Medicare MAC-Higlas

bull Effective 142016 CMS has implemented a change to begin netting (offsetting) provider money across workloads within a single organization What this means is that any related providers conducting business in two different workloads (example New York and Maine) will have their money applied to any account receivables (AR) with a remaining balance owed to Medicare within both workloads For example Provider ABC is located in New York and is scheduled to receive a payment of $1000 on todays remittance advice Provider XYZ is related to provider ABC but is located in Maine and has ARs with a balance owed of $200 Provider ABCs $1000 payment will have the $200 applied against provider XYZs ARs resulting in a net payment of $800 This will be reflected on the remittance advice by the same PLB code as seen today for offsets for the $200

65

Two Midnight RuleChange January 1 2016 httpswwwcmsgovMedicareMedicare-Fee-for-Service-PaymentHospitalOutpatientPPSHospital-Outpatient-Regulations-and-Notices-ItemsCMS-1633-FChtml

66

Two Midnight Rulebull However effective January 1 2016 CMS will allow exceptions to the

Two-Midnight Benchmark to be determined on a case-by-case basis by the physician responsible for the care of the beneficiary subject to medical review Said differently Part A payment may be appropriate in some circumstances even though there is no expectation by the physician (or qualified ordering practitioner) of a two-midnight stay and one of the two pre-existing categorical exceptions (CMS ldquoinpatient onlyrdquo list and newly initiated mechanical ventilation) does not apply CMS has indicated that this change to the Two Midnight Rule is in response to stakeholder concern and CMSrsquos continued efforts to develop the most appropriate standard for determining Medicare Part A payment

67

Two Midnight Rulebull A new 42 CFR sect4123(a) provides that a patient is considered an

inpatient of a hospitalhellipif formally admitted as an inpatient pursuant to an order for inpatient admission by a physician or other qualified practitionerhellip The physician orders inpatient status when he or she expects the patient to require a stay that crosses at least 2 midnights[10] Stays expected to be shorter than at least two midnights are generally inappropriate for inpatient admission and inpatient payment under Medicare Part A unless the surgical procedure is specified by Medicare as inpatient only under sect41922(n)[11] The physicians expectationhellipshould be based on such complex medical factors as patient history and comorbidities the severity of signs and symptoms current medical needs and the risk of an adverse event[12] The physician order is part of physician certification of the medical necessity of hospital inpatient serviceshellip[13]

68

InPatient Vs Observation Conthellip

bull Physician certification which begins with an order for inpatient admission requires the physician to certify the reasons for the hospitalization the estimated time the patient will remain in the hospital and plans for post-hospital care if appropriate[14] The certification must be completed signed and documented in the medical record prior to discharge[15]

bull A physicians admission order has no presumptive weight and both the admission order and the physician certification will be evaluated in the context of the evidence in the medical record[16] CMS intends to provide additional information about what evidence in the medical record means in future instructions and manual revisions[17]

69

Two Midnight Rulebull Although the new case-by-case exception appears to be inherently

subjective to a certain extent CMS states that the following factors (among others) would be relevant to determining whether a patient requires inpatient admission under the expanded policy

bull The severity of the signs and symptoms exhibited by the patient bull The medical predictability of something adverse happening to the patient

and bull The need for diagnostic studies that appropriately are outpatient services

(that is their performance does not ordinarily require the patient to remain at the hospital for 24 hours or more)

bull CMS also notes that an inpatient admission (and Part A payment) should be ldquorare and unusualrdquo for minor surgical procedures or other treatment that is expected to keep the patient in the hospital ldquofor only a few hoursrdquo or for a period of time that ldquodoes not span at least overnightrdquo (thus a subset of stays not meeting the Two Midnight Benchmark) CMS indicates that such cases will be prioritized for medical review

70

Health Data Insights amp Medicare Plus Blue

RAC (Retrospective Audits)

71

HDI Health Data amp Med Plus Blue

bull httpwwwhealthdatainsightscombull Blue Cross Medicare Advantage Auditsbull Facilities seeing 10 to 15 requests for Medical Recordsbull In January amp Feburarybull Selected Health Data Insights because they were a premier Audit

Vendor for CMS Recovery Audit Contractor (RAC) demonstration Project They are a audit vendor for Humana

bull Providers not sending Medical Record will get technical denial and lose payments

72

Health Data InSight

bull In 2010 they began the Hospital Reviewbull Medicare Advantage encounter datandashCMS oversight of data integrity OIG

2016bull We will review CMSs oversight of MA encounter data validation and assess

the extent to which CMSrsquos Integrated Data Repository contains timely valid and complete MA encounter data In 2012 CMS began collecting from MA organizations a more comprehensive set of encounter data reflecting the items and services provided to MA plan enrollees Prior CMS and OIG audits have indicated vulnerabilities in the accuracy of data reporting by MA organizations Realizing the potential benefits of the MA encounter data for payment and program integrity oversight is contingent upon the datarsquos completeness validity and timeliness (OEI 03-15-00060 expected issue date FY 2017)

73

Pepper Reports

bull httpswwwpepperresourcesorg

bull Program for Evaluating Payment Patterns Electronic Report ( PEPPER)

bull Annually on or about April 18 2016 will be released

bull Pepper Portal httpssecurefiletmforg

74

CGI Technologies and Solutions Inc httpracbcgicomContactInfoaspxst=1

bull Indiana bull Michiganbull Minnesotabull Illinoisbull Kentuckybull Ohiobull Wisconsin CGI Technologies and Solutions Incbull For general and administrative questions regarding client service outreach

quality assurance or project-specific issues contactbull 1877316RACB (7222)bull Email racbcgicom Tamara Tate Tamaratatecmshhsgovbull 4107861288

75

CGI Federal RAC

bull CGI Federal RAC Region Bbull Email racbcgicombull Phone 1-877-316-RACB (7222)bull Mailing Addressbull Send medical records as followsbull Medical records for Indiana Illinois Kentucky Michigan Ohio Wisconsin

Minnesota DME and Home Health CGI Federal Inc Attn RACB Imaging Dept 1001 Lakeside Ave Suite 800 Cleveland OH 44114

bull If submitting paper records please send medical records as follows For Therapy Reviews CGI Federal Inc Attn RACB Imaging 1001 Lakeside Avenue Suite 800 Cleveland OH 44114

76

How to survive RAC Audit

bull National health expenditures totaled $1679 Billion in 2003 bull National health expenditures were 153 of GROSS Domestic Product

(GDP) in 2003 bull Health care cost increasing at +9 per year bull Doomsday predictions of Medicare running out bull Congressional Action

77

RAC Audits

bull Medicare Modernization Act (MMA) of 2003Mandated a three year audit demonstration project 2005-2008

bull Appoint audit contractors to review Medicare billings for proper coding DRG assignment and medical necessity

bull Audits will apply to all health care providers (hospitals physicians homecare dme etc)

bull Audit contractors to be paid on a contingency basis a percentage of overpayments recovered

78

How Did we get here

bull Overpayments collected due to errors in Medically Unnecessary Services ndash 40

bull Incorrectly Coded ndash 35

bull Other ndash 17

bull NoInsufficient Documentation ndash 8

79

Where are we now

bull All RACrsquos completed required provider outreachAccess to Medicare billing data base given to all RAC RAC review methodology

bull Automated Review-Black amp White Issues (current) bull DRG Validation-complex review (current) bull Complex Review for coding errors (current) bull DME Medical Necessity Reviews ndashcomplex review (calendar year

2010) bull Medical Necessity Reviews-complex review (calendar year 2010)

80

RAC Reviews

bull Responsibilities of the Team Leader bull Must learn each insurance provider participating in a RAC or RAC type

program bull What are their operating rulesbull What is their appeal process Time limits

May be different process for each insurance provider bull Develop a response team

Identify who does what when why and alternate bull individual

Build and develop a manual process Review of computerized system

81

Priority Health SCIO Health Analytics

bull httpswwwsciohealthanalyticscomcore-capabilitiespayment-integrityfacility-auditsskilled-nursing-facility-audits

bull Claims for Medicare members treated at Skilled Nursing Facilities are reimbursed based on the patientsrsquo RUG (Resource Utilization Group) score which is determined using the Minimum Data Set (MDS) Using SCIOs robust analytics claims andor providers that merit review are selected for audit SCIOs auditors conduct a detailed review of the complete medical record and associated MDS to determine if the billed RUG score is valid In the event the review determines that an incorrect RUG score was billed SCIOreg provides the valid score reports the reason the change was necessary and calculates the resulting overpayment

82

+ Cheer

Onward and Upward she shall prevail We are here to care for the residents and provide a wonderful

service

13 83

84

References

bull Priority Healthbull Blue Crossbull Medicaidbull Medicare

85

  • Medicare Mange Care amp Medicaid Changes in the New World We Live In
  • Medicaid
  • NEW Medicaid Change MIlogin
  • Blueprint for Health Innovation MI
  • Provider Enrollment Electronic Signature Form Submission Process MSA 15-54
  • Provider Enrollment Electronic Signature Form Submission Process
  • Provider Enrollment Domain Administrator
  • Medicaid Coinsurance Medicare Advantage
  • Slide Number 9
  • Lawsuit DHS Changes on Caregivers
  • TPL Medicaid Change
  • CHAMPS Member Screen
  • LOC dropping off Not Due to MI Health
  • Issues
  • Secure Email Information
  • Medicaid amp Hospice
  • Medicaid
  • Medicaid Medicare Buy In
  • Manage Medicaid
  • Healthy Michigan Residents
  • Healthy Michigan Medicaid Days
  • McLaren Health Plan
  • Manage Medicaid Plans January 1
  • Slide Number 24
  • MI Health Link
  • MI Health Link 2565
  • What are the Names
  • MI Health Dual Eligible
  • MI Health LOC
  • LOC Medicaid
  • Medicaid Redetermination and MHL Enrollment
  • MI Health Link Portals
  • MI Health Authorizations
  • MI Health Issues
  • LOC 02 dropping MI Health Issues
  • PPA Offset
  • LOCD
  • MI Health Issues-New
  • ACO
  • Families Receiving Letters for ACO
  • ACO What is It
  • Payroll Based Journal
  • Slide Number 43
  • If you submit data manually should you also submit it through the XML
  • Staffing Submission Frequently Asked Questions
  • CMS defines
  • Slide Number 47
  • PBJ Medical Director Role
  • PBJ Medical Director Role
  • Dietician
  • Pharmacy Consultant
  • What are the names for the Medicare Number
  • QTSO
  • Medicare Update
  • CMS Final Rule On Returning Credits
  • Over Payment Rule
  • Questions to MAC
  • Questions to MAC
  • Final Rule on Returning Credits
  • Final Rule on Returning Credits
  • Final Rule on Returning Credits
  • Slide Number 62
  • Medicare Advantage Payors
  • Medicare Provider Enrollment Fee
  • Medicare MAC-Higlas
  • Two Midnight Rule
  • Two Midnight Rule
  • Two Midnight Rule
  • InPatient Vs Observation Conthellip
  • Two Midnight Rule
  • Health Data Insights amp Medicare Plus Blue
  • HDI Health Data amp Med Plus Blue
  • Health Data InSight
  • Pepper Reports
  • CGI Technologies and Solutions Inc httpracbcgicomContactInfoaspxst=1
  • CGI Federal RAC
  • How to survive RAC Audit
  • RAC Audits
  • How Did we get here
  • Where are we now
  • RAC Reviews
  • Priority Health SCIO Health Analytics
  • Cheer
  • References
Page 35: Medicare, Mange Care & Medicaid Changes in the New World we live in

LOC 02 dropping MI Health Issuesbull The passive enrollments have occurred in Macomb amp Wayne for

Medicaid dual eligible We are having the same issue we did as in the Southwest MI amp UP with the passive enrollments I am starting to hear from facilities who are checking there CHAMPS member screens that those residents that have opted out (some residents not all) have lost there 02 Make sure you are checking your CHAMPS member screen both for those that were passively enrolled and those that might have lost there 02 Medicaid that opted out

bull Facilities with LOC issues need to submit the Medicaid ID numbers to the (Only MI Health)MSA-MHL-Enrollmentmichigangov box with the subject line Nursing home LOC Issue so they may work to resolve the issues

35

PPA Offset

bull There are no co-pays deductibles or premiums in MI Health Link so there should be no need to offset the PPA with code 25 MI Health Link enrollees can continue to offset their PPA for non-program covered medical expenses (like Vision-Code 27 Dental-Code 28 and Hearing-Code 26) and use the appropriate codes to offset the PPA when billing the health plan for nursing facility services

bull Resident pay PPA when MedicareMedicaid coinsurance

36

LOCDbull Nursing Facility Level of Care Determination (NFLOCD)

bull The MI Health Link health plan will be responsible for conducting the Michigan Medicaid NFLOCD tool for enrollees seeking admission to a nursing facility For existing residents at the time of enrollment the existing NFLOCD will be adopted for capitation payment purposes The health plan will complete a new NFLCOD tool within the first 90 days of enrollment If a nursing facility resident is disenrolled from MI Health Link the nursing facility will be responsible for conducting a new NFLOCD tool in accordance with published Medicaid policy

37

MI Health Issues-New

bull INTEGRATEDCAREmichigangov

bull Email with Insurance Plan issues Case Manager Issues

38

ACOWhat are they

39

Families Receiving Letters for ACO

40

ACO What is It

bull Whats an ACObull Accountable Care Organizations (ACOs) are groups of doctors hospitals

and other health care providers who come together voluntarily to give coordinated high quality care to their Medicare patients

bull The goal of coordinated care is to ensure that patients especially the chronically ill get the right care at the right time while avoiding

unnecessary duplication of services and preventing medical errorsbull When an ACO succeeds both in delivering high-quality care and

spending health care dollars more wisely it will share in the savings it achieves for the Medicare program

41

Payroll Based JournalMandatory on July 1 2016Internet Explorer Version

Internet Explorer v 10 and v 11 will need to operate in compatibility mode

42

43

If you submit data manually should you also submit it through the XML

bull Now you have three options

bull Submit Manually only

bull Submit through the XML only

bull You are able to submit manually and using the XML

44

45

Staffing Submission Frequently Asked Questions

bull ldquoWho are direct care staffrdquo (Who do we submit data for)bull Submission of data for contract staffbull Medical directors and consultantsbull Staff switching roles or tasks throughout the daybull Hours paid vs hours worked ndash Must be verifiablebull Public postingQuality MeasuresFive Starbull Enforcementbull Voluntary submission risks (noneSo register now)

CMS defines

bull 37 job title codes that are required to match employees to the number of hours each direct care function was performed It is important to work with your teams to define the workers that contribute to each job type and how those daily worked hours are recorded and converted to a PBJ submission

bull The PBJ does include some more specific job descriptions than the 671 For example the PBJ system includes job descriptions for RNs with administrative duties and LPNs with administrative duties versus the 671rsquos more general ldquoNurses with Administrative Duties

Page 46

47

PBJ Medical Director Rolebull Physician Leadership

bull Help the facility ensure that patients have appropriate physician coverage and ensure the provision of physician and health care practitioner services and

bull Help the facility develop a process for reviewing physician and health care practitioner credentials

bull Provide specific guidance for physician performance expectations

bull Help the facility ensure that a system is in place for monitoring the performance of health care practitioners and

bull Facilitate feedback to physicians and other health care practitioners on performance and practices

bull Patient Care - Clinical Leadership

bull Participate in administrative decision-making and the development of policies and procedures related to patient care

bull Help develop approve and implement specific clinical practices for the facility to incorporate into its care-related policies and procedures including areas required by laws and regulations

bull Develop procedures and guidance for facility staff regarding contacting practitioners including information gathering and presentation change in condition assessment and when to contact the medical director

bull Review consider andor act upon consultant recommendations as appropriate that affect the facilitys resident care policies and procedures or the care of an individual resident

bull Review respond to and participate in federal state local and other external surveys and inspections and

bull Help review policies and procedures regarding the adequate protection of patients rights advance care planning and other ethical issues48

PBJ Medical Director Rolebull Quality of Care

bull Help the facility establish systems and methods for reviewing the quality and appropriateness of clinical care and other health-related services and provide appropriate feedback and

bull Participate in the facilitys quality improvement process

bull Advise on infection control issues and approve specific infection control policies to be incorporated into facility policies and procedures

bull Help the facility provide a safe and caring environment

bull Help promote employee health and safety and

bull Assist in the development and implementation of employee health policies and programs

bull Education Information and Communication

bull Promote a learning culture within the facility by educating informing and communicating

bull Provide information to help the facility provide care consistent with current standards of practice (defined as approaches to care procedures techniques and treatments that are based on research and or expert consensus and that are contained in current manuals textbooks and or publications or that are accepted adopted or promulgated by recognized organizations or national bodies)

bull Help the facility develop medical information and communication systems with staff patients and families and others

bull Represent the facility to the professional and lay community on medical and patient care issues

bull Maintain knowledge of the changing social regulatory political and economic factors that affect medical and health services of long term care patients and

bull Help establish appropriate relationships with other health care organizations

49

Dietician

bull When the dietary or food services supervisor is other than a registered dietitian the supervisor shall receive routine consultation and technical assistance from a registered dietitian (RD) Consultation time shall not be less than 4 hours every 60 days Additional consultation time may be needed based on the total number of patients incidence of nutrition-related health problems and food service management needs of the facility

50

Pharmacy Consultant

bull At least once per month a licensed pharmacist must perform a drug regimen review (DRR) for each resident The pharmacist must report any irregularities to the attending physician or director of nursing Furthermore these reports must be acted upon

51

What are the names for the Medicare Numberbull OSCAR -Online Survey Certification and Reporting

bull PTAN-PTAN number is assigned by Medicare to authenticate the provider when using the local Medicare Administrative Contractorrsquos (MAC) self-help tools like the IVR internet portal on-line application status etc Provider Transactions Access Number

bull CCN- CMS Certification Number

bull Medicare Number- example 23-

bull All of the above mean the same thing

52

QTSO

bull Once you are logged in the QTSO site bull You will have a state login to the site to access the various site specific

to your facilitybull Installing you will need administrator rights to your network

53

Medicare UpdateWhat are we seeing

54

CMS Final Rule On Returning Credits

httpswwwfederalregistergovarticles201602122016-02789medicare-program-reporting-and-returning-of-overpayments

55

Over Payment Rule

bull Medicare payments for non covered services

bull Medicare payments in excess of the allowable amount for an identified covered service

bull Errors and non reimbursable expenditures in cost reportsbull Duplicate payment

bull Receipt of Medicare payments when another payor had the primary responsibility for payment

56

Questions to MAC

bull Does the Medicare credit balance report change with this overpayment rule

bull No Medicare Credit Balances are still required at the end of each quarter

bull Will that still be the communication to let CMS or the MAC know that we have received an overpayment

bull Submission of Medicare Credit Balance is one form of communicating overpayments to CMS Other methods include submitting a voluntary refund with required claim information or the submission of a standard overpayment form

57

Questions to MAC

bull Will the MAC still deduct from a future RAbull If the recovery of the overpayment includes adjusting a claim then

the overpayment would be netted against future claims payments and reflected on the RA

bull Or will that process change with this new rulebull Process will remain the samebull Will NGS send communication out on thisbull Yes NGS will communicate this once the final rule is communicated

to the MACs by CMS However this could change depending on final CMS instructions

58

Final Rule on Returning Credits

bull Providers will want to immediately update their current policies governing overpayments in order to comply with this new rule which will take effect on March 14 2016

bull Providers and suppliers are required to use reasonable diligence to investigate credible information regarding overpayments through both proactive compliance efforts and reactive investigations

bull If an overpayment is identified then it must be repaid within 60 days An overpayment is identified when a person has or should have through the exercise of reasonable diligence determined that the person received an overpayment and quantified the amount

bull Providers and suppliers have a maximum of 8 months to report and return overpayments ndash up to 6 months to investigate and quantify the overpayment (ie to identify it) and up to 60 days to report and return the overpayment

59

Final Rule on Returning Credits

bull Providers and suppliers are required to report and return all overpayments within a 6-year lookback period

bull The cause and amount of the overpayment is irrelevant for the determination eg it was due to a mistake it was someone elsersquos fault it is a minor amount An overpayment is an overpayment and must be returned

bull Providers and suppliers must make their own determination to which entity to report and return the overpayment ie to the Medicare contractor or using the OIG Self Disclosure Protocol or the CMS Self Referral Disclosure Protocol

60

Final Rule on Returning Credits

bull Providers and suppliers may use the claims adjustment credit balance self-reported refund process or another appropriate process to report and return overpayments At this time there is no standard refund form to use

bull Failure to report and return an overpayment could subject the provider or supplier to False Claims Act liability Civil Monetary Penalties Law liability and exclusion from federal health care programs

61

P S amp R-Accountants will be asking for this information

The location you login into has changed it is now on EIDM EIDM is the acronym for CMS Enterprise Identity Management system which includes Identity Verification Access Management Authorization Assistance Workflow Tools and Identity Lifecycle Management functions

httpswwwcmsgovResearch-Statistics-Data-and-SystemsCMS-Information-TechnologyIACSCMS-Applications-Loginhtml

Go down the page and click on the PSampRSTARThis will take you to the login pagewill look the same as the old P S amp R didChanges Affecting PSampR System Access (Please Read) (posted 01292015)(Updated 5262015)is changingThe system which controls your PSampR user ID (currently IACS)The new system is referred to as EIDMThis will result in a different way to create new accounts or change passwords to existing accountsIf you already have an account in EIDM you may have to use that account for accessing PSampR after the transitionWhen is the change effectiveJune 13 2015What is staying the sameThe internet address for accessing PSampR remains the sameThe PSampR systemfunctionality is NOT changing 62

Medicare Advantage Payorsbull Medicare Advantage payors are pullingdenying payments on admissions if the patient was readmitted within 30 days after discharge The

client believes that the payors systematically denying payments for all readmissions within 30 days They believe this practice denies them due process to address whether the readmissions were justified and not due to a premature discharge of patient The payors seem to want to act like a QIO without having the same accountabilities of the QIO related to determinations of non-payment

bull Heres the QIO process under section 4240 of the QIO Manualbull 4240 - Readmission Review - (Rev 2 07-11-03)bull Readmission review involves admissions to an acute general short-term hospital occurring less than 31 calendar days from the date of

discharge from the same or another acute general short-term hospital (see sect1154(a)(13) and 42 CFR 47671(a)(8)(ii)) Neither the day of discharge nor the day of admission is counted when determining whether a readmission has occurred

bull A Medical Review Proceduresbull Obtain the appropriate medical records for the initial admission and readmission Perform case review on both stays Analyze the cases

specifically to determine whether the patient was prematurely discharged from the first confinement thus causing readmission Perform an analysis of the stay at the first hospital to determine the cause(s) and extent of any problem(s) (eg incomplete or substandard treatment) Consider the information available to the attending physician who discharged the patient from the first confinement Do not base a determination of a premature discharge on information that the physician or provider could not have known or events that could not have been anticipated at the time of discharge

bull Review both the initial admission and the readmission at the same time unless one of them has previously been reviewed In these cases use at a minimum the PRAF case summary of the other admission in addition to the medical record of the case under review

bull C Denialsbull Deny readmissions under the following circumstancesbull If the readmission was medically unnecessarybull If the readmission resulted from a premature discharge from the same hospital orbull If the readmission was a result of circumvention of PPS by the same hospital (see sect4255)bull With the QIO process there is an appeal within the QIO here the hospital is getting no opportunity to challenge the denials

63

Medicare Provider Enrollment Feebull Provider Enrollment Application Fee Amount for CY 2016bull On December 3 CMS issued a notice Provider Enrollment Application

Fee Amount for CY 2016 [CMSndash6066ndashN] Effective January 1 2016 the CY 2016 application fee is $554 for institutional providers that are

bull Initially enrolling in the Medicare or Medicaid program or the Childrens Health Insurance Program (CHIP)

bull Revalidating their Medicare Medicaid or CHIP enrollmentbull Adding a new Medicare practice locationbull This fee is required with any enrollment application submitted from

January 1 through December 31 2016

64

Medicare MAC-Higlas

bull Effective 142016 CMS has implemented a change to begin netting (offsetting) provider money across workloads within a single organization What this means is that any related providers conducting business in two different workloads (example New York and Maine) will have their money applied to any account receivables (AR) with a remaining balance owed to Medicare within both workloads For example Provider ABC is located in New York and is scheduled to receive a payment of $1000 on todays remittance advice Provider XYZ is related to provider ABC but is located in Maine and has ARs with a balance owed of $200 Provider ABCs $1000 payment will have the $200 applied against provider XYZs ARs resulting in a net payment of $800 This will be reflected on the remittance advice by the same PLB code as seen today for offsets for the $200

65

Two Midnight RuleChange January 1 2016 httpswwwcmsgovMedicareMedicare-Fee-for-Service-PaymentHospitalOutpatientPPSHospital-Outpatient-Regulations-and-Notices-ItemsCMS-1633-FChtml

66

Two Midnight Rulebull However effective January 1 2016 CMS will allow exceptions to the

Two-Midnight Benchmark to be determined on a case-by-case basis by the physician responsible for the care of the beneficiary subject to medical review Said differently Part A payment may be appropriate in some circumstances even though there is no expectation by the physician (or qualified ordering practitioner) of a two-midnight stay and one of the two pre-existing categorical exceptions (CMS ldquoinpatient onlyrdquo list and newly initiated mechanical ventilation) does not apply CMS has indicated that this change to the Two Midnight Rule is in response to stakeholder concern and CMSrsquos continued efforts to develop the most appropriate standard for determining Medicare Part A payment

67

Two Midnight Rulebull A new 42 CFR sect4123(a) provides that a patient is considered an

inpatient of a hospitalhellipif formally admitted as an inpatient pursuant to an order for inpatient admission by a physician or other qualified practitionerhellip The physician orders inpatient status when he or she expects the patient to require a stay that crosses at least 2 midnights[10] Stays expected to be shorter than at least two midnights are generally inappropriate for inpatient admission and inpatient payment under Medicare Part A unless the surgical procedure is specified by Medicare as inpatient only under sect41922(n)[11] The physicians expectationhellipshould be based on such complex medical factors as patient history and comorbidities the severity of signs and symptoms current medical needs and the risk of an adverse event[12] The physician order is part of physician certification of the medical necessity of hospital inpatient serviceshellip[13]

68

InPatient Vs Observation Conthellip

bull Physician certification which begins with an order for inpatient admission requires the physician to certify the reasons for the hospitalization the estimated time the patient will remain in the hospital and plans for post-hospital care if appropriate[14] The certification must be completed signed and documented in the medical record prior to discharge[15]

bull A physicians admission order has no presumptive weight and both the admission order and the physician certification will be evaluated in the context of the evidence in the medical record[16] CMS intends to provide additional information about what evidence in the medical record means in future instructions and manual revisions[17]

69

Two Midnight Rulebull Although the new case-by-case exception appears to be inherently

subjective to a certain extent CMS states that the following factors (among others) would be relevant to determining whether a patient requires inpatient admission under the expanded policy

bull The severity of the signs and symptoms exhibited by the patient bull The medical predictability of something adverse happening to the patient

and bull The need for diagnostic studies that appropriately are outpatient services

(that is their performance does not ordinarily require the patient to remain at the hospital for 24 hours or more)

bull CMS also notes that an inpatient admission (and Part A payment) should be ldquorare and unusualrdquo for minor surgical procedures or other treatment that is expected to keep the patient in the hospital ldquofor only a few hoursrdquo or for a period of time that ldquodoes not span at least overnightrdquo (thus a subset of stays not meeting the Two Midnight Benchmark) CMS indicates that such cases will be prioritized for medical review

70

Health Data Insights amp Medicare Plus Blue

RAC (Retrospective Audits)

71

HDI Health Data amp Med Plus Blue

bull httpwwwhealthdatainsightscombull Blue Cross Medicare Advantage Auditsbull Facilities seeing 10 to 15 requests for Medical Recordsbull In January amp Feburarybull Selected Health Data Insights because they were a premier Audit

Vendor for CMS Recovery Audit Contractor (RAC) demonstration Project They are a audit vendor for Humana

bull Providers not sending Medical Record will get technical denial and lose payments

72

Health Data InSight

bull In 2010 they began the Hospital Reviewbull Medicare Advantage encounter datandashCMS oversight of data integrity OIG

2016bull We will review CMSs oversight of MA encounter data validation and assess

the extent to which CMSrsquos Integrated Data Repository contains timely valid and complete MA encounter data In 2012 CMS began collecting from MA organizations a more comprehensive set of encounter data reflecting the items and services provided to MA plan enrollees Prior CMS and OIG audits have indicated vulnerabilities in the accuracy of data reporting by MA organizations Realizing the potential benefits of the MA encounter data for payment and program integrity oversight is contingent upon the datarsquos completeness validity and timeliness (OEI 03-15-00060 expected issue date FY 2017)

73

Pepper Reports

bull httpswwwpepperresourcesorg

bull Program for Evaluating Payment Patterns Electronic Report ( PEPPER)

bull Annually on or about April 18 2016 will be released

bull Pepper Portal httpssecurefiletmforg

74

CGI Technologies and Solutions Inc httpracbcgicomContactInfoaspxst=1

bull Indiana bull Michiganbull Minnesotabull Illinoisbull Kentuckybull Ohiobull Wisconsin CGI Technologies and Solutions Incbull For general and administrative questions regarding client service outreach

quality assurance or project-specific issues contactbull 1877316RACB (7222)bull Email racbcgicom Tamara Tate Tamaratatecmshhsgovbull 4107861288

75

CGI Federal RAC

bull CGI Federal RAC Region Bbull Email racbcgicombull Phone 1-877-316-RACB (7222)bull Mailing Addressbull Send medical records as followsbull Medical records for Indiana Illinois Kentucky Michigan Ohio Wisconsin

Minnesota DME and Home Health CGI Federal Inc Attn RACB Imaging Dept 1001 Lakeside Ave Suite 800 Cleveland OH 44114

bull If submitting paper records please send medical records as follows For Therapy Reviews CGI Federal Inc Attn RACB Imaging 1001 Lakeside Avenue Suite 800 Cleveland OH 44114

76

How to survive RAC Audit

bull National health expenditures totaled $1679 Billion in 2003 bull National health expenditures were 153 of GROSS Domestic Product

(GDP) in 2003 bull Health care cost increasing at +9 per year bull Doomsday predictions of Medicare running out bull Congressional Action

77

RAC Audits

bull Medicare Modernization Act (MMA) of 2003Mandated a three year audit demonstration project 2005-2008

bull Appoint audit contractors to review Medicare billings for proper coding DRG assignment and medical necessity

bull Audits will apply to all health care providers (hospitals physicians homecare dme etc)

bull Audit contractors to be paid on a contingency basis a percentage of overpayments recovered

78

How Did we get here

bull Overpayments collected due to errors in Medically Unnecessary Services ndash 40

bull Incorrectly Coded ndash 35

bull Other ndash 17

bull NoInsufficient Documentation ndash 8

79

Where are we now

bull All RACrsquos completed required provider outreachAccess to Medicare billing data base given to all RAC RAC review methodology

bull Automated Review-Black amp White Issues (current) bull DRG Validation-complex review (current) bull Complex Review for coding errors (current) bull DME Medical Necessity Reviews ndashcomplex review (calendar year

2010) bull Medical Necessity Reviews-complex review (calendar year 2010)

80

RAC Reviews

bull Responsibilities of the Team Leader bull Must learn each insurance provider participating in a RAC or RAC type

program bull What are their operating rulesbull What is their appeal process Time limits

May be different process for each insurance provider bull Develop a response team

Identify who does what when why and alternate bull individual

Build and develop a manual process Review of computerized system

81

Priority Health SCIO Health Analytics

bull httpswwwsciohealthanalyticscomcore-capabilitiespayment-integrityfacility-auditsskilled-nursing-facility-audits

bull Claims for Medicare members treated at Skilled Nursing Facilities are reimbursed based on the patientsrsquo RUG (Resource Utilization Group) score which is determined using the Minimum Data Set (MDS) Using SCIOs robust analytics claims andor providers that merit review are selected for audit SCIOs auditors conduct a detailed review of the complete medical record and associated MDS to determine if the billed RUG score is valid In the event the review determines that an incorrect RUG score was billed SCIOreg provides the valid score reports the reason the change was necessary and calculates the resulting overpayment

82

+ Cheer

Onward and Upward she shall prevail We are here to care for the residents and provide a wonderful

service

13 83

84

References

bull Priority Healthbull Blue Crossbull Medicaidbull Medicare

85

  • Medicare Mange Care amp Medicaid Changes in the New World We Live In
  • Medicaid
  • NEW Medicaid Change MIlogin
  • Blueprint for Health Innovation MI
  • Provider Enrollment Electronic Signature Form Submission Process MSA 15-54
  • Provider Enrollment Electronic Signature Form Submission Process
  • Provider Enrollment Domain Administrator
  • Medicaid Coinsurance Medicare Advantage
  • Slide Number 9
  • Lawsuit DHS Changes on Caregivers
  • TPL Medicaid Change
  • CHAMPS Member Screen
  • LOC dropping off Not Due to MI Health
  • Issues
  • Secure Email Information
  • Medicaid amp Hospice
  • Medicaid
  • Medicaid Medicare Buy In
  • Manage Medicaid
  • Healthy Michigan Residents
  • Healthy Michigan Medicaid Days
  • McLaren Health Plan
  • Manage Medicaid Plans January 1
  • Slide Number 24
  • MI Health Link
  • MI Health Link 2565
  • What are the Names
  • MI Health Dual Eligible
  • MI Health LOC
  • LOC Medicaid
  • Medicaid Redetermination and MHL Enrollment
  • MI Health Link Portals
  • MI Health Authorizations
  • MI Health Issues
  • LOC 02 dropping MI Health Issues
  • PPA Offset
  • LOCD
  • MI Health Issues-New
  • ACO
  • Families Receiving Letters for ACO
  • ACO What is It
  • Payroll Based Journal
  • Slide Number 43
  • If you submit data manually should you also submit it through the XML
  • Staffing Submission Frequently Asked Questions
  • CMS defines
  • Slide Number 47
  • PBJ Medical Director Role
  • PBJ Medical Director Role
  • Dietician
  • Pharmacy Consultant
  • What are the names for the Medicare Number
  • QTSO
  • Medicare Update
  • CMS Final Rule On Returning Credits
  • Over Payment Rule
  • Questions to MAC
  • Questions to MAC
  • Final Rule on Returning Credits
  • Final Rule on Returning Credits
  • Final Rule on Returning Credits
  • Slide Number 62
  • Medicare Advantage Payors
  • Medicare Provider Enrollment Fee
  • Medicare MAC-Higlas
  • Two Midnight Rule
  • Two Midnight Rule
  • Two Midnight Rule
  • InPatient Vs Observation Conthellip
  • Two Midnight Rule
  • Health Data Insights amp Medicare Plus Blue
  • HDI Health Data amp Med Plus Blue
  • Health Data InSight
  • Pepper Reports
  • CGI Technologies and Solutions Inc httpracbcgicomContactInfoaspxst=1
  • CGI Federal RAC
  • How to survive RAC Audit
  • RAC Audits
  • How Did we get here
  • Where are we now
  • RAC Reviews
  • Priority Health SCIO Health Analytics
  • Cheer
  • References
Page 36: Medicare, Mange Care & Medicaid Changes in the New World we live in

PPA Offset

bull There are no co-pays deductibles or premiums in MI Health Link so there should be no need to offset the PPA with code 25 MI Health Link enrollees can continue to offset their PPA for non-program covered medical expenses (like Vision-Code 27 Dental-Code 28 and Hearing-Code 26) and use the appropriate codes to offset the PPA when billing the health plan for nursing facility services

bull Resident pay PPA when MedicareMedicaid coinsurance

36

LOCDbull Nursing Facility Level of Care Determination (NFLOCD)

bull The MI Health Link health plan will be responsible for conducting the Michigan Medicaid NFLOCD tool for enrollees seeking admission to a nursing facility For existing residents at the time of enrollment the existing NFLOCD will be adopted for capitation payment purposes The health plan will complete a new NFLCOD tool within the first 90 days of enrollment If a nursing facility resident is disenrolled from MI Health Link the nursing facility will be responsible for conducting a new NFLOCD tool in accordance with published Medicaid policy

37

MI Health Issues-New

bull INTEGRATEDCAREmichigangov

bull Email with Insurance Plan issues Case Manager Issues

38

ACOWhat are they

39

Families Receiving Letters for ACO

40

ACO What is It

bull Whats an ACObull Accountable Care Organizations (ACOs) are groups of doctors hospitals

and other health care providers who come together voluntarily to give coordinated high quality care to their Medicare patients

bull The goal of coordinated care is to ensure that patients especially the chronically ill get the right care at the right time while avoiding

unnecessary duplication of services and preventing medical errorsbull When an ACO succeeds both in delivering high-quality care and

spending health care dollars more wisely it will share in the savings it achieves for the Medicare program

41

Payroll Based JournalMandatory on July 1 2016Internet Explorer Version

Internet Explorer v 10 and v 11 will need to operate in compatibility mode

42

43

If you submit data manually should you also submit it through the XML

bull Now you have three options

bull Submit Manually only

bull Submit through the XML only

bull You are able to submit manually and using the XML

44

45

Staffing Submission Frequently Asked Questions

bull ldquoWho are direct care staffrdquo (Who do we submit data for)bull Submission of data for contract staffbull Medical directors and consultantsbull Staff switching roles or tasks throughout the daybull Hours paid vs hours worked ndash Must be verifiablebull Public postingQuality MeasuresFive Starbull Enforcementbull Voluntary submission risks (noneSo register now)

CMS defines

bull 37 job title codes that are required to match employees to the number of hours each direct care function was performed It is important to work with your teams to define the workers that contribute to each job type and how those daily worked hours are recorded and converted to a PBJ submission

bull The PBJ does include some more specific job descriptions than the 671 For example the PBJ system includes job descriptions for RNs with administrative duties and LPNs with administrative duties versus the 671rsquos more general ldquoNurses with Administrative Duties

Page 46

47

PBJ Medical Director Rolebull Physician Leadership

bull Help the facility ensure that patients have appropriate physician coverage and ensure the provision of physician and health care practitioner services and

bull Help the facility develop a process for reviewing physician and health care practitioner credentials

bull Provide specific guidance for physician performance expectations

bull Help the facility ensure that a system is in place for monitoring the performance of health care practitioners and

bull Facilitate feedback to physicians and other health care practitioners on performance and practices

bull Patient Care - Clinical Leadership

bull Participate in administrative decision-making and the development of policies and procedures related to patient care

bull Help develop approve and implement specific clinical practices for the facility to incorporate into its care-related policies and procedures including areas required by laws and regulations

bull Develop procedures and guidance for facility staff regarding contacting practitioners including information gathering and presentation change in condition assessment and when to contact the medical director

bull Review consider andor act upon consultant recommendations as appropriate that affect the facilitys resident care policies and procedures or the care of an individual resident

bull Review respond to and participate in federal state local and other external surveys and inspections and

bull Help review policies and procedures regarding the adequate protection of patients rights advance care planning and other ethical issues48

PBJ Medical Director Rolebull Quality of Care

bull Help the facility establish systems and methods for reviewing the quality and appropriateness of clinical care and other health-related services and provide appropriate feedback and

bull Participate in the facilitys quality improvement process

bull Advise on infection control issues and approve specific infection control policies to be incorporated into facility policies and procedures

bull Help the facility provide a safe and caring environment

bull Help promote employee health and safety and

bull Assist in the development and implementation of employee health policies and programs

bull Education Information and Communication

bull Promote a learning culture within the facility by educating informing and communicating

bull Provide information to help the facility provide care consistent with current standards of practice (defined as approaches to care procedures techniques and treatments that are based on research and or expert consensus and that are contained in current manuals textbooks and or publications or that are accepted adopted or promulgated by recognized organizations or national bodies)

bull Help the facility develop medical information and communication systems with staff patients and families and others

bull Represent the facility to the professional and lay community on medical and patient care issues

bull Maintain knowledge of the changing social regulatory political and economic factors that affect medical and health services of long term care patients and

bull Help establish appropriate relationships with other health care organizations

49

Dietician

bull When the dietary or food services supervisor is other than a registered dietitian the supervisor shall receive routine consultation and technical assistance from a registered dietitian (RD) Consultation time shall not be less than 4 hours every 60 days Additional consultation time may be needed based on the total number of patients incidence of nutrition-related health problems and food service management needs of the facility

50

Pharmacy Consultant

bull At least once per month a licensed pharmacist must perform a drug regimen review (DRR) for each resident The pharmacist must report any irregularities to the attending physician or director of nursing Furthermore these reports must be acted upon

51

What are the names for the Medicare Numberbull OSCAR -Online Survey Certification and Reporting

bull PTAN-PTAN number is assigned by Medicare to authenticate the provider when using the local Medicare Administrative Contractorrsquos (MAC) self-help tools like the IVR internet portal on-line application status etc Provider Transactions Access Number

bull CCN- CMS Certification Number

bull Medicare Number- example 23-

bull All of the above mean the same thing

52

QTSO

bull Once you are logged in the QTSO site bull You will have a state login to the site to access the various site specific

to your facilitybull Installing you will need administrator rights to your network

53

Medicare UpdateWhat are we seeing

54

CMS Final Rule On Returning Credits

httpswwwfederalregistergovarticles201602122016-02789medicare-program-reporting-and-returning-of-overpayments

55

Over Payment Rule

bull Medicare payments for non covered services

bull Medicare payments in excess of the allowable amount for an identified covered service

bull Errors and non reimbursable expenditures in cost reportsbull Duplicate payment

bull Receipt of Medicare payments when another payor had the primary responsibility for payment

56

Questions to MAC

bull Does the Medicare credit balance report change with this overpayment rule

bull No Medicare Credit Balances are still required at the end of each quarter

bull Will that still be the communication to let CMS or the MAC know that we have received an overpayment

bull Submission of Medicare Credit Balance is one form of communicating overpayments to CMS Other methods include submitting a voluntary refund with required claim information or the submission of a standard overpayment form

57

Questions to MAC

bull Will the MAC still deduct from a future RAbull If the recovery of the overpayment includes adjusting a claim then

the overpayment would be netted against future claims payments and reflected on the RA

bull Or will that process change with this new rulebull Process will remain the samebull Will NGS send communication out on thisbull Yes NGS will communicate this once the final rule is communicated

to the MACs by CMS However this could change depending on final CMS instructions

58

Final Rule on Returning Credits

bull Providers will want to immediately update their current policies governing overpayments in order to comply with this new rule which will take effect on March 14 2016

bull Providers and suppliers are required to use reasonable diligence to investigate credible information regarding overpayments through both proactive compliance efforts and reactive investigations

bull If an overpayment is identified then it must be repaid within 60 days An overpayment is identified when a person has or should have through the exercise of reasonable diligence determined that the person received an overpayment and quantified the amount

bull Providers and suppliers have a maximum of 8 months to report and return overpayments ndash up to 6 months to investigate and quantify the overpayment (ie to identify it) and up to 60 days to report and return the overpayment

59

Final Rule on Returning Credits

bull Providers and suppliers are required to report and return all overpayments within a 6-year lookback period

bull The cause and amount of the overpayment is irrelevant for the determination eg it was due to a mistake it was someone elsersquos fault it is a minor amount An overpayment is an overpayment and must be returned

bull Providers and suppliers must make their own determination to which entity to report and return the overpayment ie to the Medicare contractor or using the OIG Self Disclosure Protocol or the CMS Self Referral Disclosure Protocol

60

Final Rule on Returning Credits

bull Providers and suppliers may use the claims adjustment credit balance self-reported refund process or another appropriate process to report and return overpayments At this time there is no standard refund form to use

bull Failure to report and return an overpayment could subject the provider or supplier to False Claims Act liability Civil Monetary Penalties Law liability and exclusion from federal health care programs

61

P S amp R-Accountants will be asking for this information

The location you login into has changed it is now on EIDM EIDM is the acronym for CMS Enterprise Identity Management system which includes Identity Verification Access Management Authorization Assistance Workflow Tools and Identity Lifecycle Management functions

httpswwwcmsgovResearch-Statistics-Data-and-SystemsCMS-Information-TechnologyIACSCMS-Applications-Loginhtml

Go down the page and click on the PSampRSTARThis will take you to the login pagewill look the same as the old P S amp R didChanges Affecting PSampR System Access (Please Read) (posted 01292015)(Updated 5262015)is changingThe system which controls your PSampR user ID (currently IACS)The new system is referred to as EIDMThis will result in a different way to create new accounts or change passwords to existing accountsIf you already have an account in EIDM you may have to use that account for accessing PSampR after the transitionWhen is the change effectiveJune 13 2015What is staying the sameThe internet address for accessing PSampR remains the sameThe PSampR systemfunctionality is NOT changing 62

Medicare Advantage Payorsbull Medicare Advantage payors are pullingdenying payments on admissions if the patient was readmitted within 30 days after discharge The

client believes that the payors systematically denying payments for all readmissions within 30 days They believe this practice denies them due process to address whether the readmissions were justified and not due to a premature discharge of patient The payors seem to want to act like a QIO without having the same accountabilities of the QIO related to determinations of non-payment

bull Heres the QIO process under section 4240 of the QIO Manualbull 4240 - Readmission Review - (Rev 2 07-11-03)bull Readmission review involves admissions to an acute general short-term hospital occurring less than 31 calendar days from the date of

discharge from the same or another acute general short-term hospital (see sect1154(a)(13) and 42 CFR 47671(a)(8)(ii)) Neither the day of discharge nor the day of admission is counted when determining whether a readmission has occurred

bull A Medical Review Proceduresbull Obtain the appropriate medical records for the initial admission and readmission Perform case review on both stays Analyze the cases

specifically to determine whether the patient was prematurely discharged from the first confinement thus causing readmission Perform an analysis of the stay at the first hospital to determine the cause(s) and extent of any problem(s) (eg incomplete or substandard treatment) Consider the information available to the attending physician who discharged the patient from the first confinement Do not base a determination of a premature discharge on information that the physician or provider could not have known or events that could not have been anticipated at the time of discharge

bull Review both the initial admission and the readmission at the same time unless one of them has previously been reviewed In these cases use at a minimum the PRAF case summary of the other admission in addition to the medical record of the case under review

bull C Denialsbull Deny readmissions under the following circumstancesbull If the readmission was medically unnecessarybull If the readmission resulted from a premature discharge from the same hospital orbull If the readmission was a result of circumvention of PPS by the same hospital (see sect4255)bull With the QIO process there is an appeal within the QIO here the hospital is getting no opportunity to challenge the denials

63

Medicare Provider Enrollment Feebull Provider Enrollment Application Fee Amount for CY 2016bull On December 3 CMS issued a notice Provider Enrollment Application

Fee Amount for CY 2016 [CMSndash6066ndashN] Effective January 1 2016 the CY 2016 application fee is $554 for institutional providers that are

bull Initially enrolling in the Medicare or Medicaid program or the Childrens Health Insurance Program (CHIP)

bull Revalidating their Medicare Medicaid or CHIP enrollmentbull Adding a new Medicare practice locationbull This fee is required with any enrollment application submitted from

January 1 through December 31 2016

64

Medicare MAC-Higlas

bull Effective 142016 CMS has implemented a change to begin netting (offsetting) provider money across workloads within a single organization What this means is that any related providers conducting business in two different workloads (example New York and Maine) will have their money applied to any account receivables (AR) with a remaining balance owed to Medicare within both workloads For example Provider ABC is located in New York and is scheduled to receive a payment of $1000 on todays remittance advice Provider XYZ is related to provider ABC but is located in Maine and has ARs with a balance owed of $200 Provider ABCs $1000 payment will have the $200 applied against provider XYZs ARs resulting in a net payment of $800 This will be reflected on the remittance advice by the same PLB code as seen today for offsets for the $200

65

Two Midnight RuleChange January 1 2016 httpswwwcmsgovMedicareMedicare-Fee-for-Service-PaymentHospitalOutpatientPPSHospital-Outpatient-Regulations-and-Notices-ItemsCMS-1633-FChtml

66

Two Midnight Rulebull However effective January 1 2016 CMS will allow exceptions to the

Two-Midnight Benchmark to be determined on a case-by-case basis by the physician responsible for the care of the beneficiary subject to medical review Said differently Part A payment may be appropriate in some circumstances even though there is no expectation by the physician (or qualified ordering practitioner) of a two-midnight stay and one of the two pre-existing categorical exceptions (CMS ldquoinpatient onlyrdquo list and newly initiated mechanical ventilation) does not apply CMS has indicated that this change to the Two Midnight Rule is in response to stakeholder concern and CMSrsquos continued efforts to develop the most appropriate standard for determining Medicare Part A payment

67

Two Midnight Rulebull A new 42 CFR sect4123(a) provides that a patient is considered an

inpatient of a hospitalhellipif formally admitted as an inpatient pursuant to an order for inpatient admission by a physician or other qualified practitionerhellip The physician orders inpatient status when he or she expects the patient to require a stay that crosses at least 2 midnights[10] Stays expected to be shorter than at least two midnights are generally inappropriate for inpatient admission and inpatient payment under Medicare Part A unless the surgical procedure is specified by Medicare as inpatient only under sect41922(n)[11] The physicians expectationhellipshould be based on such complex medical factors as patient history and comorbidities the severity of signs and symptoms current medical needs and the risk of an adverse event[12] The physician order is part of physician certification of the medical necessity of hospital inpatient serviceshellip[13]

68

InPatient Vs Observation Conthellip

bull Physician certification which begins with an order for inpatient admission requires the physician to certify the reasons for the hospitalization the estimated time the patient will remain in the hospital and plans for post-hospital care if appropriate[14] The certification must be completed signed and documented in the medical record prior to discharge[15]

bull A physicians admission order has no presumptive weight and both the admission order and the physician certification will be evaluated in the context of the evidence in the medical record[16] CMS intends to provide additional information about what evidence in the medical record means in future instructions and manual revisions[17]

69

Two Midnight Rulebull Although the new case-by-case exception appears to be inherently

subjective to a certain extent CMS states that the following factors (among others) would be relevant to determining whether a patient requires inpatient admission under the expanded policy

bull The severity of the signs and symptoms exhibited by the patient bull The medical predictability of something adverse happening to the patient

and bull The need for diagnostic studies that appropriately are outpatient services

(that is their performance does not ordinarily require the patient to remain at the hospital for 24 hours or more)

bull CMS also notes that an inpatient admission (and Part A payment) should be ldquorare and unusualrdquo for minor surgical procedures or other treatment that is expected to keep the patient in the hospital ldquofor only a few hoursrdquo or for a period of time that ldquodoes not span at least overnightrdquo (thus a subset of stays not meeting the Two Midnight Benchmark) CMS indicates that such cases will be prioritized for medical review

70

Health Data Insights amp Medicare Plus Blue

RAC (Retrospective Audits)

71

HDI Health Data amp Med Plus Blue

bull httpwwwhealthdatainsightscombull Blue Cross Medicare Advantage Auditsbull Facilities seeing 10 to 15 requests for Medical Recordsbull In January amp Feburarybull Selected Health Data Insights because they were a premier Audit

Vendor for CMS Recovery Audit Contractor (RAC) demonstration Project They are a audit vendor for Humana

bull Providers not sending Medical Record will get technical denial and lose payments

72

Health Data InSight

bull In 2010 they began the Hospital Reviewbull Medicare Advantage encounter datandashCMS oversight of data integrity OIG

2016bull We will review CMSs oversight of MA encounter data validation and assess

the extent to which CMSrsquos Integrated Data Repository contains timely valid and complete MA encounter data In 2012 CMS began collecting from MA organizations a more comprehensive set of encounter data reflecting the items and services provided to MA plan enrollees Prior CMS and OIG audits have indicated vulnerabilities in the accuracy of data reporting by MA organizations Realizing the potential benefits of the MA encounter data for payment and program integrity oversight is contingent upon the datarsquos completeness validity and timeliness (OEI 03-15-00060 expected issue date FY 2017)

73

Pepper Reports

bull httpswwwpepperresourcesorg

bull Program for Evaluating Payment Patterns Electronic Report ( PEPPER)

bull Annually on or about April 18 2016 will be released

bull Pepper Portal httpssecurefiletmforg

74

CGI Technologies and Solutions Inc httpracbcgicomContactInfoaspxst=1

bull Indiana bull Michiganbull Minnesotabull Illinoisbull Kentuckybull Ohiobull Wisconsin CGI Technologies and Solutions Incbull For general and administrative questions regarding client service outreach

quality assurance or project-specific issues contactbull 1877316RACB (7222)bull Email racbcgicom Tamara Tate Tamaratatecmshhsgovbull 4107861288

75

CGI Federal RAC

bull CGI Federal RAC Region Bbull Email racbcgicombull Phone 1-877-316-RACB (7222)bull Mailing Addressbull Send medical records as followsbull Medical records for Indiana Illinois Kentucky Michigan Ohio Wisconsin

Minnesota DME and Home Health CGI Federal Inc Attn RACB Imaging Dept 1001 Lakeside Ave Suite 800 Cleveland OH 44114

bull If submitting paper records please send medical records as follows For Therapy Reviews CGI Federal Inc Attn RACB Imaging 1001 Lakeside Avenue Suite 800 Cleveland OH 44114

76

How to survive RAC Audit

bull National health expenditures totaled $1679 Billion in 2003 bull National health expenditures were 153 of GROSS Domestic Product

(GDP) in 2003 bull Health care cost increasing at +9 per year bull Doomsday predictions of Medicare running out bull Congressional Action

77

RAC Audits

bull Medicare Modernization Act (MMA) of 2003Mandated a three year audit demonstration project 2005-2008

bull Appoint audit contractors to review Medicare billings for proper coding DRG assignment and medical necessity

bull Audits will apply to all health care providers (hospitals physicians homecare dme etc)

bull Audit contractors to be paid on a contingency basis a percentage of overpayments recovered

78

How Did we get here

bull Overpayments collected due to errors in Medically Unnecessary Services ndash 40

bull Incorrectly Coded ndash 35

bull Other ndash 17

bull NoInsufficient Documentation ndash 8

79

Where are we now

bull All RACrsquos completed required provider outreachAccess to Medicare billing data base given to all RAC RAC review methodology

bull Automated Review-Black amp White Issues (current) bull DRG Validation-complex review (current) bull Complex Review for coding errors (current) bull DME Medical Necessity Reviews ndashcomplex review (calendar year

2010) bull Medical Necessity Reviews-complex review (calendar year 2010)

80

RAC Reviews

bull Responsibilities of the Team Leader bull Must learn each insurance provider participating in a RAC or RAC type

program bull What are their operating rulesbull What is their appeal process Time limits

May be different process for each insurance provider bull Develop a response team

Identify who does what when why and alternate bull individual

Build and develop a manual process Review of computerized system

81

Priority Health SCIO Health Analytics

bull httpswwwsciohealthanalyticscomcore-capabilitiespayment-integrityfacility-auditsskilled-nursing-facility-audits

bull Claims for Medicare members treated at Skilled Nursing Facilities are reimbursed based on the patientsrsquo RUG (Resource Utilization Group) score which is determined using the Minimum Data Set (MDS) Using SCIOs robust analytics claims andor providers that merit review are selected for audit SCIOs auditors conduct a detailed review of the complete medical record and associated MDS to determine if the billed RUG score is valid In the event the review determines that an incorrect RUG score was billed SCIOreg provides the valid score reports the reason the change was necessary and calculates the resulting overpayment

82

+ Cheer

Onward and Upward she shall prevail We are here to care for the residents and provide a wonderful

service

13 83

84

References

bull Priority Healthbull Blue Crossbull Medicaidbull Medicare

85

  • Medicare Mange Care amp Medicaid Changes in the New World We Live In
  • Medicaid
  • NEW Medicaid Change MIlogin
  • Blueprint for Health Innovation MI
  • Provider Enrollment Electronic Signature Form Submission Process MSA 15-54
  • Provider Enrollment Electronic Signature Form Submission Process
  • Provider Enrollment Domain Administrator
  • Medicaid Coinsurance Medicare Advantage
  • Slide Number 9
  • Lawsuit DHS Changes on Caregivers
  • TPL Medicaid Change
  • CHAMPS Member Screen
  • LOC dropping off Not Due to MI Health
  • Issues
  • Secure Email Information
  • Medicaid amp Hospice
  • Medicaid
  • Medicaid Medicare Buy In
  • Manage Medicaid
  • Healthy Michigan Residents
  • Healthy Michigan Medicaid Days
  • McLaren Health Plan
  • Manage Medicaid Plans January 1
  • Slide Number 24
  • MI Health Link
  • MI Health Link 2565
  • What are the Names
  • MI Health Dual Eligible
  • MI Health LOC
  • LOC Medicaid
  • Medicaid Redetermination and MHL Enrollment
  • MI Health Link Portals
  • MI Health Authorizations
  • MI Health Issues
  • LOC 02 dropping MI Health Issues
  • PPA Offset
  • LOCD
  • MI Health Issues-New
  • ACO
  • Families Receiving Letters for ACO
  • ACO What is It
  • Payroll Based Journal
  • Slide Number 43
  • If you submit data manually should you also submit it through the XML
  • Staffing Submission Frequently Asked Questions
  • CMS defines
  • Slide Number 47
  • PBJ Medical Director Role
  • PBJ Medical Director Role
  • Dietician
  • Pharmacy Consultant
  • What are the names for the Medicare Number
  • QTSO
  • Medicare Update
  • CMS Final Rule On Returning Credits
  • Over Payment Rule
  • Questions to MAC
  • Questions to MAC
  • Final Rule on Returning Credits
  • Final Rule on Returning Credits
  • Final Rule on Returning Credits
  • Slide Number 62
  • Medicare Advantage Payors
  • Medicare Provider Enrollment Fee
  • Medicare MAC-Higlas
  • Two Midnight Rule
  • Two Midnight Rule
  • Two Midnight Rule
  • InPatient Vs Observation Conthellip
  • Two Midnight Rule
  • Health Data Insights amp Medicare Plus Blue
  • HDI Health Data amp Med Plus Blue
  • Health Data InSight
  • Pepper Reports
  • CGI Technologies and Solutions Inc httpracbcgicomContactInfoaspxst=1
  • CGI Federal RAC
  • How to survive RAC Audit
  • RAC Audits
  • How Did we get here
  • Where are we now
  • RAC Reviews
  • Priority Health SCIO Health Analytics
  • Cheer
  • References
Page 37: Medicare, Mange Care & Medicaid Changes in the New World we live in

LOCDbull Nursing Facility Level of Care Determination (NFLOCD)

bull The MI Health Link health plan will be responsible for conducting the Michigan Medicaid NFLOCD tool for enrollees seeking admission to a nursing facility For existing residents at the time of enrollment the existing NFLOCD will be adopted for capitation payment purposes The health plan will complete a new NFLCOD tool within the first 90 days of enrollment If a nursing facility resident is disenrolled from MI Health Link the nursing facility will be responsible for conducting a new NFLOCD tool in accordance with published Medicaid policy

37

MI Health Issues-New

bull INTEGRATEDCAREmichigangov

bull Email with Insurance Plan issues Case Manager Issues

38

ACOWhat are they

39

Families Receiving Letters for ACO

40

ACO What is It

bull Whats an ACObull Accountable Care Organizations (ACOs) are groups of doctors hospitals

and other health care providers who come together voluntarily to give coordinated high quality care to their Medicare patients

bull The goal of coordinated care is to ensure that patients especially the chronically ill get the right care at the right time while avoiding

unnecessary duplication of services and preventing medical errorsbull When an ACO succeeds both in delivering high-quality care and

spending health care dollars more wisely it will share in the savings it achieves for the Medicare program

41

Payroll Based JournalMandatory on July 1 2016Internet Explorer Version

Internet Explorer v 10 and v 11 will need to operate in compatibility mode

42

43

If you submit data manually should you also submit it through the XML

bull Now you have three options

bull Submit Manually only

bull Submit through the XML only

bull You are able to submit manually and using the XML

44

45

Staffing Submission Frequently Asked Questions

bull ldquoWho are direct care staffrdquo (Who do we submit data for)bull Submission of data for contract staffbull Medical directors and consultantsbull Staff switching roles or tasks throughout the daybull Hours paid vs hours worked ndash Must be verifiablebull Public postingQuality MeasuresFive Starbull Enforcementbull Voluntary submission risks (noneSo register now)

CMS defines

bull 37 job title codes that are required to match employees to the number of hours each direct care function was performed It is important to work with your teams to define the workers that contribute to each job type and how those daily worked hours are recorded and converted to a PBJ submission

bull The PBJ does include some more specific job descriptions than the 671 For example the PBJ system includes job descriptions for RNs with administrative duties and LPNs with administrative duties versus the 671rsquos more general ldquoNurses with Administrative Duties

Page 46

47

PBJ Medical Director Rolebull Physician Leadership

bull Help the facility ensure that patients have appropriate physician coverage and ensure the provision of physician and health care practitioner services and

bull Help the facility develop a process for reviewing physician and health care practitioner credentials

bull Provide specific guidance for physician performance expectations

bull Help the facility ensure that a system is in place for monitoring the performance of health care practitioners and

bull Facilitate feedback to physicians and other health care practitioners on performance and practices

bull Patient Care - Clinical Leadership

bull Participate in administrative decision-making and the development of policies and procedures related to patient care

bull Help develop approve and implement specific clinical practices for the facility to incorporate into its care-related policies and procedures including areas required by laws and regulations

bull Develop procedures and guidance for facility staff regarding contacting practitioners including information gathering and presentation change in condition assessment and when to contact the medical director

bull Review consider andor act upon consultant recommendations as appropriate that affect the facilitys resident care policies and procedures or the care of an individual resident

bull Review respond to and participate in federal state local and other external surveys and inspections and

bull Help review policies and procedures regarding the adequate protection of patients rights advance care planning and other ethical issues48

PBJ Medical Director Rolebull Quality of Care

bull Help the facility establish systems and methods for reviewing the quality and appropriateness of clinical care and other health-related services and provide appropriate feedback and

bull Participate in the facilitys quality improvement process

bull Advise on infection control issues and approve specific infection control policies to be incorporated into facility policies and procedures

bull Help the facility provide a safe and caring environment

bull Help promote employee health and safety and

bull Assist in the development and implementation of employee health policies and programs

bull Education Information and Communication

bull Promote a learning culture within the facility by educating informing and communicating

bull Provide information to help the facility provide care consistent with current standards of practice (defined as approaches to care procedures techniques and treatments that are based on research and or expert consensus and that are contained in current manuals textbooks and or publications or that are accepted adopted or promulgated by recognized organizations or national bodies)

bull Help the facility develop medical information and communication systems with staff patients and families and others

bull Represent the facility to the professional and lay community on medical and patient care issues

bull Maintain knowledge of the changing social regulatory political and economic factors that affect medical and health services of long term care patients and

bull Help establish appropriate relationships with other health care organizations

49

Dietician

bull When the dietary or food services supervisor is other than a registered dietitian the supervisor shall receive routine consultation and technical assistance from a registered dietitian (RD) Consultation time shall not be less than 4 hours every 60 days Additional consultation time may be needed based on the total number of patients incidence of nutrition-related health problems and food service management needs of the facility

50

Pharmacy Consultant

bull At least once per month a licensed pharmacist must perform a drug regimen review (DRR) for each resident The pharmacist must report any irregularities to the attending physician or director of nursing Furthermore these reports must be acted upon

51

What are the names for the Medicare Numberbull OSCAR -Online Survey Certification and Reporting

bull PTAN-PTAN number is assigned by Medicare to authenticate the provider when using the local Medicare Administrative Contractorrsquos (MAC) self-help tools like the IVR internet portal on-line application status etc Provider Transactions Access Number

bull CCN- CMS Certification Number

bull Medicare Number- example 23-

bull All of the above mean the same thing

52

QTSO

bull Once you are logged in the QTSO site bull You will have a state login to the site to access the various site specific

to your facilitybull Installing you will need administrator rights to your network

53

Medicare UpdateWhat are we seeing

54

CMS Final Rule On Returning Credits

httpswwwfederalregistergovarticles201602122016-02789medicare-program-reporting-and-returning-of-overpayments

55

Over Payment Rule

bull Medicare payments for non covered services

bull Medicare payments in excess of the allowable amount for an identified covered service

bull Errors and non reimbursable expenditures in cost reportsbull Duplicate payment

bull Receipt of Medicare payments when another payor had the primary responsibility for payment

56

Questions to MAC

bull Does the Medicare credit balance report change with this overpayment rule

bull No Medicare Credit Balances are still required at the end of each quarter

bull Will that still be the communication to let CMS or the MAC know that we have received an overpayment

bull Submission of Medicare Credit Balance is one form of communicating overpayments to CMS Other methods include submitting a voluntary refund with required claim information or the submission of a standard overpayment form

57

Questions to MAC

bull Will the MAC still deduct from a future RAbull If the recovery of the overpayment includes adjusting a claim then

the overpayment would be netted against future claims payments and reflected on the RA

bull Or will that process change with this new rulebull Process will remain the samebull Will NGS send communication out on thisbull Yes NGS will communicate this once the final rule is communicated

to the MACs by CMS However this could change depending on final CMS instructions

58

Final Rule on Returning Credits

bull Providers will want to immediately update their current policies governing overpayments in order to comply with this new rule which will take effect on March 14 2016

bull Providers and suppliers are required to use reasonable diligence to investigate credible information regarding overpayments through both proactive compliance efforts and reactive investigations

bull If an overpayment is identified then it must be repaid within 60 days An overpayment is identified when a person has or should have through the exercise of reasonable diligence determined that the person received an overpayment and quantified the amount

bull Providers and suppliers have a maximum of 8 months to report and return overpayments ndash up to 6 months to investigate and quantify the overpayment (ie to identify it) and up to 60 days to report and return the overpayment

59

Final Rule on Returning Credits

bull Providers and suppliers are required to report and return all overpayments within a 6-year lookback period

bull The cause and amount of the overpayment is irrelevant for the determination eg it was due to a mistake it was someone elsersquos fault it is a minor amount An overpayment is an overpayment and must be returned

bull Providers and suppliers must make their own determination to which entity to report and return the overpayment ie to the Medicare contractor or using the OIG Self Disclosure Protocol or the CMS Self Referral Disclosure Protocol

60

Final Rule on Returning Credits

bull Providers and suppliers may use the claims adjustment credit balance self-reported refund process or another appropriate process to report and return overpayments At this time there is no standard refund form to use

bull Failure to report and return an overpayment could subject the provider or supplier to False Claims Act liability Civil Monetary Penalties Law liability and exclusion from federal health care programs

61

P S amp R-Accountants will be asking for this information

The location you login into has changed it is now on EIDM EIDM is the acronym for CMS Enterprise Identity Management system which includes Identity Verification Access Management Authorization Assistance Workflow Tools and Identity Lifecycle Management functions

httpswwwcmsgovResearch-Statistics-Data-and-SystemsCMS-Information-TechnologyIACSCMS-Applications-Loginhtml

Go down the page and click on the PSampRSTARThis will take you to the login pagewill look the same as the old P S amp R didChanges Affecting PSampR System Access (Please Read) (posted 01292015)(Updated 5262015)is changingThe system which controls your PSampR user ID (currently IACS)The new system is referred to as EIDMThis will result in a different way to create new accounts or change passwords to existing accountsIf you already have an account in EIDM you may have to use that account for accessing PSampR after the transitionWhen is the change effectiveJune 13 2015What is staying the sameThe internet address for accessing PSampR remains the sameThe PSampR systemfunctionality is NOT changing 62

Medicare Advantage Payorsbull Medicare Advantage payors are pullingdenying payments on admissions if the patient was readmitted within 30 days after discharge The

client believes that the payors systematically denying payments for all readmissions within 30 days They believe this practice denies them due process to address whether the readmissions were justified and not due to a premature discharge of patient The payors seem to want to act like a QIO without having the same accountabilities of the QIO related to determinations of non-payment

bull Heres the QIO process under section 4240 of the QIO Manualbull 4240 - Readmission Review - (Rev 2 07-11-03)bull Readmission review involves admissions to an acute general short-term hospital occurring less than 31 calendar days from the date of

discharge from the same or another acute general short-term hospital (see sect1154(a)(13) and 42 CFR 47671(a)(8)(ii)) Neither the day of discharge nor the day of admission is counted when determining whether a readmission has occurred

bull A Medical Review Proceduresbull Obtain the appropriate medical records for the initial admission and readmission Perform case review on both stays Analyze the cases

specifically to determine whether the patient was prematurely discharged from the first confinement thus causing readmission Perform an analysis of the stay at the first hospital to determine the cause(s) and extent of any problem(s) (eg incomplete or substandard treatment) Consider the information available to the attending physician who discharged the patient from the first confinement Do not base a determination of a premature discharge on information that the physician or provider could not have known or events that could not have been anticipated at the time of discharge

bull Review both the initial admission and the readmission at the same time unless one of them has previously been reviewed In these cases use at a minimum the PRAF case summary of the other admission in addition to the medical record of the case under review

bull C Denialsbull Deny readmissions under the following circumstancesbull If the readmission was medically unnecessarybull If the readmission resulted from a premature discharge from the same hospital orbull If the readmission was a result of circumvention of PPS by the same hospital (see sect4255)bull With the QIO process there is an appeal within the QIO here the hospital is getting no opportunity to challenge the denials

63

Medicare Provider Enrollment Feebull Provider Enrollment Application Fee Amount for CY 2016bull On December 3 CMS issued a notice Provider Enrollment Application

Fee Amount for CY 2016 [CMSndash6066ndashN] Effective January 1 2016 the CY 2016 application fee is $554 for institutional providers that are

bull Initially enrolling in the Medicare or Medicaid program or the Childrens Health Insurance Program (CHIP)

bull Revalidating their Medicare Medicaid or CHIP enrollmentbull Adding a new Medicare practice locationbull This fee is required with any enrollment application submitted from

January 1 through December 31 2016

64

Medicare MAC-Higlas

bull Effective 142016 CMS has implemented a change to begin netting (offsetting) provider money across workloads within a single organization What this means is that any related providers conducting business in two different workloads (example New York and Maine) will have their money applied to any account receivables (AR) with a remaining balance owed to Medicare within both workloads For example Provider ABC is located in New York and is scheduled to receive a payment of $1000 on todays remittance advice Provider XYZ is related to provider ABC but is located in Maine and has ARs with a balance owed of $200 Provider ABCs $1000 payment will have the $200 applied against provider XYZs ARs resulting in a net payment of $800 This will be reflected on the remittance advice by the same PLB code as seen today for offsets for the $200

65

Two Midnight RuleChange January 1 2016 httpswwwcmsgovMedicareMedicare-Fee-for-Service-PaymentHospitalOutpatientPPSHospital-Outpatient-Regulations-and-Notices-ItemsCMS-1633-FChtml

66

Two Midnight Rulebull However effective January 1 2016 CMS will allow exceptions to the

Two-Midnight Benchmark to be determined on a case-by-case basis by the physician responsible for the care of the beneficiary subject to medical review Said differently Part A payment may be appropriate in some circumstances even though there is no expectation by the physician (or qualified ordering practitioner) of a two-midnight stay and one of the two pre-existing categorical exceptions (CMS ldquoinpatient onlyrdquo list and newly initiated mechanical ventilation) does not apply CMS has indicated that this change to the Two Midnight Rule is in response to stakeholder concern and CMSrsquos continued efforts to develop the most appropriate standard for determining Medicare Part A payment

67

Two Midnight Rulebull A new 42 CFR sect4123(a) provides that a patient is considered an

inpatient of a hospitalhellipif formally admitted as an inpatient pursuant to an order for inpatient admission by a physician or other qualified practitionerhellip The physician orders inpatient status when he or she expects the patient to require a stay that crosses at least 2 midnights[10] Stays expected to be shorter than at least two midnights are generally inappropriate for inpatient admission and inpatient payment under Medicare Part A unless the surgical procedure is specified by Medicare as inpatient only under sect41922(n)[11] The physicians expectationhellipshould be based on such complex medical factors as patient history and comorbidities the severity of signs and symptoms current medical needs and the risk of an adverse event[12] The physician order is part of physician certification of the medical necessity of hospital inpatient serviceshellip[13]

68

InPatient Vs Observation Conthellip

bull Physician certification which begins with an order for inpatient admission requires the physician to certify the reasons for the hospitalization the estimated time the patient will remain in the hospital and plans for post-hospital care if appropriate[14] The certification must be completed signed and documented in the medical record prior to discharge[15]

bull A physicians admission order has no presumptive weight and both the admission order and the physician certification will be evaluated in the context of the evidence in the medical record[16] CMS intends to provide additional information about what evidence in the medical record means in future instructions and manual revisions[17]

69

Two Midnight Rulebull Although the new case-by-case exception appears to be inherently

subjective to a certain extent CMS states that the following factors (among others) would be relevant to determining whether a patient requires inpatient admission under the expanded policy

bull The severity of the signs and symptoms exhibited by the patient bull The medical predictability of something adverse happening to the patient

and bull The need for diagnostic studies that appropriately are outpatient services

(that is their performance does not ordinarily require the patient to remain at the hospital for 24 hours or more)

bull CMS also notes that an inpatient admission (and Part A payment) should be ldquorare and unusualrdquo for minor surgical procedures or other treatment that is expected to keep the patient in the hospital ldquofor only a few hoursrdquo or for a period of time that ldquodoes not span at least overnightrdquo (thus a subset of stays not meeting the Two Midnight Benchmark) CMS indicates that such cases will be prioritized for medical review

70

Health Data Insights amp Medicare Plus Blue

RAC (Retrospective Audits)

71

HDI Health Data amp Med Plus Blue

bull httpwwwhealthdatainsightscombull Blue Cross Medicare Advantage Auditsbull Facilities seeing 10 to 15 requests for Medical Recordsbull In January amp Feburarybull Selected Health Data Insights because they were a premier Audit

Vendor for CMS Recovery Audit Contractor (RAC) demonstration Project They are a audit vendor for Humana

bull Providers not sending Medical Record will get technical denial and lose payments

72

Health Data InSight

bull In 2010 they began the Hospital Reviewbull Medicare Advantage encounter datandashCMS oversight of data integrity OIG

2016bull We will review CMSs oversight of MA encounter data validation and assess

the extent to which CMSrsquos Integrated Data Repository contains timely valid and complete MA encounter data In 2012 CMS began collecting from MA organizations a more comprehensive set of encounter data reflecting the items and services provided to MA plan enrollees Prior CMS and OIG audits have indicated vulnerabilities in the accuracy of data reporting by MA organizations Realizing the potential benefits of the MA encounter data for payment and program integrity oversight is contingent upon the datarsquos completeness validity and timeliness (OEI 03-15-00060 expected issue date FY 2017)

73

Pepper Reports

bull httpswwwpepperresourcesorg

bull Program for Evaluating Payment Patterns Electronic Report ( PEPPER)

bull Annually on or about April 18 2016 will be released

bull Pepper Portal httpssecurefiletmforg

74

CGI Technologies and Solutions Inc httpracbcgicomContactInfoaspxst=1

bull Indiana bull Michiganbull Minnesotabull Illinoisbull Kentuckybull Ohiobull Wisconsin CGI Technologies and Solutions Incbull For general and administrative questions regarding client service outreach

quality assurance or project-specific issues contactbull 1877316RACB (7222)bull Email racbcgicom Tamara Tate Tamaratatecmshhsgovbull 4107861288

75

CGI Federal RAC

bull CGI Federal RAC Region Bbull Email racbcgicombull Phone 1-877-316-RACB (7222)bull Mailing Addressbull Send medical records as followsbull Medical records for Indiana Illinois Kentucky Michigan Ohio Wisconsin

Minnesota DME and Home Health CGI Federal Inc Attn RACB Imaging Dept 1001 Lakeside Ave Suite 800 Cleveland OH 44114

bull If submitting paper records please send medical records as follows For Therapy Reviews CGI Federal Inc Attn RACB Imaging 1001 Lakeside Avenue Suite 800 Cleveland OH 44114

76

How to survive RAC Audit

bull National health expenditures totaled $1679 Billion in 2003 bull National health expenditures were 153 of GROSS Domestic Product

(GDP) in 2003 bull Health care cost increasing at +9 per year bull Doomsday predictions of Medicare running out bull Congressional Action

77

RAC Audits

bull Medicare Modernization Act (MMA) of 2003Mandated a three year audit demonstration project 2005-2008

bull Appoint audit contractors to review Medicare billings for proper coding DRG assignment and medical necessity

bull Audits will apply to all health care providers (hospitals physicians homecare dme etc)

bull Audit contractors to be paid on a contingency basis a percentage of overpayments recovered

78

How Did we get here

bull Overpayments collected due to errors in Medically Unnecessary Services ndash 40

bull Incorrectly Coded ndash 35

bull Other ndash 17

bull NoInsufficient Documentation ndash 8

79

Where are we now

bull All RACrsquos completed required provider outreachAccess to Medicare billing data base given to all RAC RAC review methodology

bull Automated Review-Black amp White Issues (current) bull DRG Validation-complex review (current) bull Complex Review for coding errors (current) bull DME Medical Necessity Reviews ndashcomplex review (calendar year

2010) bull Medical Necessity Reviews-complex review (calendar year 2010)

80

RAC Reviews

bull Responsibilities of the Team Leader bull Must learn each insurance provider participating in a RAC or RAC type

program bull What are their operating rulesbull What is their appeal process Time limits

May be different process for each insurance provider bull Develop a response team

Identify who does what when why and alternate bull individual

Build and develop a manual process Review of computerized system

81

Priority Health SCIO Health Analytics

bull httpswwwsciohealthanalyticscomcore-capabilitiespayment-integrityfacility-auditsskilled-nursing-facility-audits

bull Claims for Medicare members treated at Skilled Nursing Facilities are reimbursed based on the patientsrsquo RUG (Resource Utilization Group) score which is determined using the Minimum Data Set (MDS) Using SCIOs robust analytics claims andor providers that merit review are selected for audit SCIOs auditors conduct a detailed review of the complete medical record and associated MDS to determine if the billed RUG score is valid In the event the review determines that an incorrect RUG score was billed SCIOreg provides the valid score reports the reason the change was necessary and calculates the resulting overpayment

82

+ Cheer

Onward and Upward she shall prevail We are here to care for the residents and provide a wonderful

service

13 83

84

References

bull Priority Healthbull Blue Crossbull Medicaidbull Medicare

85

  • Medicare Mange Care amp Medicaid Changes in the New World We Live In
  • Medicaid
  • NEW Medicaid Change MIlogin
  • Blueprint for Health Innovation MI
  • Provider Enrollment Electronic Signature Form Submission Process MSA 15-54
  • Provider Enrollment Electronic Signature Form Submission Process
  • Provider Enrollment Domain Administrator
  • Medicaid Coinsurance Medicare Advantage
  • Slide Number 9
  • Lawsuit DHS Changes on Caregivers
  • TPL Medicaid Change
  • CHAMPS Member Screen
  • LOC dropping off Not Due to MI Health
  • Issues
  • Secure Email Information
  • Medicaid amp Hospice
  • Medicaid
  • Medicaid Medicare Buy In
  • Manage Medicaid
  • Healthy Michigan Residents
  • Healthy Michigan Medicaid Days
  • McLaren Health Plan
  • Manage Medicaid Plans January 1
  • Slide Number 24
  • MI Health Link
  • MI Health Link 2565
  • What are the Names
  • MI Health Dual Eligible
  • MI Health LOC
  • LOC Medicaid
  • Medicaid Redetermination and MHL Enrollment
  • MI Health Link Portals
  • MI Health Authorizations
  • MI Health Issues
  • LOC 02 dropping MI Health Issues
  • PPA Offset
  • LOCD
  • MI Health Issues-New
  • ACO
  • Families Receiving Letters for ACO
  • ACO What is It
  • Payroll Based Journal
  • Slide Number 43
  • If you submit data manually should you also submit it through the XML
  • Staffing Submission Frequently Asked Questions
  • CMS defines
  • Slide Number 47
  • PBJ Medical Director Role
  • PBJ Medical Director Role
  • Dietician
  • Pharmacy Consultant
  • What are the names for the Medicare Number
  • QTSO
  • Medicare Update
  • CMS Final Rule On Returning Credits
  • Over Payment Rule
  • Questions to MAC
  • Questions to MAC
  • Final Rule on Returning Credits
  • Final Rule on Returning Credits
  • Final Rule on Returning Credits
  • Slide Number 62
  • Medicare Advantage Payors
  • Medicare Provider Enrollment Fee
  • Medicare MAC-Higlas
  • Two Midnight Rule
  • Two Midnight Rule
  • Two Midnight Rule
  • InPatient Vs Observation Conthellip
  • Two Midnight Rule
  • Health Data Insights amp Medicare Plus Blue
  • HDI Health Data amp Med Plus Blue
  • Health Data InSight
  • Pepper Reports
  • CGI Technologies and Solutions Inc httpracbcgicomContactInfoaspxst=1
  • CGI Federal RAC
  • How to survive RAC Audit
  • RAC Audits
  • How Did we get here
  • Where are we now
  • RAC Reviews
  • Priority Health SCIO Health Analytics
  • Cheer
  • References
Page 38: Medicare, Mange Care & Medicaid Changes in the New World we live in

MI Health Issues-New

bull INTEGRATEDCAREmichigangov

bull Email with Insurance Plan issues Case Manager Issues

38

ACOWhat are they

39

Families Receiving Letters for ACO

40

ACO What is It

bull Whats an ACObull Accountable Care Organizations (ACOs) are groups of doctors hospitals

and other health care providers who come together voluntarily to give coordinated high quality care to their Medicare patients

bull The goal of coordinated care is to ensure that patients especially the chronically ill get the right care at the right time while avoiding

unnecessary duplication of services and preventing medical errorsbull When an ACO succeeds both in delivering high-quality care and

spending health care dollars more wisely it will share in the savings it achieves for the Medicare program

41

Payroll Based JournalMandatory on July 1 2016Internet Explorer Version

Internet Explorer v 10 and v 11 will need to operate in compatibility mode

42

43

If you submit data manually should you also submit it through the XML

bull Now you have three options

bull Submit Manually only

bull Submit through the XML only

bull You are able to submit manually and using the XML

44

45

Staffing Submission Frequently Asked Questions

bull ldquoWho are direct care staffrdquo (Who do we submit data for)bull Submission of data for contract staffbull Medical directors and consultantsbull Staff switching roles or tasks throughout the daybull Hours paid vs hours worked ndash Must be verifiablebull Public postingQuality MeasuresFive Starbull Enforcementbull Voluntary submission risks (noneSo register now)

CMS defines

bull 37 job title codes that are required to match employees to the number of hours each direct care function was performed It is important to work with your teams to define the workers that contribute to each job type and how those daily worked hours are recorded and converted to a PBJ submission

bull The PBJ does include some more specific job descriptions than the 671 For example the PBJ system includes job descriptions for RNs with administrative duties and LPNs with administrative duties versus the 671rsquos more general ldquoNurses with Administrative Duties

Page 46

47

PBJ Medical Director Rolebull Physician Leadership

bull Help the facility ensure that patients have appropriate physician coverage and ensure the provision of physician and health care practitioner services and

bull Help the facility develop a process for reviewing physician and health care practitioner credentials

bull Provide specific guidance for physician performance expectations

bull Help the facility ensure that a system is in place for monitoring the performance of health care practitioners and

bull Facilitate feedback to physicians and other health care practitioners on performance and practices

bull Patient Care - Clinical Leadership

bull Participate in administrative decision-making and the development of policies and procedures related to patient care

bull Help develop approve and implement specific clinical practices for the facility to incorporate into its care-related policies and procedures including areas required by laws and regulations

bull Develop procedures and guidance for facility staff regarding contacting practitioners including information gathering and presentation change in condition assessment and when to contact the medical director

bull Review consider andor act upon consultant recommendations as appropriate that affect the facilitys resident care policies and procedures or the care of an individual resident

bull Review respond to and participate in federal state local and other external surveys and inspections and

bull Help review policies and procedures regarding the adequate protection of patients rights advance care planning and other ethical issues48

PBJ Medical Director Rolebull Quality of Care

bull Help the facility establish systems and methods for reviewing the quality and appropriateness of clinical care and other health-related services and provide appropriate feedback and

bull Participate in the facilitys quality improvement process

bull Advise on infection control issues and approve specific infection control policies to be incorporated into facility policies and procedures

bull Help the facility provide a safe and caring environment

bull Help promote employee health and safety and

bull Assist in the development and implementation of employee health policies and programs

bull Education Information and Communication

bull Promote a learning culture within the facility by educating informing and communicating

bull Provide information to help the facility provide care consistent with current standards of practice (defined as approaches to care procedures techniques and treatments that are based on research and or expert consensus and that are contained in current manuals textbooks and or publications or that are accepted adopted or promulgated by recognized organizations or national bodies)

bull Help the facility develop medical information and communication systems with staff patients and families and others

bull Represent the facility to the professional and lay community on medical and patient care issues

bull Maintain knowledge of the changing social regulatory political and economic factors that affect medical and health services of long term care patients and

bull Help establish appropriate relationships with other health care organizations

49

Dietician

bull When the dietary or food services supervisor is other than a registered dietitian the supervisor shall receive routine consultation and technical assistance from a registered dietitian (RD) Consultation time shall not be less than 4 hours every 60 days Additional consultation time may be needed based on the total number of patients incidence of nutrition-related health problems and food service management needs of the facility

50

Pharmacy Consultant

bull At least once per month a licensed pharmacist must perform a drug regimen review (DRR) for each resident The pharmacist must report any irregularities to the attending physician or director of nursing Furthermore these reports must be acted upon

51

What are the names for the Medicare Numberbull OSCAR -Online Survey Certification and Reporting

bull PTAN-PTAN number is assigned by Medicare to authenticate the provider when using the local Medicare Administrative Contractorrsquos (MAC) self-help tools like the IVR internet portal on-line application status etc Provider Transactions Access Number

bull CCN- CMS Certification Number

bull Medicare Number- example 23-

bull All of the above mean the same thing

52

QTSO

bull Once you are logged in the QTSO site bull You will have a state login to the site to access the various site specific

to your facilitybull Installing you will need administrator rights to your network

53

Medicare UpdateWhat are we seeing

54

CMS Final Rule On Returning Credits

httpswwwfederalregistergovarticles201602122016-02789medicare-program-reporting-and-returning-of-overpayments

55

Over Payment Rule

bull Medicare payments for non covered services

bull Medicare payments in excess of the allowable amount for an identified covered service

bull Errors and non reimbursable expenditures in cost reportsbull Duplicate payment

bull Receipt of Medicare payments when another payor had the primary responsibility for payment

56

Questions to MAC

bull Does the Medicare credit balance report change with this overpayment rule

bull No Medicare Credit Balances are still required at the end of each quarter

bull Will that still be the communication to let CMS or the MAC know that we have received an overpayment

bull Submission of Medicare Credit Balance is one form of communicating overpayments to CMS Other methods include submitting a voluntary refund with required claim information or the submission of a standard overpayment form

57

Questions to MAC

bull Will the MAC still deduct from a future RAbull If the recovery of the overpayment includes adjusting a claim then

the overpayment would be netted against future claims payments and reflected on the RA

bull Or will that process change with this new rulebull Process will remain the samebull Will NGS send communication out on thisbull Yes NGS will communicate this once the final rule is communicated

to the MACs by CMS However this could change depending on final CMS instructions

58

Final Rule on Returning Credits

bull Providers will want to immediately update their current policies governing overpayments in order to comply with this new rule which will take effect on March 14 2016

bull Providers and suppliers are required to use reasonable diligence to investigate credible information regarding overpayments through both proactive compliance efforts and reactive investigations

bull If an overpayment is identified then it must be repaid within 60 days An overpayment is identified when a person has or should have through the exercise of reasonable diligence determined that the person received an overpayment and quantified the amount

bull Providers and suppliers have a maximum of 8 months to report and return overpayments ndash up to 6 months to investigate and quantify the overpayment (ie to identify it) and up to 60 days to report and return the overpayment

59

Final Rule on Returning Credits

bull Providers and suppliers are required to report and return all overpayments within a 6-year lookback period

bull The cause and amount of the overpayment is irrelevant for the determination eg it was due to a mistake it was someone elsersquos fault it is a minor amount An overpayment is an overpayment and must be returned

bull Providers and suppliers must make their own determination to which entity to report and return the overpayment ie to the Medicare contractor or using the OIG Self Disclosure Protocol or the CMS Self Referral Disclosure Protocol

60

Final Rule on Returning Credits

bull Providers and suppliers may use the claims adjustment credit balance self-reported refund process or another appropriate process to report and return overpayments At this time there is no standard refund form to use

bull Failure to report and return an overpayment could subject the provider or supplier to False Claims Act liability Civil Monetary Penalties Law liability and exclusion from federal health care programs

61

P S amp R-Accountants will be asking for this information

The location you login into has changed it is now on EIDM EIDM is the acronym for CMS Enterprise Identity Management system which includes Identity Verification Access Management Authorization Assistance Workflow Tools and Identity Lifecycle Management functions

httpswwwcmsgovResearch-Statistics-Data-and-SystemsCMS-Information-TechnologyIACSCMS-Applications-Loginhtml

Go down the page and click on the PSampRSTARThis will take you to the login pagewill look the same as the old P S amp R didChanges Affecting PSampR System Access (Please Read) (posted 01292015)(Updated 5262015)is changingThe system which controls your PSampR user ID (currently IACS)The new system is referred to as EIDMThis will result in a different way to create new accounts or change passwords to existing accountsIf you already have an account in EIDM you may have to use that account for accessing PSampR after the transitionWhen is the change effectiveJune 13 2015What is staying the sameThe internet address for accessing PSampR remains the sameThe PSampR systemfunctionality is NOT changing 62

Medicare Advantage Payorsbull Medicare Advantage payors are pullingdenying payments on admissions if the patient was readmitted within 30 days after discharge The

client believes that the payors systematically denying payments for all readmissions within 30 days They believe this practice denies them due process to address whether the readmissions were justified and not due to a premature discharge of patient The payors seem to want to act like a QIO without having the same accountabilities of the QIO related to determinations of non-payment

bull Heres the QIO process under section 4240 of the QIO Manualbull 4240 - Readmission Review - (Rev 2 07-11-03)bull Readmission review involves admissions to an acute general short-term hospital occurring less than 31 calendar days from the date of

discharge from the same or another acute general short-term hospital (see sect1154(a)(13) and 42 CFR 47671(a)(8)(ii)) Neither the day of discharge nor the day of admission is counted when determining whether a readmission has occurred

bull A Medical Review Proceduresbull Obtain the appropriate medical records for the initial admission and readmission Perform case review on both stays Analyze the cases

specifically to determine whether the patient was prematurely discharged from the first confinement thus causing readmission Perform an analysis of the stay at the first hospital to determine the cause(s) and extent of any problem(s) (eg incomplete or substandard treatment) Consider the information available to the attending physician who discharged the patient from the first confinement Do not base a determination of a premature discharge on information that the physician or provider could not have known or events that could not have been anticipated at the time of discharge

bull Review both the initial admission and the readmission at the same time unless one of them has previously been reviewed In these cases use at a minimum the PRAF case summary of the other admission in addition to the medical record of the case under review

bull C Denialsbull Deny readmissions under the following circumstancesbull If the readmission was medically unnecessarybull If the readmission resulted from a premature discharge from the same hospital orbull If the readmission was a result of circumvention of PPS by the same hospital (see sect4255)bull With the QIO process there is an appeal within the QIO here the hospital is getting no opportunity to challenge the denials

63

Medicare Provider Enrollment Feebull Provider Enrollment Application Fee Amount for CY 2016bull On December 3 CMS issued a notice Provider Enrollment Application

Fee Amount for CY 2016 [CMSndash6066ndashN] Effective January 1 2016 the CY 2016 application fee is $554 for institutional providers that are

bull Initially enrolling in the Medicare or Medicaid program or the Childrens Health Insurance Program (CHIP)

bull Revalidating their Medicare Medicaid or CHIP enrollmentbull Adding a new Medicare practice locationbull This fee is required with any enrollment application submitted from

January 1 through December 31 2016

64

Medicare MAC-Higlas

bull Effective 142016 CMS has implemented a change to begin netting (offsetting) provider money across workloads within a single organization What this means is that any related providers conducting business in two different workloads (example New York and Maine) will have their money applied to any account receivables (AR) with a remaining balance owed to Medicare within both workloads For example Provider ABC is located in New York and is scheduled to receive a payment of $1000 on todays remittance advice Provider XYZ is related to provider ABC but is located in Maine and has ARs with a balance owed of $200 Provider ABCs $1000 payment will have the $200 applied against provider XYZs ARs resulting in a net payment of $800 This will be reflected on the remittance advice by the same PLB code as seen today for offsets for the $200

65

Two Midnight RuleChange January 1 2016 httpswwwcmsgovMedicareMedicare-Fee-for-Service-PaymentHospitalOutpatientPPSHospital-Outpatient-Regulations-and-Notices-ItemsCMS-1633-FChtml

66

Two Midnight Rulebull However effective January 1 2016 CMS will allow exceptions to the

Two-Midnight Benchmark to be determined on a case-by-case basis by the physician responsible for the care of the beneficiary subject to medical review Said differently Part A payment may be appropriate in some circumstances even though there is no expectation by the physician (or qualified ordering practitioner) of a two-midnight stay and one of the two pre-existing categorical exceptions (CMS ldquoinpatient onlyrdquo list and newly initiated mechanical ventilation) does not apply CMS has indicated that this change to the Two Midnight Rule is in response to stakeholder concern and CMSrsquos continued efforts to develop the most appropriate standard for determining Medicare Part A payment

67

Two Midnight Rulebull A new 42 CFR sect4123(a) provides that a patient is considered an

inpatient of a hospitalhellipif formally admitted as an inpatient pursuant to an order for inpatient admission by a physician or other qualified practitionerhellip The physician orders inpatient status when he or she expects the patient to require a stay that crosses at least 2 midnights[10] Stays expected to be shorter than at least two midnights are generally inappropriate for inpatient admission and inpatient payment under Medicare Part A unless the surgical procedure is specified by Medicare as inpatient only under sect41922(n)[11] The physicians expectationhellipshould be based on such complex medical factors as patient history and comorbidities the severity of signs and symptoms current medical needs and the risk of an adverse event[12] The physician order is part of physician certification of the medical necessity of hospital inpatient serviceshellip[13]

68

InPatient Vs Observation Conthellip

bull Physician certification which begins with an order for inpatient admission requires the physician to certify the reasons for the hospitalization the estimated time the patient will remain in the hospital and plans for post-hospital care if appropriate[14] The certification must be completed signed and documented in the medical record prior to discharge[15]

bull A physicians admission order has no presumptive weight and both the admission order and the physician certification will be evaluated in the context of the evidence in the medical record[16] CMS intends to provide additional information about what evidence in the medical record means in future instructions and manual revisions[17]

69

Two Midnight Rulebull Although the new case-by-case exception appears to be inherently

subjective to a certain extent CMS states that the following factors (among others) would be relevant to determining whether a patient requires inpatient admission under the expanded policy

bull The severity of the signs and symptoms exhibited by the patient bull The medical predictability of something adverse happening to the patient

and bull The need for diagnostic studies that appropriately are outpatient services

(that is their performance does not ordinarily require the patient to remain at the hospital for 24 hours or more)

bull CMS also notes that an inpatient admission (and Part A payment) should be ldquorare and unusualrdquo for minor surgical procedures or other treatment that is expected to keep the patient in the hospital ldquofor only a few hoursrdquo or for a period of time that ldquodoes not span at least overnightrdquo (thus a subset of stays not meeting the Two Midnight Benchmark) CMS indicates that such cases will be prioritized for medical review

70

Health Data Insights amp Medicare Plus Blue

RAC (Retrospective Audits)

71

HDI Health Data amp Med Plus Blue

bull httpwwwhealthdatainsightscombull Blue Cross Medicare Advantage Auditsbull Facilities seeing 10 to 15 requests for Medical Recordsbull In January amp Feburarybull Selected Health Data Insights because they were a premier Audit

Vendor for CMS Recovery Audit Contractor (RAC) demonstration Project They are a audit vendor for Humana

bull Providers not sending Medical Record will get technical denial and lose payments

72

Health Data InSight

bull In 2010 they began the Hospital Reviewbull Medicare Advantage encounter datandashCMS oversight of data integrity OIG

2016bull We will review CMSs oversight of MA encounter data validation and assess

the extent to which CMSrsquos Integrated Data Repository contains timely valid and complete MA encounter data In 2012 CMS began collecting from MA organizations a more comprehensive set of encounter data reflecting the items and services provided to MA plan enrollees Prior CMS and OIG audits have indicated vulnerabilities in the accuracy of data reporting by MA organizations Realizing the potential benefits of the MA encounter data for payment and program integrity oversight is contingent upon the datarsquos completeness validity and timeliness (OEI 03-15-00060 expected issue date FY 2017)

73

Pepper Reports

bull httpswwwpepperresourcesorg

bull Program for Evaluating Payment Patterns Electronic Report ( PEPPER)

bull Annually on or about April 18 2016 will be released

bull Pepper Portal httpssecurefiletmforg

74

CGI Technologies and Solutions Inc httpracbcgicomContactInfoaspxst=1

bull Indiana bull Michiganbull Minnesotabull Illinoisbull Kentuckybull Ohiobull Wisconsin CGI Technologies and Solutions Incbull For general and administrative questions regarding client service outreach

quality assurance or project-specific issues contactbull 1877316RACB (7222)bull Email racbcgicom Tamara Tate Tamaratatecmshhsgovbull 4107861288

75

CGI Federal RAC

bull CGI Federal RAC Region Bbull Email racbcgicombull Phone 1-877-316-RACB (7222)bull Mailing Addressbull Send medical records as followsbull Medical records for Indiana Illinois Kentucky Michigan Ohio Wisconsin

Minnesota DME and Home Health CGI Federal Inc Attn RACB Imaging Dept 1001 Lakeside Ave Suite 800 Cleveland OH 44114

bull If submitting paper records please send medical records as follows For Therapy Reviews CGI Federal Inc Attn RACB Imaging 1001 Lakeside Avenue Suite 800 Cleveland OH 44114

76

How to survive RAC Audit

bull National health expenditures totaled $1679 Billion in 2003 bull National health expenditures were 153 of GROSS Domestic Product

(GDP) in 2003 bull Health care cost increasing at +9 per year bull Doomsday predictions of Medicare running out bull Congressional Action

77

RAC Audits

bull Medicare Modernization Act (MMA) of 2003Mandated a three year audit demonstration project 2005-2008

bull Appoint audit contractors to review Medicare billings for proper coding DRG assignment and medical necessity

bull Audits will apply to all health care providers (hospitals physicians homecare dme etc)

bull Audit contractors to be paid on a contingency basis a percentage of overpayments recovered

78

How Did we get here

bull Overpayments collected due to errors in Medically Unnecessary Services ndash 40

bull Incorrectly Coded ndash 35

bull Other ndash 17

bull NoInsufficient Documentation ndash 8

79

Where are we now

bull All RACrsquos completed required provider outreachAccess to Medicare billing data base given to all RAC RAC review methodology

bull Automated Review-Black amp White Issues (current) bull DRG Validation-complex review (current) bull Complex Review for coding errors (current) bull DME Medical Necessity Reviews ndashcomplex review (calendar year

2010) bull Medical Necessity Reviews-complex review (calendar year 2010)

80

RAC Reviews

bull Responsibilities of the Team Leader bull Must learn each insurance provider participating in a RAC or RAC type

program bull What are their operating rulesbull What is their appeal process Time limits

May be different process for each insurance provider bull Develop a response team

Identify who does what when why and alternate bull individual

Build and develop a manual process Review of computerized system

81

Priority Health SCIO Health Analytics

bull httpswwwsciohealthanalyticscomcore-capabilitiespayment-integrityfacility-auditsskilled-nursing-facility-audits

bull Claims for Medicare members treated at Skilled Nursing Facilities are reimbursed based on the patientsrsquo RUG (Resource Utilization Group) score which is determined using the Minimum Data Set (MDS) Using SCIOs robust analytics claims andor providers that merit review are selected for audit SCIOs auditors conduct a detailed review of the complete medical record and associated MDS to determine if the billed RUG score is valid In the event the review determines that an incorrect RUG score was billed SCIOreg provides the valid score reports the reason the change was necessary and calculates the resulting overpayment

82

+ Cheer

Onward and Upward she shall prevail We are here to care for the residents and provide a wonderful

service

13 83

84

References

bull Priority Healthbull Blue Crossbull Medicaidbull Medicare

85

  • Medicare Mange Care amp Medicaid Changes in the New World We Live In
  • Medicaid
  • NEW Medicaid Change MIlogin
  • Blueprint for Health Innovation MI
  • Provider Enrollment Electronic Signature Form Submission Process MSA 15-54
  • Provider Enrollment Electronic Signature Form Submission Process
  • Provider Enrollment Domain Administrator
  • Medicaid Coinsurance Medicare Advantage
  • Slide Number 9
  • Lawsuit DHS Changes on Caregivers
  • TPL Medicaid Change
  • CHAMPS Member Screen
  • LOC dropping off Not Due to MI Health
  • Issues
  • Secure Email Information
  • Medicaid amp Hospice
  • Medicaid
  • Medicaid Medicare Buy In
  • Manage Medicaid
  • Healthy Michigan Residents
  • Healthy Michigan Medicaid Days
  • McLaren Health Plan
  • Manage Medicaid Plans January 1
  • Slide Number 24
  • MI Health Link
  • MI Health Link 2565
  • What are the Names
  • MI Health Dual Eligible
  • MI Health LOC
  • LOC Medicaid
  • Medicaid Redetermination and MHL Enrollment
  • MI Health Link Portals
  • MI Health Authorizations
  • MI Health Issues
  • LOC 02 dropping MI Health Issues
  • PPA Offset
  • LOCD
  • MI Health Issues-New
  • ACO
  • Families Receiving Letters for ACO
  • ACO What is It
  • Payroll Based Journal
  • Slide Number 43
  • If you submit data manually should you also submit it through the XML
  • Staffing Submission Frequently Asked Questions
  • CMS defines
  • Slide Number 47
  • PBJ Medical Director Role
  • PBJ Medical Director Role
  • Dietician
  • Pharmacy Consultant
  • What are the names for the Medicare Number
  • QTSO
  • Medicare Update
  • CMS Final Rule On Returning Credits
  • Over Payment Rule
  • Questions to MAC
  • Questions to MAC
  • Final Rule on Returning Credits
  • Final Rule on Returning Credits
  • Final Rule on Returning Credits
  • Slide Number 62
  • Medicare Advantage Payors
  • Medicare Provider Enrollment Fee
  • Medicare MAC-Higlas
  • Two Midnight Rule
  • Two Midnight Rule
  • Two Midnight Rule
  • InPatient Vs Observation Conthellip
  • Two Midnight Rule
  • Health Data Insights amp Medicare Plus Blue
  • HDI Health Data amp Med Plus Blue
  • Health Data InSight
  • Pepper Reports
  • CGI Technologies and Solutions Inc httpracbcgicomContactInfoaspxst=1
  • CGI Federal RAC
  • How to survive RAC Audit
  • RAC Audits
  • How Did we get here
  • Where are we now
  • RAC Reviews
  • Priority Health SCIO Health Analytics
  • Cheer
  • References
Page 39: Medicare, Mange Care & Medicaid Changes in the New World we live in

ACOWhat are they

39

Families Receiving Letters for ACO

40

ACO What is It

bull Whats an ACObull Accountable Care Organizations (ACOs) are groups of doctors hospitals

and other health care providers who come together voluntarily to give coordinated high quality care to their Medicare patients

bull The goal of coordinated care is to ensure that patients especially the chronically ill get the right care at the right time while avoiding

unnecessary duplication of services and preventing medical errorsbull When an ACO succeeds both in delivering high-quality care and

spending health care dollars more wisely it will share in the savings it achieves for the Medicare program

41

Payroll Based JournalMandatory on July 1 2016Internet Explorer Version

Internet Explorer v 10 and v 11 will need to operate in compatibility mode

42

43

If you submit data manually should you also submit it through the XML

bull Now you have three options

bull Submit Manually only

bull Submit through the XML only

bull You are able to submit manually and using the XML

44

45

Staffing Submission Frequently Asked Questions

bull ldquoWho are direct care staffrdquo (Who do we submit data for)bull Submission of data for contract staffbull Medical directors and consultantsbull Staff switching roles or tasks throughout the daybull Hours paid vs hours worked ndash Must be verifiablebull Public postingQuality MeasuresFive Starbull Enforcementbull Voluntary submission risks (noneSo register now)

CMS defines

bull 37 job title codes that are required to match employees to the number of hours each direct care function was performed It is important to work with your teams to define the workers that contribute to each job type and how those daily worked hours are recorded and converted to a PBJ submission

bull The PBJ does include some more specific job descriptions than the 671 For example the PBJ system includes job descriptions for RNs with administrative duties and LPNs with administrative duties versus the 671rsquos more general ldquoNurses with Administrative Duties

Page 46

47

PBJ Medical Director Rolebull Physician Leadership

bull Help the facility ensure that patients have appropriate physician coverage and ensure the provision of physician and health care practitioner services and

bull Help the facility develop a process for reviewing physician and health care practitioner credentials

bull Provide specific guidance for physician performance expectations

bull Help the facility ensure that a system is in place for monitoring the performance of health care practitioners and

bull Facilitate feedback to physicians and other health care practitioners on performance and practices

bull Patient Care - Clinical Leadership

bull Participate in administrative decision-making and the development of policies and procedures related to patient care

bull Help develop approve and implement specific clinical practices for the facility to incorporate into its care-related policies and procedures including areas required by laws and regulations

bull Develop procedures and guidance for facility staff regarding contacting practitioners including information gathering and presentation change in condition assessment and when to contact the medical director

bull Review consider andor act upon consultant recommendations as appropriate that affect the facilitys resident care policies and procedures or the care of an individual resident

bull Review respond to and participate in federal state local and other external surveys and inspections and

bull Help review policies and procedures regarding the adequate protection of patients rights advance care planning and other ethical issues48

PBJ Medical Director Rolebull Quality of Care

bull Help the facility establish systems and methods for reviewing the quality and appropriateness of clinical care and other health-related services and provide appropriate feedback and

bull Participate in the facilitys quality improvement process

bull Advise on infection control issues and approve specific infection control policies to be incorporated into facility policies and procedures

bull Help the facility provide a safe and caring environment

bull Help promote employee health and safety and

bull Assist in the development and implementation of employee health policies and programs

bull Education Information and Communication

bull Promote a learning culture within the facility by educating informing and communicating

bull Provide information to help the facility provide care consistent with current standards of practice (defined as approaches to care procedures techniques and treatments that are based on research and or expert consensus and that are contained in current manuals textbooks and or publications or that are accepted adopted or promulgated by recognized organizations or national bodies)

bull Help the facility develop medical information and communication systems with staff patients and families and others

bull Represent the facility to the professional and lay community on medical and patient care issues

bull Maintain knowledge of the changing social regulatory political and economic factors that affect medical and health services of long term care patients and

bull Help establish appropriate relationships with other health care organizations

49

Dietician

bull When the dietary or food services supervisor is other than a registered dietitian the supervisor shall receive routine consultation and technical assistance from a registered dietitian (RD) Consultation time shall not be less than 4 hours every 60 days Additional consultation time may be needed based on the total number of patients incidence of nutrition-related health problems and food service management needs of the facility

50

Pharmacy Consultant

bull At least once per month a licensed pharmacist must perform a drug regimen review (DRR) for each resident The pharmacist must report any irregularities to the attending physician or director of nursing Furthermore these reports must be acted upon

51

What are the names for the Medicare Numberbull OSCAR -Online Survey Certification and Reporting

bull PTAN-PTAN number is assigned by Medicare to authenticate the provider when using the local Medicare Administrative Contractorrsquos (MAC) self-help tools like the IVR internet portal on-line application status etc Provider Transactions Access Number

bull CCN- CMS Certification Number

bull Medicare Number- example 23-

bull All of the above mean the same thing

52

QTSO

bull Once you are logged in the QTSO site bull You will have a state login to the site to access the various site specific

to your facilitybull Installing you will need administrator rights to your network

53

Medicare UpdateWhat are we seeing

54

CMS Final Rule On Returning Credits

httpswwwfederalregistergovarticles201602122016-02789medicare-program-reporting-and-returning-of-overpayments

55

Over Payment Rule

bull Medicare payments for non covered services

bull Medicare payments in excess of the allowable amount for an identified covered service

bull Errors and non reimbursable expenditures in cost reportsbull Duplicate payment

bull Receipt of Medicare payments when another payor had the primary responsibility for payment

56

Questions to MAC

bull Does the Medicare credit balance report change with this overpayment rule

bull No Medicare Credit Balances are still required at the end of each quarter

bull Will that still be the communication to let CMS or the MAC know that we have received an overpayment

bull Submission of Medicare Credit Balance is one form of communicating overpayments to CMS Other methods include submitting a voluntary refund with required claim information or the submission of a standard overpayment form

57

Questions to MAC

bull Will the MAC still deduct from a future RAbull If the recovery of the overpayment includes adjusting a claim then

the overpayment would be netted against future claims payments and reflected on the RA

bull Or will that process change with this new rulebull Process will remain the samebull Will NGS send communication out on thisbull Yes NGS will communicate this once the final rule is communicated

to the MACs by CMS However this could change depending on final CMS instructions

58

Final Rule on Returning Credits

bull Providers will want to immediately update their current policies governing overpayments in order to comply with this new rule which will take effect on March 14 2016

bull Providers and suppliers are required to use reasonable diligence to investigate credible information regarding overpayments through both proactive compliance efforts and reactive investigations

bull If an overpayment is identified then it must be repaid within 60 days An overpayment is identified when a person has or should have through the exercise of reasonable diligence determined that the person received an overpayment and quantified the amount

bull Providers and suppliers have a maximum of 8 months to report and return overpayments ndash up to 6 months to investigate and quantify the overpayment (ie to identify it) and up to 60 days to report and return the overpayment

59

Final Rule on Returning Credits

bull Providers and suppliers are required to report and return all overpayments within a 6-year lookback period

bull The cause and amount of the overpayment is irrelevant for the determination eg it was due to a mistake it was someone elsersquos fault it is a minor amount An overpayment is an overpayment and must be returned

bull Providers and suppliers must make their own determination to which entity to report and return the overpayment ie to the Medicare contractor or using the OIG Self Disclosure Protocol or the CMS Self Referral Disclosure Protocol

60

Final Rule on Returning Credits

bull Providers and suppliers may use the claims adjustment credit balance self-reported refund process or another appropriate process to report and return overpayments At this time there is no standard refund form to use

bull Failure to report and return an overpayment could subject the provider or supplier to False Claims Act liability Civil Monetary Penalties Law liability and exclusion from federal health care programs

61

P S amp R-Accountants will be asking for this information

The location you login into has changed it is now on EIDM EIDM is the acronym for CMS Enterprise Identity Management system which includes Identity Verification Access Management Authorization Assistance Workflow Tools and Identity Lifecycle Management functions

httpswwwcmsgovResearch-Statistics-Data-and-SystemsCMS-Information-TechnologyIACSCMS-Applications-Loginhtml

Go down the page and click on the PSampRSTARThis will take you to the login pagewill look the same as the old P S amp R didChanges Affecting PSampR System Access (Please Read) (posted 01292015)(Updated 5262015)is changingThe system which controls your PSampR user ID (currently IACS)The new system is referred to as EIDMThis will result in a different way to create new accounts or change passwords to existing accountsIf you already have an account in EIDM you may have to use that account for accessing PSampR after the transitionWhen is the change effectiveJune 13 2015What is staying the sameThe internet address for accessing PSampR remains the sameThe PSampR systemfunctionality is NOT changing 62

Medicare Advantage Payorsbull Medicare Advantage payors are pullingdenying payments on admissions if the patient was readmitted within 30 days after discharge The

client believes that the payors systematically denying payments for all readmissions within 30 days They believe this practice denies them due process to address whether the readmissions were justified and not due to a premature discharge of patient The payors seem to want to act like a QIO without having the same accountabilities of the QIO related to determinations of non-payment

bull Heres the QIO process under section 4240 of the QIO Manualbull 4240 - Readmission Review - (Rev 2 07-11-03)bull Readmission review involves admissions to an acute general short-term hospital occurring less than 31 calendar days from the date of

discharge from the same or another acute general short-term hospital (see sect1154(a)(13) and 42 CFR 47671(a)(8)(ii)) Neither the day of discharge nor the day of admission is counted when determining whether a readmission has occurred

bull A Medical Review Proceduresbull Obtain the appropriate medical records for the initial admission and readmission Perform case review on both stays Analyze the cases

specifically to determine whether the patient was prematurely discharged from the first confinement thus causing readmission Perform an analysis of the stay at the first hospital to determine the cause(s) and extent of any problem(s) (eg incomplete or substandard treatment) Consider the information available to the attending physician who discharged the patient from the first confinement Do not base a determination of a premature discharge on information that the physician or provider could not have known or events that could not have been anticipated at the time of discharge

bull Review both the initial admission and the readmission at the same time unless one of them has previously been reviewed In these cases use at a minimum the PRAF case summary of the other admission in addition to the medical record of the case under review

bull C Denialsbull Deny readmissions under the following circumstancesbull If the readmission was medically unnecessarybull If the readmission resulted from a premature discharge from the same hospital orbull If the readmission was a result of circumvention of PPS by the same hospital (see sect4255)bull With the QIO process there is an appeal within the QIO here the hospital is getting no opportunity to challenge the denials

63

Medicare Provider Enrollment Feebull Provider Enrollment Application Fee Amount for CY 2016bull On December 3 CMS issued a notice Provider Enrollment Application

Fee Amount for CY 2016 [CMSndash6066ndashN] Effective January 1 2016 the CY 2016 application fee is $554 for institutional providers that are

bull Initially enrolling in the Medicare or Medicaid program or the Childrens Health Insurance Program (CHIP)

bull Revalidating their Medicare Medicaid or CHIP enrollmentbull Adding a new Medicare practice locationbull This fee is required with any enrollment application submitted from

January 1 through December 31 2016

64

Medicare MAC-Higlas

bull Effective 142016 CMS has implemented a change to begin netting (offsetting) provider money across workloads within a single organization What this means is that any related providers conducting business in two different workloads (example New York and Maine) will have their money applied to any account receivables (AR) with a remaining balance owed to Medicare within both workloads For example Provider ABC is located in New York and is scheduled to receive a payment of $1000 on todays remittance advice Provider XYZ is related to provider ABC but is located in Maine and has ARs with a balance owed of $200 Provider ABCs $1000 payment will have the $200 applied against provider XYZs ARs resulting in a net payment of $800 This will be reflected on the remittance advice by the same PLB code as seen today for offsets for the $200

65

Two Midnight RuleChange January 1 2016 httpswwwcmsgovMedicareMedicare-Fee-for-Service-PaymentHospitalOutpatientPPSHospital-Outpatient-Regulations-and-Notices-ItemsCMS-1633-FChtml

66

Two Midnight Rulebull However effective January 1 2016 CMS will allow exceptions to the

Two-Midnight Benchmark to be determined on a case-by-case basis by the physician responsible for the care of the beneficiary subject to medical review Said differently Part A payment may be appropriate in some circumstances even though there is no expectation by the physician (or qualified ordering practitioner) of a two-midnight stay and one of the two pre-existing categorical exceptions (CMS ldquoinpatient onlyrdquo list and newly initiated mechanical ventilation) does not apply CMS has indicated that this change to the Two Midnight Rule is in response to stakeholder concern and CMSrsquos continued efforts to develop the most appropriate standard for determining Medicare Part A payment

67

Two Midnight Rulebull A new 42 CFR sect4123(a) provides that a patient is considered an

inpatient of a hospitalhellipif formally admitted as an inpatient pursuant to an order for inpatient admission by a physician or other qualified practitionerhellip The physician orders inpatient status when he or she expects the patient to require a stay that crosses at least 2 midnights[10] Stays expected to be shorter than at least two midnights are generally inappropriate for inpatient admission and inpatient payment under Medicare Part A unless the surgical procedure is specified by Medicare as inpatient only under sect41922(n)[11] The physicians expectationhellipshould be based on such complex medical factors as patient history and comorbidities the severity of signs and symptoms current medical needs and the risk of an adverse event[12] The physician order is part of physician certification of the medical necessity of hospital inpatient serviceshellip[13]

68

InPatient Vs Observation Conthellip

bull Physician certification which begins with an order for inpatient admission requires the physician to certify the reasons for the hospitalization the estimated time the patient will remain in the hospital and plans for post-hospital care if appropriate[14] The certification must be completed signed and documented in the medical record prior to discharge[15]

bull A physicians admission order has no presumptive weight and both the admission order and the physician certification will be evaluated in the context of the evidence in the medical record[16] CMS intends to provide additional information about what evidence in the medical record means in future instructions and manual revisions[17]

69

Two Midnight Rulebull Although the new case-by-case exception appears to be inherently

subjective to a certain extent CMS states that the following factors (among others) would be relevant to determining whether a patient requires inpatient admission under the expanded policy

bull The severity of the signs and symptoms exhibited by the patient bull The medical predictability of something adverse happening to the patient

and bull The need for diagnostic studies that appropriately are outpatient services

(that is their performance does not ordinarily require the patient to remain at the hospital for 24 hours or more)

bull CMS also notes that an inpatient admission (and Part A payment) should be ldquorare and unusualrdquo for minor surgical procedures or other treatment that is expected to keep the patient in the hospital ldquofor only a few hoursrdquo or for a period of time that ldquodoes not span at least overnightrdquo (thus a subset of stays not meeting the Two Midnight Benchmark) CMS indicates that such cases will be prioritized for medical review

70

Health Data Insights amp Medicare Plus Blue

RAC (Retrospective Audits)

71

HDI Health Data amp Med Plus Blue

bull httpwwwhealthdatainsightscombull Blue Cross Medicare Advantage Auditsbull Facilities seeing 10 to 15 requests for Medical Recordsbull In January amp Feburarybull Selected Health Data Insights because they were a premier Audit

Vendor for CMS Recovery Audit Contractor (RAC) demonstration Project They are a audit vendor for Humana

bull Providers not sending Medical Record will get technical denial and lose payments

72

Health Data InSight

bull In 2010 they began the Hospital Reviewbull Medicare Advantage encounter datandashCMS oversight of data integrity OIG

2016bull We will review CMSs oversight of MA encounter data validation and assess

the extent to which CMSrsquos Integrated Data Repository contains timely valid and complete MA encounter data In 2012 CMS began collecting from MA organizations a more comprehensive set of encounter data reflecting the items and services provided to MA plan enrollees Prior CMS and OIG audits have indicated vulnerabilities in the accuracy of data reporting by MA organizations Realizing the potential benefits of the MA encounter data for payment and program integrity oversight is contingent upon the datarsquos completeness validity and timeliness (OEI 03-15-00060 expected issue date FY 2017)

73

Pepper Reports

bull httpswwwpepperresourcesorg

bull Program for Evaluating Payment Patterns Electronic Report ( PEPPER)

bull Annually on or about April 18 2016 will be released

bull Pepper Portal httpssecurefiletmforg

74

CGI Technologies and Solutions Inc httpracbcgicomContactInfoaspxst=1

bull Indiana bull Michiganbull Minnesotabull Illinoisbull Kentuckybull Ohiobull Wisconsin CGI Technologies and Solutions Incbull For general and administrative questions regarding client service outreach

quality assurance or project-specific issues contactbull 1877316RACB (7222)bull Email racbcgicom Tamara Tate Tamaratatecmshhsgovbull 4107861288

75

CGI Federal RAC

bull CGI Federal RAC Region Bbull Email racbcgicombull Phone 1-877-316-RACB (7222)bull Mailing Addressbull Send medical records as followsbull Medical records for Indiana Illinois Kentucky Michigan Ohio Wisconsin

Minnesota DME and Home Health CGI Federal Inc Attn RACB Imaging Dept 1001 Lakeside Ave Suite 800 Cleveland OH 44114

bull If submitting paper records please send medical records as follows For Therapy Reviews CGI Federal Inc Attn RACB Imaging 1001 Lakeside Avenue Suite 800 Cleveland OH 44114

76

How to survive RAC Audit

bull National health expenditures totaled $1679 Billion in 2003 bull National health expenditures were 153 of GROSS Domestic Product

(GDP) in 2003 bull Health care cost increasing at +9 per year bull Doomsday predictions of Medicare running out bull Congressional Action

77

RAC Audits

bull Medicare Modernization Act (MMA) of 2003Mandated a three year audit demonstration project 2005-2008

bull Appoint audit contractors to review Medicare billings for proper coding DRG assignment and medical necessity

bull Audits will apply to all health care providers (hospitals physicians homecare dme etc)

bull Audit contractors to be paid on a contingency basis a percentage of overpayments recovered

78

How Did we get here

bull Overpayments collected due to errors in Medically Unnecessary Services ndash 40

bull Incorrectly Coded ndash 35

bull Other ndash 17

bull NoInsufficient Documentation ndash 8

79

Where are we now

bull All RACrsquos completed required provider outreachAccess to Medicare billing data base given to all RAC RAC review methodology

bull Automated Review-Black amp White Issues (current) bull DRG Validation-complex review (current) bull Complex Review for coding errors (current) bull DME Medical Necessity Reviews ndashcomplex review (calendar year

2010) bull Medical Necessity Reviews-complex review (calendar year 2010)

80

RAC Reviews

bull Responsibilities of the Team Leader bull Must learn each insurance provider participating in a RAC or RAC type

program bull What are their operating rulesbull What is their appeal process Time limits

May be different process for each insurance provider bull Develop a response team

Identify who does what when why and alternate bull individual

Build and develop a manual process Review of computerized system

81

Priority Health SCIO Health Analytics

bull httpswwwsciohealthanalyticscomcore-capabilitiespayment-integrityfacility-auditsskilled-nursing-facility-audits

bull Claims for Medicare members treated at Skilled Nursing Facilities are reimbursed based on the patientsrsquo RUG (Resource Utilization Group) score which is determined using the Minimum Data Set (MDS) Using SCIOs robust analytics claims andor providers that merit review are selected for audit SCIOs auditors conduct a detailed review of the complete medical record and associated MDS to determine if the billed RUG score is valid In the event the review determines that an incorrect RUG score was billed SCIOreg provides the valid score reports the reason the change was necessary and calculates the resulting overpayment

82

+ Cheer

Onward and Upward she shall prevail We are here to care for the residents and provide a wonderful

service

13 83

84

References

bull Priority Healthbull Blue Crossbull Medicaidbull Medicare

85

  • Medicare Mange Care amp Medicaid Changes in the New World We Live In
  • Medicaid
  • NEW Medicaid Change MIlogin
  • Blueprint for Health Innovation MI
  • Provider Enrollment Electronic Signature Form Submission Process MSA 15-54
  • Provider Enrollment Electronic Signature Form Submission Process
  • Provider Enrollment Domain Administrator
  • Medicaid Coinsurance Medicare Advantage
  • Slide Number 9
  • Lawsuit DHS Changes on Caregivers
  • TPL Medicaid Change
  • CHAMPS Member Screen
  • LOC dropping off Not Due to MI Health
  • Issues
  • Secure Email Information
  • Medicaid amp Hospice
  • Medicaid
  • Medicaid Medicare Buy In
  • Manage Medicaid
  • Healthy Michigan Residents
  • Healthy Michigan Medicaid Days
  • McLaren Health Plan
  • Manage Medicaid Plans January 1
  • Slide Number 24
  • MI Health Link
  • MI Health Link 2565
  • What are the Names
  • MI Health Dual Eligible
  • MI Health LOC
  • LOC Medicaid
  • Medicaid Redetermination and MHL Enrollment
  • MI Health Link Portals
  • MI Health Authorizations
  • MI Health Issues
  • LOC 02 dropping MI Health Issues
  • PPA Offset
  • LOCD
  • MI Health Issues-New
  • ACO
  • Families Receiving Letters for ACO
  • ACO What is It
  • Payroll Based Journal
  • Slide Number 43
  • If you submit data manually should you also submit it through the XML
  • Staffing Submission Frequently Asked Questions
  • CMS defines
  • Slide Number 47
  • PBJ Medical Director Role
  • PBJ Medical Director Role
  • Dietician
  • Pharmacy Consultant
  • What are the names for the Medicare Number
  • QTSO
  • Medicare Update
  • CMS Final Rule On Returning Credits
  • Over Payment Rule
  • Questions to MAC
  • Questions to MAC
  • Final Rule on Returning Credits
  • Final Rule on Returning Credits
  • Final Rule on Returning Credits
  • Slide Number 62
  • Medicare Advantage Payors
  • Medicare Provider Enrollment Fee
  • Medicare MAC-Higlas
  • Two Midnight Rule
  • Two Midnight Rule
  • Two Midnight Rule
  • InPatient Vs Observation Conthellip
  • Two Midnight Rule
  • Health Data Insights amp Medicare Plus Blue
  • HDI Health Data amp Med Plus Blue
  • Health Data InSight
  • Pepper Reports
  • CGI Technologies and Solutions Inc httpracbcgicomContactInfoaspxst=1
  • CGI Federal RAC
  • How to survive RAC Audit
  • RAC Audits
  • How Did we get here
  • Where are we now
  • RAC Reviews
  • Priority Health SCIO Health Analytics
  • Cheer
  • References
Page 40: Medicare, Mange Care & Medicaid Changes in the New World we live in

Families Receiving Letters for ACO

40

ACO What is It

bull Whats an ACObull Accountable Care Organizations (ACOs) are groups of doctors hospitals

and other health care providers who come together voluntarily to give coordinated high quality care to their Medicare patients

bull The goal of coordinated care is to ensure that patients especially the chronically ill get the right care at the right time while avoiding

unnecessary duplication of services and preventing medical errorsbull When an ACO succeeds both in delivering high-quality care and

spending health care dollars more wisely it will share in the savings it achieves for the Medicare program

41

Payroll Based JournalMandatory on July 1 2016Internet Explorer Version

Internet Explorer v 10 and v 11 will need to operate in compatibility mode

42

43

If you submit data manually should you also submit it through the XML

bull Now you have three options

bull Submit Manually only

bull Submit through the XML only

bull You are able to submit manually and using the XML

44

45

Staffing Submission Frequently Asked Questions

bull ldquoWho are direct care staffrdquo (Who do we submit data for)bull Submission of data for contract staffbull Medical directors and consultantsbull Staff switching roles or tasks throughout the daybull Hours paid vs hours worked ndash Must be verifiablebull Public postingQuality MeasuresFive Starbull Enforcementbull Voluntary submission risks (noneSo register now)

CMS defines

bull 37 job title codes that are required to match employees to the number of hours each direct care function was performed It is important to work with your teams to define the workers that contribute to each job type and how those daily worked hours are recorded and converted to a PBJ submission

bull The PBJ does include some more specific job descriptions than the 671 For example the PBJ system includes job descriptions for RNs with administrative duties and LPNs with administrative duties versus the 671rsquos more general ldquoNurses with Administrative Duties

Page 46

47

PBJ Medical Director Rolebull Physician Leadership

bull Help the facility ensure that patients have appropriate physician coverage and ensure the provision of physician and health care practitioner services and

bull Help the facility develop a process for reviewing physician and health care practitioner credentials

bull Provide specific guidance for physician performance expectations

bull Help the facility ensure that a system is in place for monitoring the performance of health care practitioners and

bull Facilitate feedback to physicians and other health care practitioners on performance and practices

bull Patient Care - Clinical Leadership

bull Participate in administrative decision-making and the development of policies and procedures related to patient care

bull Help develop approve and implement specific clinical practices for the facility to incorporate into its care-related policies and procedures including areas required by laws and regulations

bull Develop procedures and guidance for facility staff regarding contacting practitioners including information gathering and presentation change in condition assessment and when to contact the medical director

bull Review consider andor act upon consultant recommendations as appropriate that affect the facilitys resident care policies and procedures or the care of an individual resident

bull Review respond to and participate in federal state local and other external surveys and inspections and

bull Help review policies and procedures regarding the adequate protection of patients rights advance care planning and other ethical issues48

PBJ Medical Director Rolebull Quality of Care

bull Help the facility establish systems and methods for reviewing the quality and appropriateness of clinical care and other health-related services and provide appropriate feedback and

bull Participate in the facilitys quality improvement process

bull Advise on infection control issues and approve specific infection control policies to be incorporated into facility policies and procedures

bull Help the facility provide a safe and caring environment

bull Help promote employee health and safety and

bull Assist in the development and implementation of employee health policies and programs

bull Education Information and Communication

bull Promote a learning culture within the facility by educating informing and communicating

bull Provide information to help the facility provide care consistent with current standards of practice (defined as approaches to care procedures techniques and treatments that are based on research and or expert consensus and that are contained in current manuals textbooks and or publications or that are accepted adopted or promulgated by recognized organizations or national bodies)

bull Help the facility develop medical information and communication systems with staff patients and families and others

bull Represent the facility to the professional and lay community on medical and patient care issues

bull Maintain knowledge of the changing social regulatory political and economic factors that affect medical and health services of long term care patients and

bull Help establish appropriate relationships with other health care organizations

49

Dietician

bull When the dietary or food services supervisor is other than a registered dietitian the supervisor shall receive routine consultation and technical assistance from a registered dietitian (RD) Consultation time shall not be less than 4 hours every 60 days Additional consultation time may be needed based on the total number of patients incidence of nutrition-related health problems and food service management needs of the facility

50

Pharmacy Consultant

bull At least once per month a licensed pharmacist must perform a drug regimen review (DRR) for each resident The pharmacist must report any irregularities to the attending physician or director of nursing Furthermore these reports must be acted upon

51

What are the names for the Medicare Numberbull OSCAR -Online Survey Certification and Reporting

bull PTAN-PTAN number is assigned by Medicare to authenticate the provider when using the local Medicare Administrative Contractorrsquos (MAC) self-help tools like the IVR internet portal on-line application status etc Provider Transactions Access Number

bull CCN- CMS Certification Number

bull Medicare Number- example 23-

bull All of the above mean the same thing

52

QTSO

bull Once you are logged in the QTSO site bull You will have a state login to the site to access the various site specific

to your facilitybull Installing you will need administrator rights to your network

53

Medicare UpdateWhat are we seeing

54

CMS Final Rule On Returning Credits

httpswwwfederalregistergovarticles201602122016-02789medicare-program-reporting-and-returning-of-overpayments

55

Over Payment Rule

bull Medicare payments for non covered services

bull Medicare payments in excess of the allowable amount for an identified covered service

bull Errors and non reimbursable expenditures in cost reportsbull Duplicate payment

bull Receipt of Medicare payments when another payor had the primary responsibility for payment

56

Questions to MAC

bull Does the Medicare credit balance report change with this overpayment rule

bull No Medicare Credit Balances are still required at the end of each quarter

bull Will that still be the communication to let CMS or the MAC know that we have received an overpayment

bull Submission of Medicare Credit Balance is one form of communicating overpayments to CMS Other methods include submitting a voluntary refund with required claim information or the submission of a standard overpayment form

57

Questions to MAC

bull Will the MAC still deduct from a future RAbull If the recovery of the overpayment includes adjusting a claim then

the overpayment would be netted against future claims payments and reflected on the RA

bull Or will that process change with this new rulebull Process will remain the samebull Will NGS send communication out on thisbull Yes NGS will communicate this once the final rule is communicated

to the MACs by CMS However this could change depending on final CMS instructions

58

Final Rule on Returning Credits

bull Providers will want to immediately update their current policies governing overpayments in order to comply with this new rule which will take effect on March 14 2016

bull Providers and suppliers are required to use reasonable diligence to investigate credible information regarding overpayments through both proactive compliance efforts and reactive investigations

bull If an overpayment is identified then it must be repaid within 60 days An overpayment is identified when a person has or should have through the exercise of reasonable diligence determined that the person received an overpayment and quantified the amount

bull Providers and suppliers have a maximum of 8 months to report and return overpayments ndash up to 6 months to investigate and quantify the overpayment (ie to identify it) and up to 60 days to report and return the overpayment

59

Final Rule on Returning Credits

bull Providers and suppliers are required to report and return all overpayments within a 6-year lookback period

bull The cause and amount of the overpayment is irrelevant for the determination eg it was due to a mistake it was someone elsersquos fault it is a minor amount An overpayment is an overpayment and must be returned

bull Providers and suppliers must make their own determination to which entity to report and return the overpayment ie to the Medicare contractor or using the OIG Self Disclosure Protocol or the CMS Self Referral Disclosure Protocol

60

Final Rule on Returning Credits

bull Providers and suppliers may use the claims adjustment credit balance self-reported refund process or another appropriate process to report and return overpayments At this time there is no standard refund form to use

bull Failure to report and return an overpayment could subject the provider or supplier to False Claims Act liability Civil Monetary Penalties Law liability and exclusion from federal health care programs

61

P S amp R-Accountants will be asking for this information

The location you login into has changed it is now on EIDM EIDM is the acronym for CMS Enterprise Identity Management system which includes Identity Verification Access Management Authorization Assistance Workflow Tools and Identity Lifecycle Management functions

httpswwwcmsgovResearch-Statistics-Data-and-SystemsCMS-Information-TechnologyIACSCMS-Applications-Loginhtml

Go down the page and click on the PSampRSTARThis will take you to the login pagewill look the same as the old P S amp R didChanges Affecting PSampR System Access (Please Read) (posted 01292015)(Updated 5262015)is changingThe system which controls your PSampR user ID (currently IACS)The new system is referred to as EIDMThis will result in a different way to create new accounts or change passwords to existing accountsIf you already have an account in EIDM you may have to use that account for accessing PSampR after the transitionWhen is the change effectiveJune 13 2015What is staying the sameThe internet address for accessing PSampR remains the sameThe PSampR systemfunctionality is NOT changing 62

Medicare Advantage Payorsbull Medicare Advantage payors are pullingdenying payments on admissions if the patient was readmitted within 30 days after discharge The

client believes that the payors systematically denying payments for all readmissions within 30 days They believe this practice denies them due process to address whether the readmissions were justified and not due to a premature discharge of patient The payors seem to want to act like a QIO without having the same accountabilities of the QIO related to determinations of non-payment

bull Heres the QIO process under section 4240 of the QIO Manualbull 4240 - Readmission Review - (Rev 2 07-11-03)bull Readmission review involves admissions to an acute general short-term hospital occurring less than 31 calendar days from the date of

discharge from the same or another acute general short-term hospital (see sect1154(a)(13) and 42 CFR 47671(a)(8)(ii)) Neither the day of discharge nor the day of admission is counted when determining whether a readmission has occurred

bull A Medical Review Proceduresbull Obtain the appropriate medical records for the initial admission and readmission Perform case review on both stays Analyze the cases

specifically to determine whether the patient was prematurely discharged from the first confinement thus causing readmission Perform an analysis of the stay at the first hospital to determine the cause(s) and extent of any problem(s) (eg incomplete or substandard treatment) Consider the information available to the attending physician who discharged the patient from the first confinement Do not base a determination of a premature discharge on information that the physician or provider could not have known or events that could not have been anticipated at the time of discharge

bull Review both the initial admission and the readmission at the same time unless one of them has previously been reviewed In these cases use at a minimum the PRAF case summary of the other admission in addition to the medical record of the case under review

bull C Denialsbull Deny readmissions under the following circumstancesbull If the readmission was medically unnecessarybull If the readmission resulted from a premature discharge from the same hospital orbull If the readmission was a result of circumvention of PPS by the same hospital (see sect4255)bull With the QIO process there is an appeal within the QIO here the hospital is getting no opportunity to challenge the denials

63

Medicare Provider Enrollment Feebull Provider Enrollment Application Fee Amount for CY 2016bull On December 3 CMS issued a notice Provider Enrollment Application

Fee Amount for CY 2016 [CMSndash6066ndashN] Effective January 1 2016 the CY 2016 application fee is $554 for institutional providers that are

bull Initially enrolling in the Medicare or Medicaid program or the Childrens Health Insurance Program (CHIP)

bull Revalidating their Medicare Medicaid or CHIP enrollmentbull Adding a new Medicare practice locationbull This fee is required with any enrollment application submitted from

January 1 through December 31 2016

64

Medicare MAC-Higlas

bull Effective 142016 CMS has implemented a change to begin netting (offsetting) provider money across workloads within a single organization What this means is that any related providers conducting business in two different workloads (example New York and Maine) will have their money applied to any account receivables (AR) with a remaining balance owed to Medicare within both workloads For example Provider ABC is located in New York and is scheduled to receive a payment of $1000 on todays remittance advice Provider XYZ is related to provider ABC but is located in Maine and has ARs with a balance owed of $200 Provider ABCs $1000 payment will have the $200 applied against provider XYZs ARs resulting in a net payment of $800 This will be reflected on the remittance advice by the same PLB code as seen today for offsets for the $200

65

Two Midnight RuleChange January 1 2016 httpswwwcmsgovMedicareMedicare-Fee-for-Service-PaymentHospitalOutpatientPPSHospital-Outpatient-Regulations-and-Notices-ItemsCMS-1633-FChtml

66

Two Midnight Rulebull However effective January 1 2016 CMS will allow exceptions to the

Two-Midnight Benchmark to be determined on a case-by-case basis by the physician responsible for the care of the beneficiary subject to medical review Said differently Part A payment may be appropriate in some circumstances even though there is no expectation by the physician (or qualified ordering practitioner) of a two-midnight stay and one of the two pre-existing categorical exceptions (CMS ldquoinpatient onlyrdquo list and newly initiated mechanical ventilation) does not apply CMS has indicated that this change to the Two Midnight Rule is in response to stakeholder concern and CMSrsquos continued efforts to develop the most appropriate standard for determining Medicare Part A payment

67

Two Midnight Rulebull A new 42 CFR sect4123(a) provides that a patient is considered an

inpatient of a hospitalhellipif formally admitted as an inpatient pursuant to an order for inpatient admission by a physician or other qualified practitionerhellip The physician orders inpatient status when he or she expects the patient to require a stay that crosses at least 2 midnights[10] Stays expected to be shorter than at least two midnights are generally inappropriate for inpatient admission and inpatient payment under Medicare Part A unless the surgical procedure is specified by Medicare as inpatient only under sect41922(n)[11] The physicians expectationhellipshould be based on such complex medical factors as patient history and comorbidities the severity of signs and symptoms current medical needs and the risk of an adverse event[12] The physician order is part of physician certification of the medical necessity of hospital inpatient serviceshellip[13]

68

InPatient Vs Observation Conthellip

bull Physician certification which begins with an order for inpatient admission requires the physician to certify the reasons for the hospitalization the estimated time the patient will remain in the hospital and plans for post-hospital care if appropriate[14] The certification must be completed signed and documented in the medical record prior to discharge[15]

bull A physicians admission order has no presumptive weight and both the admission order and the physician certification will be evaluated in the context of the evidence in the medical record[16] CMS intends to provide additional information about what evidence in the medical record means in future instructions and manual revisions[17]

69

Two Midnight Rulebull Although the new case-by-case exception appears to be inherently

subjective to a certain extent CMS states that the following factors (among others) would be relevant to determining whether a patient requires inpatient admission under the expanded policy

bull The severity of the signs and symptoms exhibited by the patient bull The medical predictability of something adverse happening to the patient

and bull The need for diagnostic studies that appropriately are outpatient services

(that is their performance does not ordinarily require the patient to remain at the hospital for 24 hours or more)

bull CMS also notes that an inpatient admission (and Part A payment) should be ldquorare and unusualrdquo for minor surgical procedures or other treatment that is expected to keep the patient in the hospital ldquofor only a few hoursrdquo or for a period of time that ldquodoes not span at least overnightrdquo (thus a subset of stays not meeting the Two Midnight Benchmark) CMS indicates that such cases will be prioritized for medical review

70

Health Data Insights amp Medicare Plus Blue

RAC (Retrospective Audits)

71

HDI Health Data amp Med Plus Blue

bull httpwwwhealthdatainsightscombull Blue Cross Medicare Advantage Auditsbull Facilities seeing 10 to 15 requests for Medical Recordsbull In January amp Feburarybull Selected Health Data Insights because they were a premier Audit

Vendor for CMS Recovery Audit Contractor (RAC) demonstration Project They are a audit vendor for Humana

bull Providers not sending Medical Record will get technical denial and lose payments

72

Health Data InSight

bull In 2010 they began the Hospital Reviewbull Medicare Advantage encounter datandashCMS oversight of data integrity OIG

2016bull We will review CMSs oversight of MA encounter data validation and assess

the extent to which CMSrsquos Integrated Data Repository contains timely valid and complete MA encounter data In 2012 CMS began collecting from MA organizations a more comprehensive set of encounter data reflecting the items and services provided to MA plan enrollees Prior CMS and OIG audits have indicated vulnerabilities in the accuracy of data reporting by MA organizations Realizing the potential benefits of the MA encounter data for payment and program integrity oversight is contingent upon the datarsquos completeness validity and timeliness (OEI 03-15-00060 expected issue date FY 2017)

73

Pepper Reports

bull httpswwwpepperresourcesorg

bull Program for Evaluating Payment Patterns Electronic Report ( PEPPER)

bull Annually on or about April 18 2016 will be released

bull Pepper Portal httpssecurefiletmforg

74

CGI Technologies and Solutions Inc httpracbcgicomContactInfoaspxst=1

bull Indiana bull Michiganbull Minnesotabull Illinoisbull Kentuckybull Ohiobull Wisconsin CGI Technologies and Solutions Incbull For general and administrative questions regarding client service outreach

quality assurance or project-specific issues contactbull 1877316RACB (7222)bull Email racbcgicom Tamara Tate Tamaratatecmshhsgovbull 4107861288

75

CGI Federal RAC

bull CGI Federal RAC Region Bbull Email racbcgicombull Phone 1-877-316-RACB (7222)bull Mailing Addressbull Send medical records as followsbull Medical records for Indiana Illinois Kentucky Michigan Ohio Wisconsin

Minnesota DME and Home Health CGI Federal Inc Attn RACB Imaging Dept 1001 Lakeside Ave Suite 800 Cleveland OH 44114

bull If submitting paper records please send medical records as follows For Therapy Reviews CGI Federal Inc Attn RACB Imaging 1001 Lakeside Avenue Suite 800 Cleveland OH 44114

76

How to survive RAC Audit

bull National health expenditures totaled $1679 Billion in 2003 bull National health expenditures were 153 of GROSS Domestic Product

(GDP) in 2003 bull Health care cost increasing at +9 per year bull Doomsday predictions of Medicare running out bull Congressional Action

77

RAC Audits

bull Medicare Modernization Act (MMA) of 2003Mandated a three year audit demonstration project 2005-2008

bull Appoint audit contractors to review Medicare billings for proper coding DRG assignment and medical necessity

bull Audits will apply to all health care providers (hospitals physicians homecare dme etc)

bull Audit contractors to be paid on a contingency basis a percentage of overpayments recovered

78

How Did we get here

bull Overpayments collected due to errors in Medically Unnecessary Services ndash 40

bull Incorrectly Coded ndash 35

bull Other ndash 17

bull NoInsufficient Documentation ndash 8

79

Where are we now

bull All RACrsquos completed required provider outreachAccess to Medicare billing data base given to all RAC RAC review methodology

bull Automated Review-Black amp White Issues (current) bull DRG Validation-complex review (current) bull Complex Review for coding errors (current) bull DME Medical Necessity Reviews ndashcomplex review (calendar year

2010) bull Medical Necessity Reviews-complex review (calendar year 2010)

80

RAC Reviews

bull Responsibilities of the Team Leader bull Must learn each insurance provider participating in a RAC or RAC type

program bull What are their operating rulesbull What is their appeal process Time limits

May be different process for each insurance provider bull Develop a response team

Identify who does what when why and alternate bull individual

Build and develop a manual process Review of computerized system

81

Priority Health SCIO Health Analytics

bull httpswwwsciohealthanalyticscomcore-capabilitiespayment-integrityfacility-auditsskilled-nursing-facility-audits

bull Claims for Medicare members treated at Skilled Nursing Facilities are reimbursed based on the patientsrsquo RUG (Resource Utilization Group) score which is determined using the Minimum Data Set (MDS) Using SCIOs robust analytics claims andor providers that merit review are selected for audit SCIOs auditors conduct a detailed review of the complete medical record and associated MDS to determine if the billed RUG score is valid In the event the review determines that an incorrect RUG score was billed SCIOreg provides the valid score reports the reason the change was necessary and calculates the resulting overpayment

82

+ Cheer

Onward and Upward she shall prevail We are here to care for the residents and provide a wonderful

service

13 83

84

References

bull Priority Healthbull Blue Crossbull Medicaidbull Medicare

85

  • Medicare Mange Care amp Medicaid Changes in the New World We Live In
  • Medicaid
  • NEW Medicaid Change MIlogin
  • Blueprint for Health Innovation MI
  • Provider Enrollment Electronic Signature Form Submission Process MSA 15-54
  • Provider Enrollment Electronic Signature Form Submission Process
  • Provider Enrollment Domain Administrator
  • Medicaid Coinsurance Medicare Advantage
  • Slide Number 9
  • Lawsuit DHS Changes on Caregivers
  • TPL Medicaid Change
  • CHAMPS Member Screen
  • LOC dropping off Not Due to MI Health
  • Issues
  • Secure Email Information
  • Medicaid amp Hospice
  • Medicaid
  • Medicaid Medicare Buy In
  • Manage Medicaid
  • Healthy Michigan Residents
  • Healthy Michigan Medicaid Days
  • McLaren Health Plan
  • Manage Medicaid Plans January 1
  • Slide Number 24
  • MI Health Link
  • MI Health Link 2565
  • What are the Names
  • MI Health Dual Eligible
  • MI Health LOC
  • LOC Medicaid
  • Medicaid Redetermination and MHL Enrollment
  • MI Health Link Portals
  • MI Health Authorizations
  • MI Health Issues
  • LOC 02 dropping MI Health Issues
  • PPA Offset
  • LOCD
  • MI Health Issues-New
  • ACO
  • Families Receiving Letters for ACO
  • ACO What is It
  • Payroll Based Journal
  • Slide Number 43
  • If you submit data manually should you also submit it through the XML
  • Staffing Submission Frequently Asked Questions
  • CMS defines
  • Slide Number 47
  • PBJ Medical Director Role
  • PBJ Medical Director Role
  • Dietician
  • Pharmacy Consultant
  • What are the names for the Medicare Number
  • QTSO
  • Medicare Update
  • CMS Final Rule On Returning Credits
  • Over Payment Rule
  • Questions to MAC
  • Questions to MAC
  • Final Rule on Returning Credits
  • Final Rule on Returning Credits
  • Final Rule on Returning Credits
  • Slide Number 62
  • Medicare Advantage Payors
  • Medicare Provider Enrollment Fee
  • Medicare MAC-Higlas
  • Two Midnight Rule
  • Two Midnight Rule
  • Two Midnight Rule
  • InPatient Vs Observation Conthellip
  • Two Midnight Rule
  • Health Data Insights amp Medicare Plus Blue
  • HDI Health Data amp Med Plus Blue
  • Health Data InSight
  • Pepper Reports
  • CGI Technologies and Solutions Inc httpracbcgicomContactInfoaspxst=1
  • CGI Federal RAC
  • How to survive RAC Audit
  • RAC Audits
  • How Did we get here
  • Where are we now
  • RAC Reviews
  • Priority Health SCIO Health Analytics
  • Cheer
  • References
Page 41: Medicare, Mange Care & Medicaid Changes in the New World we live in

ACO What is It

bull Whats an ACObull Accountable Care Organizations (ACOs) are groups of doctors hospitals

and other health care providers who come together voluntarily to give coordinated high quality care to their Medicare patients

bull The goal of coordinated care is to ensure that patients especially the chronically ill get the right care at the right time while avoiding

unnecessary duplication of services and preventing medical errorsbull When an ACO succeeds both in delivering high-quality care and

spending health care dollars more wisely it will share in the savings it achieves for the Medicare program

41

Payroll Based JournalMandatory on July 1 2016Internet Explorer Version

Internet Explorer v 10 and v 11 will need to operate in compatibility mode

42

43

If you submit data manually should you also submit it through the XML

bull Now you have three options

bull Submit Manually only

bull Submit through the XML only

bull You are able to submit manually and using the XML

44

45

Staffing Submission Frequently Asked Questions

bull ldquoWho are direct care staffrdquo (Who do we submit data for)bull Submission of data for contract staffbull Medical directors and consultantsbull Staff switching roles or tasks throughout the daybull Hours paid vs hours worked ndash Must be verifiablebull Public postingQuality MeasuresFive Starbull Enforcementbull Voluntary submission risks (noneSo register now)

CMS defines

bull 37 job title codes that are required to match employees to the number of hours each direct care function was performed It is important to work with your teams to define the workers that contribute to each job type and how those daily worked hours are recorded and converted to a PBJ submission

bull The PBJ does include some more specific job descriptions than the 671 For example the PBJ system includes job descriptions for RNs with administrative duties and LPNs with administrative duties versus the 671rsquos more general ldquoNurses with Administrative Duties

Page 46

47

PBJ Medical Director Rolebull Physician Leadership

bull Help the facility ensure that patients have appropriate physician coverage and ensure the provision of physician and health care practitioner services and

bull Help the facility develop a process for reviewing physician and health care practitioner credentials

bull Provide specific guidance for physician performance expectations

bull Help the facility ensure that a system is in place for monitoring the performance of health care practitioners and

bull Facilitate feedback to physicians and other health care practitioners on performance and practices

bull Patient Care - Clinical Leadership

bull Participate in administrative decision-making and the development of policies and procedures related to patient care

bull Help develop approve and implement specific clinical practices for the facility to incorporate into its care-related policies and procedures including areas required by laws and regulations

bull Develop procedures and guidance for facility staff regarding contacting practitioners including information gathering and presentation change in condition assessment and when to contact the medical director

bull Review consider andor act upon consultant recommendations as appropriate that affect the facilitys resident care policies and procedures or the care of an individual resident

bull Review respond to and participate in federal state local and other external surveys and inspections and

bull Help review policies and procedures regarding the adequate protection of patients rights advance care planning and other ethical issues48

PBJ Medical Director Rolebull Quality of Care

bull Help the facility establish systems and methods for reviewing the quality and appropriateness of clinical care and other health-related services and provide appropriate feedback and

bull Participate in the facilitys quality improvement process

bull Advise on infection control issues and approve specific infection control policies to be incorporated into facility policies and procedures

bull Help the facility provide a safe and caring environment

bull Help promote employee health and safety and

bull Assist in the development and implementation of employee health policies and programs

bull Education Information and Communication

bull Promote a learning culture within the facility by educating informing and communicating

bull Provide information to help the facility provide care consistent with current standards of practice (defined as approaches to care procedures techniques and treatments that are based on research and or expert consensus and that are contained in current manuals textbooks and or publications or that are accepted adopted or promulgated by recognized organizations or national bodies)

bull Help the facility develop medical information and communication systems with staff patients and families and others

bull Represent the facility to the professional and lay community on medical and patient care issues

bull Maintain knowledge of the changing social regulatory political and economic factors that affect medical and health services of long term care patients and

bull Help establish appropriate relationships with other health care organizations

49

Dietician

bull When the dietary or food services supervisor is other than a registered dietitian the supervisor shall receive routine consultation and technical assistance from a registered dietitian (RD) Consultation time shall not be less than 4 hours every 60 days Additional consultation time may be needed based on the total number of patients incidence of nutrition-related health problems and food service management needs of the facility

50

Pharmacy Consultant

bull At least once per month a licensed pharmacist must perform a drug regimen review (DRR) for each resident The pharmacist must report any irregularities to the attending physician or director of nursing Furthermore these reports must be acted upon

51

What are the names for the Medicare Numberbull OSCAR -Online Survey Certification and Reporting

bull PTAN-PTAN number is assigned by Medicare to authenticate the provider when using the local Medicare Administrative Contractorrsquos (MAC) self-help tools like the IVR internet portal on-line application status etc Provider Transactions Access Number

bull CCN- CMS Certification Number

bull Medicare Number- example 23-

bull All of the above mean the same thing

52

QTSO

bull Once you are logged in the QTSO site bull You will have a state login to the site to access the various site specific

to your facilitybull Installing you will need administrator rights to your network

53

Medicare UpdateWhat are we seeing

54

CMS Final Rule On Returning Credits

httpswwwfederalregistergovarticles201602122016-02789medicare-program-reporting-and-returning-of-overpayments

55

Over Payment Rule

bull Medicare payments for non covered services

bull Medicare payments in excess of the allowable amount for an identified covered service

bull Errors and non reimbursable expenditures in cost reportsbull Duplicate payment

bull Receipt of Medicare payments when another payor had the primary responsibility for payment

56

Questions to MAC

bull Does the Medicare credit balance report change with this overpayment rule

bull No Medicare Credit Balances are still required at the end of each quarter

bull Will that still be the communication to let CMS or the MAC know that we have received an overpayment

bull Submission of Medicare Credit Balance is one form of communicating overpayments to CMS Other methods include submitting a voluntary refund with required claim information or the submission of a standard overpayment form

57

Questions to MAC

bull Will the MAC still deduct from a future RAbull If the recovery of the overpayment includes adjusting a claim then

the overpayment would be netted against future claims payments and reflected on the RA

bull Or will that process change with this new rulebull Process will remain the samebull Will NGS send communication out on thisbull Yes NGS will communicate this once the final rule is communicated

to the MACs by CMS However this could change depending on final CMS instructions

58

Final Rule on Returning Credits

bull Providers will want to immediately update their current policies governing overpayments in order to comply with this new rule which will take effect on March 14 2016

bull Providers and suppliers are required to use reasonable diligence to investigate credible information regarding overpayments through both proactive compliance efforts and reactive investigations

bull If an overpayment is identified then it must be repaid within 60 days An overpayment is identified when a person has or should have through the exercise of reasonable diligence determined that the person received an overpayment and quantified the amount

bull Providers and suppliers have a maximum of 8 months to report and return overpayments ndash up to 6 months to investigate and quantify the overpayment (ie to identify it) and up to 60 days to report and return the overpayment

59

Final Rule on Returning Credits

bull Providers and suppliers are required to report and return all overpayments within a 6-year lookback period

bull The cause and amount of the overpayment is irrelevant for the determination eg it was due to a mistake it was someone elsersquos fault it is a minor amount An overpayment is an overpayment and must be returned

bull Providers and suppliers must make their own determination to which entity to report and return the overpayment ie to the Medicare contractor or using the OIG Self Disclosure Protocol or the CMS Self Referral Disclosure Protocol

60

Final Rule on Returning Credits

bull Providers and suppliers may use the claims adjustment credit balance self-reported refund process or another appropriate process to report and return overpayments At this time there is no standard refund form to use

bull Failure to report and return an overpayment could subject the provider or supplier to False Claims Act liability Civil Monetary Penalties Law liability and exclusion from federal health care programs

61

P S amp R-Accountants will be asking for this information

The location you login into has changed it is now on EIDM EIDM is the acronym for CMS Enterprise Identity Management system which includes Identity Verification Access Management Authorization Assistance Workflow Tools and Identity Lifecycle Management functions

httpswwwcmsgovResearch-Statistics-Data-and-SystemsCMS-Information-TechnologyIACSCMS-Applications-Loginhtml

Go down the page and click on the PSampRSTARThis will take you to the login pagewill look the same as the old P S amp R didChanges Affecting PSampR System Access (Please Read) (posted 01292015)(Updated 5262015)is changingThe system which controls your PSampR user ID (currently IACS)The new system is referred to as EIDMThis will result in a different way to create new accounts or change passwords to existing accountsIf you already have an account in EIDM you may have to use that account for accessing PSampR after the transitionWhen is the change effectiveJune 13 2015What is staying the sameThe internet address for accessing PSampR remains the sameThe PSampR systemfunctionality is NOT changing 62

Medicare Advantage Payorsbull Medicare Advantage payors are pullingdenying payments on admissions if the patient was readmitted within 30 days after discharge The

client believes that the payors systematically denying payments for all readmissions within 30 days They believe this practice denies them due process to address whether the readmissions were justified and not due to a premature discharge of patient The payors seem to want to act like a QIO without having the same accountabilities of the QIO related to determinations of non-payment

bull Heres the QIO process under section 4240 of the QIO Manualbull 4240 - Readmission Review - (Rev 2 07-11-03)bull Readmission review involves admissions to an acute general short-term hospital occurring less than 31 calendar days from the date of

discharge from the same or another acute general short-term hospital (see sect1154(a)(13) and 42 CFR 47671(a)(8)(ii)) Neither the day of discharge nor the day of admission is counted when determining whether a readmission has occurred

bull A Medical Review Proceduresbull Obtain the appropriate medical records for the initial admission and readmission Perform case review on both stays Analyze the cases

specifically to determine whether the patient was prematurely discharged from the first confinement thus causing readmission Perform an analysis of the stay at the first hospital to determine the cause(s) and extent of any problem(s) (eg incomplete or substandard treatment) Consider the information available to the attending physician who discharged the patient from the first confinement Do not base a determination of a premature discharge on information that the physician or provider could not have known or events that could not have been anticipated at the time of discharge

bull Review both the initial admission and the readmission at the same time unless one of them has previously been reviewed In these cases use at a minimum the PRAF case summary of the other admission in addition to the medical record of the case under review

bull C Denialsbull Deny readmissions under the following circumstancesbull If the readmission was medically unnecessarybull If the readmission resulted from a premature discharge from the same hospital orbull If the readmission was a result of circumvention of PPS by the same hospital (see sect4255)bull With the QIO process there is an appeal within the QIO here the hospital is getting no opportunity to challenge the denials

63

Medicare Provider Enrollment Feebull Provider Enrollment Application Fee Amount for CY 2016bull On December 3 CMS issued a notice Provider Enrollment Application

Fee Amount for CY 2016 [CMSndash6066ndashN] Effective January 1 2016 the CY 2016 application fee is $554 for institutional providers that are

bull Initially enrolling in the Medicare or Medicaid program or the Childrens Health Insurance Program (CHIP)

bull Revalidating their Medicare Medicaid or CHIP enrollmentbull Adding a new Medicare practice locationbull This fee is required with any enrollment application submitted from

January 1 through December 31 2016

64

Medicare MAC-Higlas

bull Effective 142016 CMS has implemented a change to begin netting (offsetting) provider money across workloads within a single organization What this means is that any related providers conducting business in two different workloads (example New York and Maine) will have their money applied to any account receivables (AR) with a remaining balance owed to Medicare within both workloads For example Provider ABC is located in New York and is scheduled to receive a payment of $1000 on todays remittance advice Provider XYZ is related to provider ABC but is located in Maine and has ARs with a balance owed of $200 Provider ABCs $1000 payment will have the $200 applied against provider XYZs ARs resulting in a net payment of $800 This will be reflected on the remittance advice by the same PLB code as seen today for offsets for the $200

65

Two Midnight RuleChange January 1 2016 httpswwwcmsgovMedicareMedicare-Fee-for-Service-PaymentHospitalOutpatientPPSHospital-Outpatient-Regulations-and-Notices-ItemsCMS-1633-FChtml

66

Two Midnight Rulebull However effective January 1 2016 CMS will allow exceptions to the

Two-Midnight Benchmark to be determined on a case-by-case basis by the physician responsible for the care of the beneficiary subject to medical review Said differently Part A payment may be appropriate in some circumstances even though there is no expectation by the physician (or qualified ordering practitioner) of a two-midnight stay and one of the two pre-existing categorical exceptions (CMS ldquoinpatient onlyrdquo list and newly initiated mechanical ventilation) does not apply CMS has indicated that this change to the Two Midnight Rule is in response to stakeholder concern and CMSrsquos continued efforts to develop the most appropriate standard for determining Medicare Part A payment

67

Two Midnight Rulebull A new 42 CFR sect4123(a) provides that a patient is considered an

inpatient of a hospitalhellipif formally admitted as an inpatient pursuant to an order for inpatient admission by a physician or other qualified practitionerhellip The physician orders inpatient status when he or she expects the patient to require a stay that crosses at least 2 midnights[10] Stays expected to be shorter than at least two midnights are generally inappropriate for inpatient admission and inpatient payment under Medicare Part A unless the surgical procedure is specified by Medicare as inpatient only under sect41922(n)[11] The physicians expectationhellipshould be based on such complex medical factors as patient history and comorbidities the severity of signs and symptoms current medical needs and the risk of an adverse event[12] The physician order is part of physician certification of the medical necessity of hospital inpatient serviceshellip[13]

68

InPatient Vs Observation Conthellip

bull Physician certification which begins with an order for inpatient admission requires the physician to certify the reasons for the hospitalization the estimated time the patient will remain in the hospital and plans for post-hospital care if appropriate[14] The certification must be completed signed and documented in the medical record prior to discharge[15]

bull A physicians admission order has no presumptive weight and both the admission order and the physician certification will be evaluated in the context of the evidence in the medical record[16] CMS intends to provide additional information about what evidence in the medical record means in future instructions and manual revisions[17]

69

Two Midnight Rulebull Although the new case-by-case exception appears to be inherently

subjective to a certain extent CMS states that the following factors (among others) would be relevant to determining whether a patient requires inpatient admission under the expanded policy

bull The severity of the signs and symptoms exhibited by the patient bull The medical predictability of something adverse happening to the patient

and bull The need for diagnostic studies that appropriately are outpatient services

(that is their performance does not ordinarily require the patient to remain at the hospital for 24 hours or more)

bull CMS also notes that an inpatient admission (and Part A payment) should be ldquorare and unusualrdquo for minor surgical procedures or other treatment that is expected to keep the patient in the hospital ldquofor only a few hoursrdquo or for a period of time that ldquodoes not span at least overnightrdquo (thus a subset of stays not meeting the Two Midnight Benchmark) CMS indicates that such cases will be prioritized for medical review

70

Health Data Insights amp Medicare Plus Blue

RAC (Retrospective Audits)

71

HDI Health Data amp Med Plus Blue

bull httpwwwhealthdatainsightscombull Blue Cross Medicare Advantage Auditsbull Facilities seeing 10 to 15 requests for Medical Recordsbull In January amp Feburarybull Selected Health Data Insights because they were a premier Audit

Vendor for CMS Recovery Audit Contractor (RAC) demonstration Project They are a audit vendor for Humana

bull Providers not sending Medical Record will get technical denial and lose payments

72

Health Data InSight

bull In 2010 they began the Hospital Reviewbull Medicare Advantage encounter datandashCMS oversight of data integrity OIG

2016bull We will review CMSs oversight of MA encounter data validation and assess

the extent to which CMSrsquos Integrated Data Repository contains timely valid and complete MA encounter data In 2012 CMS began collecting from MA organizations a more comprehensive set of encounter data reflecting the items and services provided to MA plan enrollees Prior CMS and OIG audits have indicated vulnerabilities in the accuracy of data reporting by MA organizations Realizing the potential benefits of the MA encounter data for payment and program integrity oversight is contingent upon the datarsquos completeness validity and timeliness (OEI 03-15-00060 expected issue date FY 2017)

73

Pepper Reports

bull httpswwwpepperresourcesorg

bull Program for Evaluating Payment Patterns Electronic Report ( PEPPER)

bull Annually on or about April 18 2016 will be released

bull Pepper Portal httpssecurefiletmforg

74

CGI Technologies and Solutions Inc httpracbcgicomContactInfoaspxst=1

bull Indiana bull Michiganbull Minnesotabull Illinoisbull Kentuckybull Ohiobull Wisconsin CGI Technologies and Solutions Incbull For general and administrative questions regarding client service outreach

quality assurance or project-specific issues contactbull 1877316RACB (7222)bull Email racbcgicom Tamara Tate Tamaratatecmshhsgovbull 4107861288

75

CGI Federal RAC

bull CGI Federal RAC Region Bbull Email racbcgicombull Phone 1-877-316-RACB (7222)bull Mailing Addressbull Send medical records as followsbull Medical records for Indiana Illinois Kentucky Michigan Ohio Wisconsin

Minnesota DME and Home Health CGI Federal Inc Attn RACB Imaging Dept 1001 Lakeside Ave Suite 800 Cleveland OH 44114

bull If submitting paper records please send medical records as follows For Therapy Reviews CGI Federal Inc Attn RACB Imaging 1001 Lakeside Avenue Suite 800 Cleveland OH 44114

76

How to survive RAC Audit

bull National health expenditures totaled $1679 Billion in 2003 bull National health expenditures were 153 of GROSS Domestic Product

(GDP) in 2003 bull Health care cost increasing at +9 per year bull Doomsday predictions of Medicare running out bull Congressional Action

77

RAC Audits

bull Medicare Modernization Act (MMA) of 2003Mandated a three year audit demonstration project 2005-2008

bull Appoint audit contractors to review Medicare billings for proper coding DRG assignment and medical necessity

bull Audits will apply to all health care providers (hospitals physicians homecare dme etc)

bull Audit contractors to be paid on a contingency basis a percentage of overpayments recovered

78

How Did we get here

bull Overpayments collected due to errors in Medically Unnecessary Services ndash 40

bull Incorrectly Coded ndash 35

bull Other ndash 17

bull NoInsufficient Documentation ndash 8

79

Where are we now

bull All RACrsquos completed required provider outreachAccess to Medicare billing data base given to all RAC RAC review methodology

bull Automated Review-Black amp White Issues (current) bull DRG Validation-complex review (current) bull Complex Review for coding errors (current) bull DME Medical Necessity Reviews ndashcomplex review (calendar year

2010) bull Medical Necessity Reviews-complex review (calendar year 2010)

80

RAC Reviews

bull Responsibilities of the Team Leader bull Must learn each insurance provider participating in a RAC or RAC type

program bull What are their operating rulesbull What is their appeal process Time limits

May be different process for each insurance provider bull Develop a response team

Identify who does what when why and alternate bull individual

Build and develop a manual process Review of computerized system

81

Priority Health SCIO Health Analytics

bull httpswwwsciohealthanalyticscomcore-capabilitiespayment-integrityfacility-auditsskilled-nursing-facility-audits

bull Claims for Medicare members treated at Skilled Nursing Facilities are reimbursed based on the patientsrsquo RUG (Resource Utilization Group) score which is determined using the Minimum Data Set (MDS) Using SCIOs robust analytics claims andor providers that merit review are selected for audit SCIOs auditors conduct a detailed review of the complete medical record and associated MDS to determine if the billed RUG score is valid In the event the review determines that an incorrect RUG score was billed SCIOreg provides the valid score reports the reason the change was necessary and calculates the resulting overpayment

82

+ Cheer

Onward and Upward she shall prevail We are here to care for the residents and provide a wonderful

service

13 83

84

References

bull Priority Healthbull Blue Crossbull Medicaidbull Medicare

85

  • Medicare Mange Care amp Medicaid Changes in the New World We Live In
  • Medicaid
  • NEW Medicaid Change MIlogin
  • Blueprint for Health Innovation MI
  • Provider Enrollment Electronic Signature Form Submission Process MSA 15-54
  • Provider Enrollment Electronic Signature Form Submission Process
  • Provider Enrollment Domain Administrator
  • Medicaid Coinsurance Medicare Advantage
  • Slide Number 9
  • Lawsuit DHS Changes on Caregivers
  • TPL Medicaid Change
  • CHAMPS Member Screen
  • LOC dropping off Not Due to MI Health
  • Issues
  • Secure Email Information
  • Medicaid amp Hospice
  • Medicaid
  • Medicaid Medicare Buy In
  • Manage Medicaid
  • Healthy Michigan Residents
  • Healthy Michigan Medicaid Days
  • McLaren Health Plan
  • Manage Medicaid Plans January 1
  • Slide Number 24
  • MI Health Link
  • MI Health Link 2565
  • What are the Names
  • MI Health Dual Eligible
  • MI Health LOC
  • LOC Medicaid
  • Medicaid Redetermination and MHL Enrollment
  • MI Health Link Portals
  • MI Health Authorizations
  • MI Health Issues
  • LOC 02 dropping MI Health Issues
  • PPA Offset
  • LOCD
  • MI Health Issues-New
  • ACO
  • Families Receiving Letters for ACO
  • ACO What is It
  • Payroll Based Journal
  • Slide Number 43
  • If you submit data manually should you also submit it through the XML
  • Staffing Submission Frequently Asked Questions
  • CMS defines
  • Slide Number 47
  • PBJ Medical Director Role
  • PBJ Medical Director Role
  • Dietician
  • Pharmacy Consultant
  • What are the names for the Medicare Number
  • QTSO
  • Medicare Update
  • CMS Final Rule On Returning Credits
  • Over Payment Rule
  • Questions to MAC
  • Questions to MAC
  • Final Rule on Returning Credits
  • Final Rule on Returning Credits
  • Final Rule on Returning Credits
  • Slide Number 62
  • Medicare Advantage Payors
  • Medicare Provider Enrollment Fee
  • Medicare MAC-Higlas
  • Two Midnight Rule
  • Two Midnight Rule
  • Two Midnight Rule
  • InPatient Vs Observation Conthellip
  • Two Midnight Rule
  • Health Data Insights amp Medicare Plus Blue
  • HDI Health Data amp Med Plus Blue
  • Health Data InSight
  • Pepper Reports
  • CGI Technologies and Solutions Inc httpracbcgicomContactInfoaspxst=1
  • CGI Federal RAC
  • How to survive RAC Audit
  • RAC Audits
  • How Did we get here
  • Where are we now
  • RAC Reviews
  • Priority Health SCIO Health Analytics
  • Cheer
  • References
Page 42: Medicare, Mange Care & Medicaid Changes in the New World we live in

Payroll Based JournalMandatory on July 1 2016Internet Explorer Version

Internet Explorer v 10 and v 11 will need to operate in compatibility mode

42

43

If you submit data manually should you also submit it through the XML

bull Now you have three options

bull Submit Manually only

bull Submit through the XML only

bull You are able to submit manually and using the XML

44

45

Staffing Submission Frequently Asked Questions

bull ldquoWho are direct care staffrdquo (Who do we submit data for)bull Submission of data for contract staffbull Medical directors and consultantsbull Staff switching roles or tasks throughout the daybull Hours paid vs hours worked ndash Must be verifiablebull Public postingQuality MeasuresFive Starbull Enforcementbull Voluntary submission risks (noneSo register now)

CMS defines

bull 37 job title codes that are required to match employees to the number of hours each direct care function was performed It is important to work with your teams to define the workers that contribute to each job type and how those daily worked hours are recorded and converted to a PBJ submission

bull The PBJ does include some more specific job descriptions than the 671 For example the PBJ system includes job descriptions for RNs with administrative duties and LPNs with administrative duties versus the 671rsquos more general ldquoNurses with Administrative Duties

Page 46

47

PBJ Medical Director Rolebull Physician Leadership

bull Help the facility ensure that patients have appropriate physician coverage and ensure the provision of physician and health care practitioner services and

bull Help the facility develop a process for reviewing physician and health care practitioner credentials

bull Provide specific guidance for physician performance expectations

bull Help the facility ensure that a system is in place for monitoring the performance of health care practitioners and

bull Facilitate feedback to physicians and other health care practitioners on performance and practices

bull Patient Care - Clinical Leadership

bull Participate in administrative decision-making and the development of policies and procedures related to patient care

bull Help develop approve and implement specific clinical practices for the facility to incorporate into its care-related policies and procedures including areas required by laws and regulations

bull Develop procedures and guidance for facility staff regarding contacting practitioners including information gathering and presentation change in condition assessment and when to contact the medical director

bull Review consider andor act upon consultant recommendations as appropriate that affect the facilitys resident care policies and procedures or the care of an individual resident

bull Review respond to and participate in federal state local and other external surveys and inspections and

bull Help review policies and procedures regarding the adequate protection of patients rights advance care planning and other ethical issues48

PBJ Medical Director Rolebull Quality of Care

bull Help the facility establish systems and methods for reviewing the quality and appropriateness of clinical care and other health-related services and provide appropriate feedback and

bull Participate in the facilitys quality improvement process

bull Advise on infection control issues and approve specific infection control policies to be incorporated into facility policies and procedures

bull Help the facility provide a safe and caring environment

bull Help promote employee health and safety and

bull Assist in the development and implementation of employee health policies and programs

bull Education Information and Communication

bull Promote a learning culture within the facility by educating informing and communicating

bull Provide information to help the facility provide care consistent with current standards of practice (defined as approaches to care procedures techniques and treatments that are based on research and or expert consensus and that are contained in current manuals textbooks and or publications or that are accepted adopted or promulgated by recognized organizations or national bodies)

bull Help the facility develop medical information and communication systems with staff patients and families and others

bull Represent the facility to the professional and lay community on medical and patient care issues

bull Maintain knowledge of the changing social regulatory political and economic factors that affect medical and health services of long term care patients and

bull Help establish appropriate relationships with other health care organizations

49

Dietician

bull When the dietary or food services supervisor is other than a registered dietitian the supervisor shall receive routine consultation and technical assistance from a registered dietitian (RD) Consultation time shall not be less than 4 hours every 60 days Additional consultation time may be needed based on the total number of patients incidence of nutrition-related health problems and food service management needs of the facility

50

Pharmacy Consultant

bull At least once per month a licensed pharmacist must perform a drug regimen review (DRR) for each resident The pharmacist must report any irregularities to the attending physician or director of nursing Furthermore these reports must be acted upon

51

What are the names for the Medicare Numberbull OSCAR -Online Survey Certification and Reporting

bull PTAN-PTAN number is assigned by Medicare to authenticate the provider when using the local Medicare Administrative Contractorrsquos (MAC) self-help tools like the IVR internet portal on-line application status etc Provider Transactions Access Number

bull CCN- CMS Certification Number

bull Medicare Number- example 23-

bull All of the above mean the same thing

52

QTSO

bull Once you are logged in the QTSO site bull You will have a state login to the site to access the various site specific

to your facilitybull Installing you will need administrator rights to your network

53

Medicare UpdateWhat are we seeing

54

CMS Final Rule On Returning Credits

httpswwwfederalregistergovarticles201602122016-02789medicare-program-reporting-and-returning-of-overpayments

55

Over Payment Rule

bull Medicare payments for non covered services

bull Medicare payments in excess of the allowable amount for an identified covered service

bull Errors and non reimbursable expenditures in cost reportsbull Duplicate payment

bull Receipt of Medicare payments when another payor had the primary responsibility for payment

56

Questions to MAC

bull Does the Medicare credit balance report change with this overpayment rule

bull No Medicare Credit Balances are still required at the end of each quarter

bull Will that still be the communication to let CMS or the MAC know that we have received an overpayment

bull Submission of Medicare Credit Balance is one form of communicating overpayments to CMS Other methods include submitting a voluntary refund with required claim information or the submission of a standard overpayment form

57

Questions to MAC

bull Will the MAC still deduct from a future RAbull If the recovery of the overpayment includes adjusting a claim then

the overpayment would be netted against future claims payments and reflected on the RA

bull Or will that process change with this new rulebull Process will remain the samebull Will NGS send communication out on thisbull Yes NGS will communicate this once the final rule is communicated

to the MACs by CMS However this could change depending on final CMS instructions

58

Final Rule on Returning Credits

bull Providers will want to immediately update their current policies governing overpayments in order to comply with this new rule which will take effect on March 14 2016

bull Providers and suppliers are required to use reasonable diligence to investigate credible information regarding overpayments through both proactive compliance efforts and reactive investigations

bull If an overpayment is identified then it must be repaid within 60 days An overpayment is identified when a person has or should have through the exercise of reasonable diligence determined that the person received an overpayment and quantified the amount

bull Providers and suppliers have a maximum of 8 months to report and return overpayments ndash up to 6 months to investigate and quantify the overpayment (ie to identify it) and up to 60 days to report and return the overpayment

59

Final Rule on Returning Credits

bull Providers and suppliers are required to report and return all overpayments within a 6-year lookback period

bull The cause and amount of the overpayment is irrelevant for the determination eg it was due to a mistake it was someone elsersquos fault it is a minor amount An overpayment is an overpayment and must be returned

bull Providers and suppliers must make their own determination to which entity to report and return the overpayment ie to the Medicare contractor or using the OIG Self Disclosure Protocol or the CMS Self Referral Disclosure Protocol

60

Final Rule on Returning Credits

bull Providers and suppliers may use the claims adjustment credit balance self-reported refund process or another appropriate process to report and return overpayments At this time there is no standard refund form to use

bull Failure to report and return an overpayment could subject the provider or supplier to False Claims Act liability Civil Monetary Penalties Law liability and exclusion from federal health care programs

61

P S amp R-Accountants will be asking for this information

The location you login into has changed it is now on EIDM EIDM is the acronym for CMS Enterprise Identity Management system which includes Identity Verification Access Management Authorization Assistance Workflow Tools and Identity Lifecycle Management functions

httpswwwcmsgovResearch-Statistics-Data-and-SystemsCMS-Information-TechnologyIACSCMS-Applications-Loginhtml

Go down the page and click on the PSampRSTARThis will take you to the login pagewill look the same as the old P S amp R didChanges Affecting PSampR System Access (Please Read) (posted 01292015)(Updated 5262015)is changingThe system which controls your PSampR user ID (currently IACS)The new system is referred to as EIDMThis will result in a different way to create new accounts or change passwords to existing accountsIf you already have an account in EIDM you may have to use that account for accessing PSampR after the transitionWhen is the change effectiveJune 13 2015What is staying the sameThe internet address for accessing PSampR remains the sameThe PSampR systemfunctionality is NOT changing 62

Medicare Advantage Payorsbull Medicare Advantage payors are pullingdenying payments on admissions if the patient was readmitted within 30 days after discharge The

client believes that the payors systematically denying payments for all readmissions within 30 days They believe this practice denies them due process to address whether the readmissions were justified and not due to a premature discharge of patient The payors seem to want to act like a QIO without having the same accountabilities of the QIO related to determinations of non-payment

bull Heres the QIO process under section 4240 of the QIO Manualbull 4240 - Readmission Review - (Rev 2 07-11-03)bull Readmission review involves admissions to an acute general short-term hospital occurring less than 31 calendar days from the date of

discharge from the same or another acute general short-term hospital (see sect1154(a)(13) and 42 CFR 47671(a)(8)(ii)) Neither the day of discharge nor the day of admission is counted when determining whether a readmission has occurred

bull A Medical Review Proceduresbull Obtain the appropriate medical records for the initial admission and readmission Perform case review on both stays Analyze the cases

specifically to determine whether the patient was prematurely discharged from the first confinement thus causing readmission Perform an analysis of the stay at the first hospital to determine the cause(s) and extent of any problem(s) (eg incomplete or substandard treatment) Consider the information available to the attending physician who discharged the patient from the first confinement Do not base a determination of a premature discharge on information that the physician or provider could not have known or events that could not have been anticipated at the time of discharge

bull Review both the initial admission and the readmission at the same time unless one of them has previously been reviewed In these cases use at a minimum the PRAF case summary of the other admission in addition to the medical record of the case under review

bull C Denialsbull Deny readmissions under the following circumstancesbull If the readmission was medically unnecessarybull If the readmission resulted from a premature discharge from the same hospital orbull If the readmission was a result of circumvention of PPS by the same hospital (see sect4255)bull With the QIO process there is an appeal within the QIO here the hospital is getting no opportunity to challenge the denials

63

Medicare Provider Enrollment Feebull Provider Enrollment Application Fee Amount for CY 2016bull On December 3 CMS issued a notice Provider Enrollment Application

Fee Amount for CY 2016 [CMSndash6066ndashN] Effective January 1 2016 the CY 2016 application fee is $554 for institutional providers that are

bull Initially enrolling in the Medicare or Medicaid program or the Childrens Health Insurance Program (CHIP)

bull Revalidating their Medicare Medicaid or CHIP enrollmentbull Adding a new Medicare practice locationbull This fee is required with any enrollment application submitted from

January 1 through December 31 2016

64

Medicare MAC-Higlas

bull Effective 142016 CMS has implemented a change to begin netting (offsetting) provider money across workloads within a single organization What this means is that any related providers conducting business in two different workloads (example New York and Maine) will have their money applied to any account receivables (AR) with a remaining balance owed to Medicare within both workloads For example Provider ABC is located in New York and is scheduled to receive a payment of $1000 on todays remittance advice Provider XYZ is related to provider ABC but is located in Maine and has ARs with a balance owed of $200 Provider ABCs $1000 payment will have the $200 applied against provider XYZs ARs resulting in a net payment of $800 This will be reflected on the remittance advice by the same PLB code as seen today for offsets for the $200

65

Two Midnight RuleChange January 1 2016 httpswwwcmsgovMedicareMedicare-Fee-for-Service-PaymentHospitalOutpatientPPSHospital-Outpatient-Regulations-and-Notices-ItemsCMS-1633-FChtml

66

Two Midnight Rulebull However effective January 1 2016 CMS will allow exceptions to the

Two-Midnight Benchmark to be determined on a case-by-case basis by the physician responsible for the care of the beneficiary subject to medical review Said differently Part A payment may be appropriate in some circumstances even though there is no expectation by the physician (or qualified ordering practitioner) of a two-midnight stay and one of the two pre-existing categorical exceptions (CMS ldquoinpatient onlyrdquo list and newly initiated mechanical ventilation) does not apply CMS has indicated that this change to the Two Midnight Rule is in response to stakeholder concern and CMSrsquos continued efforts to develop the most appropriate standard for determining Medicare Part A payment

67

Two Midnight Rulebull A new 42 CFR sect4123(a) provides that a patient is considered an

inpatient of a hospitalhellipif formally admitted as an inpatient pursuant to an order for inpatient admission by a physician or other qualified practitionerhellip The physician orders inpatient status when he or she expects the patient to require a stay that crosses at least 2 midnights[10] Stays expected to be shorter than at least two midnights are generally inappropriate for inpatient admission and inpatient payment under Medicare Part A unless the surgical procedure is specified by Medicare as inpatient only under sect41922(n)[11] The physicians expectationhellipshould be based on such complex medical factors as patient history and comorbidities the severity of signs and symptoms current medical needs and the risk of an adverse event[12] The physician order is part of physician certification of the medical necessity of hospital inpatient serviceshellip[13]

68

InPatient Vs Observation Conthellip

bull Physician certification which begins with an order for inpatient admission requires the physician to certify the reasons for the hospitalization the estimated time the patient will remain in the hospital and plans for post-hospital care if appropriate[14] The certification must be completed signed and documented in the medical record prior to discharge[15]

bull A physicians admission order has no presumptive weight and both the admission order and the physician certification will be evaluated in the context of the evidence in the medical record[16] CMS intends to provide additional information about what evidence in the medical record means in future instructions and manual revisions[17]

69

Two Midnight Rulebull Although the new case-by-case exception appears to be inherently

subjective to a certain extent CMS states that the following factors (among others) would be relevant to determining whether a patient requires inpatient admission under the expanded policy

bull The severity of the signs and symptoms exhibited by the patient bull The medical predictability of something adverse happening to the patient

and bull The need for diagnostic studies that appropriately are outpatient services

(that is their performance does not ordinarily require the patient to remain at the hospital for 24 hours or more)

bull CMS also notes that an inpatient admission (and Part A payment) should be ldquorare and unusualrdquo for minor surgical procedures or other treatment that is expected to keep the patient in the hospital ldquofor only a few hoursrdquo or for a period of time that ldquodoes not span at least overnightrdquo (thus a subset of stays not meeting the Two Midnight Benchmark) CMS indicates that such cases will be prioritized for medical review

70

Health Data Insights amp Medicare Plus Blue

RAC (Retrospective Audits)

71

HDI Health Data amp Med Plus Blue

bull httpwwwhealthdatainsightscombull Blue Cross Medicare Advantage Auditsbull Facilities seeing 10 to 15 requests for Medical Recordsbull In January amp Feburarybull Selected Health Data Insights because they were a premier Audit

Vendor for CMS Recovery Audit Contractor (RAC) demonstration Project They are a audit vendor for Humana

bull Providers not sending Medical Record will get technical denial and lose payments

72

Health Data InSight

bull In 2010 they began the Hospital Reviewbull Medicare Advantage encounter datandashCMS oversight of data integrity OIG

2016bull We will review CMSs oversight of MA encounter data validation and assess

the extent to which CMSrsquos Integrated Data Repository contains timely valid and complete MA encounter data In 2012 CMS began collecting from MA organizations a more comprehensive set of encounter data reflecting the items and services provided to MA plan enrollees Prior CMS and OIG audits have indicated vulnerabilities in the accuracy of data reporting by MA organizations Realizing the potential benefits of the MA encounter data for payment and program integrity oversight is contingent upon the datarsquos completeness validity and timeliness (OEI 03-15-00060 expected issue date FY 2017)

73

Pepper Reports

bull httpswwwpepperresourcesorg

bull Program for Evaluating Payment Patterns Electronic Report ( PEPPER)

bull Annually on or about April 18 2016 will be released

bull Pepper Portal httpssecurefiletmforg

74

CGI Technologies and Solutions Inc httpracbcgicomContactInfoaspxst=1

bull Indiana bull Michiganbull Minnesotabull Illinoisbull Kentuckybull Ohiobull Wisconsin CGI Technologies and Solutions Incbull For general and administrative questions regarding client service outreach

quality assurance or project-specific issues contactbull 1877316RACB (7222)bull Email racbcgicom Tamara Tate Tamaratatecmshhsgovbull 4107861288

75

CGI Federal RAC

bull CGI Federal RAC Region Bbull Email racbcgicombull Phone 1-877-316-RACB (7222)bull Mailing Addressbull Send medical records as followsbull Medical records for Indiana Illinois Kentucky Michigan Ohio Wisconsin

Minnesota DME and Home Health CGI Federal Inc Attn RACB Imaging Dept 1001 Lakeside Ave Suite 800 Cleveland OH 44114

bull If submitting paper records please send medical records as follows For Therapy Reviews CGI Federal Inc Attn RACB Imaging 1001 Lakeside Avenue Suite 800 Cleveland OH 44114

76

How to survive RAC Audit

bull National health expenditures totaled $1679 Billion in 2003 bull National health expenditures were 153 of GROSS Domestic Product

(GDP) in 2003 bull Health care cost increasing at +9 per year bull Doomsday predictions of Medicare running out bull Congressional Action

77

RAC Audits

bull Medicare Modernization Act (MMA) of 2003Mandated a three year audit demonstration project 2005-2008

bull Appoint audit contractors to review Medicare billings for proper coding DRG assignment and medical necessity

bull Audits will apply to all health care providers (hospitals physicians homecare dme etc)

bull Audit contractors to be paid on a contingency basis a percentage of overpayments recovered

78

How Did we get here

bull Overpayments collected due to errors in Medically Unnecessary Services ndash 40

bull Incorrectly Coded ndash 35

bull Other ndash 17

bull NoInsufficient Documentation ndash 8

79

Where are we now

bull All RACrsquos completed required provider outreachAccess to Medicare billing data base given to all RAC RAC review methodology

bull Automated Review-Black amp White Issues (current) bull DRG Validation-complex review (current) bull Complex Review for coding errors (current) bull DME Medical Necessity Reviews ndashcomplex review (calendar year

2010) bull Medical Necessity Reviews-complex review (calendar year 2010)

80

RAC Reviews

bull Responsibilities of the Team Leader bull Must learn each insurance provider participating in a RAC or RAC type

program bull What are their operating rulesbull What is their appeal process Time limits

May be different process for each insurance provider bull Develop a response team

Identify who does what when why and alternate bull individual

Build and develop a manual process Review of computerized system

81

Priority Health SCIO Health Analytics

bull httpswwwsciohealthanalyticscomcore-capabilitiespayment-integrityfacility-auditsskilled-nursing-facility-audits

bull Claims for Medicare members treated at Skilled Nursing Facilities are reimbursed based on the patientsrsquo RUG (Resource Utilization Group) score which is determined using the Minimum Data Set (MDS) Using SCIOs robust analytics claims andor providers that merit review are selected for audit SCIOs auditors conduct a detailed review of the complete medical record and associated MDS to determine if the billed RUG score is valid In the event the review determines that an incorrect RUG score was billed SCIOreg provides the valid score reports the reason the change was necessary and calculates the resulting overpayment

82

+ Cheer

Onward and Upward she shall prevail We are here to care for the residents and provide a wonderful

service

13 83

84

References

bull Priority Healthbull Blue Crossbull Medicaidbull Medicare

85

  • Medicare Mange Care amp Medicaid Changes in the New World We Live In
  • Medicaid
  • NEW Medicaid Change MIlogin
  • Blueprint for Health Innovation MI
  • Provider Enrollment Electronic Signature Form Submission Process MSA 15-54
  • Provider Enrollment Electronic Signature Form Submission Process
  • Provider Enrollment Domain Administrator
  • Medicaid Coinsurance Medicare Advantage
  • Slide Number 9
  • Lawsuit DHS Changes on Caregivers
  • TPL Medicaid Change
  • CHAMPS Member Screen
  • LOC dropping off Not Due to MI Health
  • Issues
  • Secure Email Information
  • Medicaid amp Hospice
  • Medicaid
  • Medicaid Medicare Buy In
  • Manage Medicaid
  • Healthy Michigan Residents
  • Healthy Michigan Medicaid Days
  • McLaren Health Plan
  • Manage Medicaid Plans January 1
  • Slide Number 24
  • MI Health Link
  • MI Health Link 2565
  • What are the Names
  • MI Health Dual Eligible
  • MI Health LOC
  • LOC Medicaid
  • Medicaid Redetermination and MHL Enrollment
  • MI Health Link Portals
  • MI Health Authorizations
  • MI Health Issues
  • LOC 02 dropping MI Health Issues
  • PPA Offset
  • LOCD
  • MI Health Issues-New
  • ACO
  • Families Receiving Letters for ACO
  • ACO What is It
  • Payroll Based Journal
  • Slide Number 43
  • If you submit data manually should you also submit it through the XML
  • Staffing Submission Frequently Asked Questions
  • CMS defines
  • Slide Number 47
  • PBJ Medical Director Role
  • PBJ Medical Director Role
  • Dietician
  • Pharmacy Consultant
  • What are the names for the Medicare Number
  • QTSO
  • Medicare Update
  • CMS Final Rule On Returning Credits
  • Over Payment Rule
  • Questions to MAC
  • Questions to MAC
  • Final Rule on Returning Credits
  • Final Rule on Returning Credits
  • Final Rule on Returning Credits
  • Slide Number 62
  • Medicare Advantage Payors
  • Medicare Provider Enrollment Fee
  • Medicare MAC-Higlas
  • Two Midnight Rule
  • Two Midnight Rule
  • Two Midnight Rule
  • InPatient Vs Observation Conthellip
  • Two Midnight Rule
  • Health Data Insights amp Medicare Plus Blue
  • HDI Health Data amp Med Plus Blue
  • Health Data InSight
  • Pepper Reports
  • CGI Technologies and Solutions Inc httpracbcgicomContactInfoaspxst=1
  • CGI Federal RAC
  • How to survive RAC Audit
  • RAC Audits
  • How Did we get here
  • Where are we now
  • RAC Reviews
  • Priority Health SCIO Health Analytics
  • Cheer
  • References
Page 43: Medicare, Mange Care & Medicaid Changes in the New World we live in

43

If you submit data manually should you also submit it through the XML

bull Now you have three options

bull Submit Manually only

bull Submit through the XML only

bull You are able to submit manually and using the XML

44

45

Staffing Submission Frequently Asked Questions

bull ldquoWho are direct care staffrdquo (Who do we submit data for)bull Submission of data for contract staffbull Medical directors and consultantsbull Staff switching roles or tasks throughout the daybull Hours paid vs hours worked ndash Must be verifiablebull Public postingQuality MeasuresFive Starbull Enforcementbull Voluntary submission risks (noneSo register now)

CMS defines

bull 37 job title codes that are required to match employees to the number of hours each direct care function was performed It is important to work with your teams to define the workers that contribute to each job type and how those daily worked hours are recorded and converted to a PBJ submission

bull The PBJ does include some more specific job descriptions than the 671 For example the PBJ system includes job descriptions for RNs with administrative duties and LPNs with administrative duties versus the 671rsquos more general ldquoNurses with Administrative Duties

Page 46

47

PBJ Medical Director Rolebull Physician Leadership

bull Help the facility ensure that patients have appropriate physician coverage and ensure the provision of physician and health care practitioner services and

bull Help the facility develop a process for reviewing physician and health care practitioner credentials

bull Provide specific guidance for physician performance expectations

bull Help the facility ensure that a system is in place for monitoring the performance of health care practitioners and

bull Facilitate feedback to physicians and other health care practitioners on performance and practices

bull Patient Care - Clinical Leadership

bull Participate in administrative decision-making and the development of policies and procedures related to patient care

bull Help develop approve and implement specific clinical practices for the facility to incorporate into its care-related policies and procedures including areas required by laws and regulations

bull Develop procedures and guidance for facility staff regarding contacting practitioners including information gathering and presentation change in condition assessment and when to contact the medical director

bull Review consider andor act upon consultant recommendations as appropriate that affect the facilitys resident care policies and procedures or the care of an individual resident

bull Review respond to and participate in federal state local and other external surveys and inspections and

bull Help review policies and procedures regarding the adequate protection of patients rights advance care planning and other ethical issues48

PBJ Medical Director Rolebull Quality of Care

bull Help the facility establish systems and methods for reviewing the quality and appropriateness of clinical care and other health-related services and provide appropriate feedback and

bull Participate in the facilitys quality improvement process

bull Advise on infection control issues and approve specific infection control policies to be incorporated into facility policies and procedures

bull Help the facility provide a safe and caring environment

bull Help promote employee health and safety and

bull Assist in the development and implementation of employee health policies and programs

bull Education Information and Communication

bull Promote a learning culture within the facility by educating informing and communicating

bull Provide information to help the facility provide care consistent with current standards of practice (defined as approaches to care procedures techniques and treatments that are based on research and or expert consensus and that are contained in current manuals textbooks and or publications or that are accepted adopted or promulgated by recognized organizations or national bodies)

bull Help the facility develop medical information and communication systems with staff patients and families and others

bull Represent the facility to the professional and lay community on medical and patient care issues

bull Maintain knowledge of the changing social regulatory political and economic factors that affect medical and health services of long term care patients and

bull Help establish appropriate relationships with other health care organizations

49

Dietician

bull When the dietary or food services supervisor is other than a registered dietitian the supervisor shall receive routine consultation and technical assistance from a registered dietitian (RD) Consultation time shall not be less than 4 hours every 60 days Additional consultation time may be needed based on the total number of patients incidence of nutrition-related health problems and food service management needs of the facility

50

Pharmacy Consultant

bull At least once per month a licensed pharmacist must perform a drug regimen review (DRR) for each resident The pharmacist must report any irregularities to the attending physician or director of nursing Furthermore these reports must be acted upon

51

What are the names for the Medicare Numberbull OSCAR -Online Survey Certification and Reporting

bull PTAN-PTAN number is assigned by Medicare to authenticate the provider when using the local Medicare Administrative Contractorrsquos (MAC) self-help tools like the IVR internet portal on-line application status etc Provider Transactions Access Number

bull CCN- CMS Certification Number

bull Medicare Number- example 23-

bull All of the above mean the same thing

52

QTSO

bull Once you are logged in the QTSO site bull You will have a state login to the site to access the various site specific

to your facilitybull Installing you will need administrator rights to your network

53

Medicare UpdateWhat are we seeing

54

CMS Final Rule On Returning Credits

httpswwwfederalregistergovarticles201602122016-02789medicare-program-reporting-and-returning-of-overpayments

55

Over Payment Rule

bull Medicare payments for non covered services

bull Medicare payments in excess of the allowable amount for an identified covered service

bull Errors and non reimbursable expenditures in cost reportsbull Duplicate payment

bull Receipt of Medicare payments when another payor had the primary responsibility for payment

56

Questions to MAC

bull Does the Medicare credit balance report change with this overpayment rule

bull No Medicare Credit Balances are still required at the end of each quarter

bull Will that still be the communication to let CMS or the MAC know that we have received an overpayment

bull Submission of Medicare Credit Balance is one form of communicating overpayments to CMS Other methods include submitting a voluntary refund with required claim information or the submission of a standard overpayment form

57

Questions to MAC

bull Will the MAC still deduct from a future RAbull If the recovery of the overpayment includes adjusting a claim then

the overpayment would be netted against future claims payments and reflected on the RA

bull Or will that process change with this new rulebull Process will remain the samebull Will NGS send communication out on thisbull Yes NGS will communicate this once the final rule is communicated

to the MACs by CMS However this could change depending on final CMS instructions

58

Final Rule on Returning Credits

bull Providers will want to immediately update their current policies governing overpayments in order to comply with this new rule which will take effect on March 14 2016

bull Providers and suppliers are required to use reasonable diligence to investigate credible information regarding overpayments through both proactive compliance efforts and reactive investigations

bull If an overpayment is identified then it must be repaid within 60 days An overpayment is identified when a person has or should have through the exercise of reasonable diligence determined that the person received an overpayment and quantified the amount

bull Providers and suppliers have a maximum of 8 months to report and return overpayments ndash up to 6 months to investigate and quantify the overpayment (ie to identify it) and up to 60 days to report and return the overpayment

59

Final Rule on Returning Credits

bull Providers and suppliers are required to report and return all overpayments within a 6-year lookback period

bull The cause and amount of the overpayment is irrelevant for the determination eg it was due to a mistake it was someone elsersquos fault it is a minor amount An overpayment is an overpayment and must be returned

bull Providers and suppliers must make their own determination to which entity to report and return the overpayment ie to the Medicare contractor or using the OIG Self Disclosure Protocol or the CMS Self Referral Disclosure Protocol

60

Final Rule on Returning Credits

bull Providers and suppliers may use the claims adjustment credit balance self-reported refund process or another appropriate process to report and return overpayments At this time there is no standard refund form to use

bull Failure to report and return an overpayment could subject the provider or supplier to False Claims Act liability Civil Monetary Penalties Law liability and exclusion from federal health care programs

61

P S amp R-Accountants will be asking for this information

The location you login into has changed it is now on EIDM EIDM is the acronym for CMS Enterprise Identity Management system which includes Identity Verification Access Management Authorization Assistance Workflow Tools and Identity Lifecycle Management functions

httpswwwcmsgovResearch-Statistics-Data-and-SystemsCMS-Information-TechnologyIACSCMS-Applications-Loginhtml

Go down the page and click on the PSampRSTARThis will take you to the login pagewill look the same as the old P S amp R didChanges Affecting PSampR System Access (Please Read) (posted 01292015)(Updated 5262015)is changingThe system which controls your PSampR user ID (currently IACS)The new system is referred to as EIDMThis will result in a different way to create new accounts or change passwords to existing accountsIf you already have an account in EIDM you may have to use that account for accessing PSampR after the transitionWhen is the change effectiveJune 13 2015What is staying the sameThe internet address for accessing PSampR remains the sameThe PSampR systemfunctionality is NOT changing 62

Medicare Advantage Payorsbull Medicare Advantage payors are pullingdenying payments on admissions if the patient was readmitted within 30 days after discharge The

client believes that the payors systematically denying payments for all readmissions within 30 days They believe this practice denies them due process to address whether the readmissions were justified and not due to a premature discharge of patient The payors seem to want to act like a QIO without having the same accountabilities of the QIO related to determinations of non-payment

bull Heres the QIO process under section 4240 of the QIO Manualbull 4240 - Readmission Review - (Rev 2 07-11-03)bull Readmission review involves admissions to an acute general short-term hospital occurring less than 31 calendar days from the date of

discharge from the same or another acute general short-term hospital (see sect1154(a)(13) and 42 CFR 47671(a)(8)(ii)) Neither the day of discharge nor the day of admission is counted when determining whether a readmission has occurred

bull A Medical Review Proceduresbull Obtain the appropriate medical records for the initial admission and readmission Perform case review on both stays Analyze the cases

specifically to determine whether the patient was prematurely discharged from the first confinement thus causing readmission Perform an analysis of the stay at the first hospital to determine the cause(s) and extent of any problem(s) (eg incomplete or substandard treatment) Consider the information available to the attending physician who discharged the patient from the first confinement Do not base a determination of a premature discharge on information that the physician or provider could not have known or events that could not have been anticipated at the time of discharge

bull Review both the initial admission and the readmission at the same time unless one of them has previously been reviewed In these cases use at a minimum the PRAF case summary of the other admission in addition to the medical record of the case under review

bull C Denialsbull Deny readmissions under the following circumstancesbull If the readmission was medically unnecessarybull If the readmission resulted from a premature discharge from the same hospital orbull If the readmission was a result of circumvention of PPS by the same hospital (see sect4255)bull With the QIO process there is an appeal within the QIO here the hospital is getting no opportunity to challenge the denials

63

Medicare Provider Enrollment Feebull Provider Enrollment Application Fee Amount for CY 2016bull On December 3 CMS issued a notice Provider Enrollment Application

Fee Amount for CY 2016 [CMSndash6066ndashN] Effective January 1 2016 the CY 2016 application fee is $554 for institutional providers that are

bull Initially enrolling in the Medicare or Medicaid program or the Childrens Health Insurance Program (CHIP)

bull Revalidating their Medicare Medicaid or CHIP enrollmentbull Adding a new Medicare practice locationbull This fee is required with any enrollment application submitted from

January 1 through December 31 2016

64

Medicare MAC-Higlas

bull Effective 142016 CMS has implemented a change to begin netting (offsetting) provider money across workloads within a single organization What this means is that any related providers conducting business in two different workloads (example New York and Maine) will have their money applied to any account receivables (AR) with a remaining balance owed to Medicare within both workloads For example Provider ABC is located in New York and is scheduled to receive a payment of $1000 on todays remittance advice Provider XYZ is related to provider ABC but is located in Maine and has ARs with a balance owed of $200 Provider ABCs $1000 payment will have the $200 applied against provider XYZs ARs resulting in a net payment of $800 This will be reflected on the remittance advice by the same PLB code as seen today for offsets for the $200

65

Two Midnight RuleChange January 1 2016 httpswwwcmsgovMedicareMedicare-Fee-for-Service-PaymentHospitalOutpatientPPSHospital-Outpatient-Regulations-and-Notices-ItemsCMS-1633-FChtml

66

Two Midnight Rulebull However effective January 1 2016 CMS will allow exceptions to the

Two-Midnight Benchmark to be determined on a case-by-case basis by the physician responsible for the care of the beneficiary subject to medical review Said differently Part A payment may be appropriate in some circumstances even though there is no expectation by the physician (or qualified ordering practitioner) of a two-midnight stay and one of the two pre-existing categorical exceptions (CMS ldquoinpatient onlyrdquo list and newly initiated mechanical ventilation) does not apply CMS has indicated that this change to the Two Midnight Rule is in response to stakeholder concern and CMSrsquos continued efforts to develop the most appropriate standard for determining Medicare Part A payment

67

Two Midnight Rulebull A new 42 CFR sect4123(a) provides that a patient is considered an

inpatient of a hospitalhellipif formally admitted as an inpatient pursuant to an order for inpatient admission by a physician or other qualified practitionerhellip The physician orders inpatient status when he or she expects the patient to require a stay that crosses at least 2 midnights[10] Stays expected to be shorter than at least two midnights are generally inappropriate for inpatient admission and inpatient payment under Medicare Part A unless the surgical procedure is specified by Medicare as inpatient only under sect41922(n)[11] The physicians expectationhellipshould be based on such complex medical factors as patient history and comorbidities the severity of signs and symptoms current medical needs and the risk of an adverse event[12] The physician order is part of physician certification of the medical necessity of hospital inpatient serviceshellip[13]

68

InPatient Vs Observation Conthellip

bull Physician certification which begins with an order for inpatient admission requires the physician to certify the reasons for the hospitalization the estimated time the patient will remain in the hospital and plans for post-hospital care if appropriate[14] The certification must be completed signed and documented in the medical record prior to discharge[15]

bull A physicians admission order has no presumptive weight and both the admission order and the physician certification will be evaluated in the context of the evidence in the medical record[16] CMS intends to provide additional information about what evidence in the medical record means in future instructions and manual revisions[17]

69

Two Midnight Rulebull Although the new case-by-case exception appears to be inherently

subjective to a certain extent CMS states that the following factors (among others) would be relevant to determining whether a patient requires inpatient admission under the expanded policy

bull The severity of the signs and symptoms exhibited by the patient bull The medical predictability of something adverse happening to the patient

and bull The need for diagnostic studies that appropriately are outpatient services

(that is their performance does not ordinarily require the patient to remain at the hospital for 24 hours or more)

bull CMS also notes that an inpatient admission (and Part A payment) should be ldquorare and unusualrdquo for minor surgical procedures or other treatment that is expected to keep the patient in the hospital ldquofor only a few hoursrdquo or for a period of time that ldquodoes not span at least overnightrdquo (thus a subset of stays not meeting the Two Midnight Benchmark) CMS indicates that such cases will be prioritized for medical review

70

Health Data Insights amp Medicare Plus Blue

RAC (Retrospective Audits)

71

HDI Health Data amp Med Plus Blue

bull httpwwwhealthdatainsightscombull Blue Cross Medicare Advantage Auditsbull Facilities seeing 10 to 15 requests for Medical Recordsbull In January amp Feburarybull Selected Health Data Insights because they were a premier Audit

Vendor for CMS Recovery Audit Contractor (RAC) demonstration Project They are a audit vendor for Humana

bull Providers not sending Medical Record will get technical denial and lose payments

72

Health Data InSight

bull In 2010 they began the Hospital Reviewbull Medicare Advantage encounter datandashCMS oversight of data integrity OIG

2016bull We will review CMSs oversight of MA encounter data validation and assess

the extent to which CMSrsquos Integrated Data Repository contains timely valid and complete MA encounter data In 2012 CMS began collecting from MA organizations a more comprehensive set of encounter data reflecting the items and services provided to MA plan enrollees Prior CMS and OIG audits have indicated vulnerabilities in the accuracy of data reporting by MA organizations Realizing the potential benefits of the MA encounter data for payment and program integrity oversight is contingent upon the datarsquos completeness validity and timeliness (OEI 03-15-00060 expected issue date FY 2017)

73

Pepper Reports

bull httpswwwpepperresourcesorg

bull Program for Evaluating Payment Patterns Electronic Report ( PEPPER)

bull Annually on or about April 18 2016 will be released

bull Pepper Portal httpssecurefiletmforg

74

CGI Technologies and Solutions Inc httpracbcgicomContactInfoaspxst=1

bull Indiana bull Michiganbull Minnesotabull Illinoisbull Kentuckybull Ohiobull Wisconsin CGI Technologies and Solutions Incbull For general and administrative questions regarding client service outreach

quality assurance or project-specific issues contactbull 1877316RACB (7222)bull Email racbcgicom Tamara Tate Tamaratatecmshhsgovbull 4107861288

75

CGI Federal RAC

bull CGI Federal RAC Region Bbull Email racbcgicombull Phone 1-877-316-RACB (7222)bull Mailing Addressbull Send medical records as followsbull Medical records for Indiana Illinois Kentucky Michigan Ohio Wisconsin

Minnesota DME and Home Health CGI Federal Inc Attn RACB Imaging Dept 1001 Lakeside Ave Suite 800 Cleveland OH 44114

bull If submitting paper records please send medical records as follows For Therapy Reviews CGI Federal Inc Attn RACB Imaging 1001 Lakeside Avenue Suite 800 Cleveland OH 44114

76

How to survive RAC Audit

bull National health expenditures totaled $1679 Billion in 2003 bull National health expenditures were 153 of GROSS Domestic Product

(GDP) in 2003 bull Health care cost increasing at +9 per year bull Doomsday predictions of Medicare running out bull Congressional Action

77

RAC Audits

bull Medicare Modernization Act (MMA) of 2003Mandated a three year audit demonstration project 2005-2008

bull Appoint audit contractors to review Medicare billings for proper coding DRG assignment and medical necessity

bull Audits will apply to all health care providers (hospitals physicians homecare dme etc)

bull Audit contractors to be paid on a contingency basis a percentage of overpayments recovered

78

How Did we get here

bull Overpayments collected due to errors in Medically Unnecessary Services ndash 40

bull Incorrectly Coded ndash 35

bull Other ndash 17

bull NoInsufficient Documentation ndash 8

79

Where are we now

bull All RACrsquos completed required provider outreachAccess to Medicare billing data base given to all RAC RAC review methodology

bull Automated Review-Black amp White Issues (current) bull DRG Validation-complex review (current) bull Complex Review for coding errors (current) bull DME Medical Necessity Reviews ndashcomplex review (calendar year

2010) bull Medical Necessity Reviews-complex review (calendar year 2010)

80

RAC Reviews

bull Responsibilities of the Team Leader bull Must learn each insurance provider participating in a RAC or RAC type

program bull What are their operating rulesbull What is their appeal process Time limits

May be different process for each insurance provider bull Develop a response team

Identify who does what when why and alternate bull individual

Build and develop a manual process Review of computerized system

81

Priority Health SCIO Health Analytics

bull httpswwwsciohealthanalyticscomcore-capabilitiespayment-integrityfacility-auditsskilled-nursing-facility-audits

bull Claims for Medicare members treated at Skilled Nursing Facilities are reimbursed based on the patientsrsquo RUG (Resource Utilization Group) score which is determined using the Minimum Data Set (MDS) Using SCIOs robust analytics claims andor providers that merit review are selected for audit SCIOs auditors conduct a detailed review of the complete medical record and associated MDS to determine if the billed RUG score is valid In the event the review determines that an incorrect RUG score was billed SCIOreg provides the valid score reports the reason the change was necessary and calculates the resulting overpayment

82

+ Cheer

Onward and Upward she shall prevail We are here to care for the residents and provide a wonderful

service

13 83

84

References

bull Priority Healthbull Blue Crossbull Medicaidbull Medicare

85

  • Medicare Mange Care amp Medicaid Changes in the New World We Live In
  • Medicaid
  • NEW Medicaid Change MIlogin
  • Blueprint for Health Innovation MI
  • Provider Enrollment Electronic Signature Form Submission Process MSA 15-54
  • Provider Enrollment Electronic Signature Form Submission Process
  • Provider Enrollment Domain Administrator
  • Medicaid Coinsurance Medicare Advantage
  • Slide Number 9
  • Lawsuit DHS Changes on Caregivers
  • TPL Medicaid Change
  • CHAMPS Member Screen
  • LOC dropping off Not Due to MI Health
  • Issues
  • Secure Email Information
  • Medicaid amp Hospice
  • Medicaid
  • Medicaid Medicare Buy In
  • Manage Medicaid
  • Healthy Michigan Residents
  • Healthy Michigan Medicaid Days
  • McLaren Health Plan
  • Manage Medicaid Plans January 1
  • Slide Number 24
  • MI Health Link
  • MI Health Link 2565
  • What are the Names
  • MI Health Dual Eligible
  • MI Health LOC
  • LOC Medicaid
  • Medicaid Redetermination and MHL Enrollment
  • MI Health Link Portals
  • MI Health Authorizations
  • MI Health Issues
  • LOC 02 dropping MI Health Issues
  • PPA Offset
  • LOCD
  • MI Health Issues-New
  • ACO
  • Families Receiving Letters for ACO
  • ACO What is It
  • Payroll Based Journal
  • Slide Number 43
  • If you submit data manually should you also submit it through the XML
  • Staffing Submission Frequently Asked Questions
  • CMS defines
  • Slide Number 47
  • PBJ Medical Director Role
  • PBJ Medical Director Role
  • Dietician
  • Pharmacy Consultant
  • What are the names for the Medicare Number
  • QTSO
  • Medicare Update
  • CMS Final Rule On Returning Credits
  • Over Payment Rule
  • Questions to MAC
  • Questions to MAC
  • Final Rule on Returning Credits
  • Final Rule on Returning Credits
  • Final Rule on Returning Credits
  • Slide Number 62
  • Medicare Advantage Payors
  • Medicare Provider Enrollment Fee
  • Medicare MAC-Higlas
  • Two Midnight Rule
  • Two Midnight Rule
  • Two Midnight Rule
  • InPatient Vs Observation Conthellip
  • Two Midnight Rule
  • Health Data Insights amp Medicare Plus Blue
  • HDI Health Data amp Med Plus Blue
  • Health Data InSight
  • Pepper Reports
  • CGI Technologies and Solutions Inc httpracbcgicomContactInfoaspxst=1
  • CGI Federal RAC
  • How to survive RAC Audit
  • RAC Audits
  • How Did we get here
  • Where are we now
  • RAC Reviews
  • Priority Health SCIO Health Analytics
  • Cheer
  • References
Page 44: Medicare, Mange Care & Medicaid Changes in the New World we live in

If you submit data manually should you also submit it through the XML

bull Now you have three options

bull Submit Manually only

bull Submit through the XML only

bull You are able to submit manually and using the XML

44

45

Staffing Submission Frequently Asked Questions

bull ldquoWho are direct care staffrdquo (Who do we submit data for)bull Submission of data for contract staffbull Medical directors and consultantsbull Staff switching roles or tasks throughout the daybull Hours paid vs hours worked ndash Must be verifiablebull Public postingQuality MeasuresFive Starbull Enforcementbull Voluntary submission risks (noneSo register now)

CMS defines

bull 37 job title codes that are required to match employees to the number of hours each direct care function was performed It is important to work with your teams to define the workers that contribute to each job type and how those daily worked hours are recorded and converted to a PBJ submission

bull The PBJ does include some more specific job descriptions than the 671 For example the PBJ system includes job descriptions for RNs with administrative duties and LPNs with administrative duties versus the 671rsquos more general ldquoNurses with Administrative Duties

Page 46

47

PBJ Medical Director Rolebull Physician Leadership

bull Help the facility ensure that patients have appropriate physician coverage and ensure the provision of physician and health care practitioner services and

bull Help the facility develop a process for reviewing physician and health care practitioner credentials

bull Provide specific guidance for physician performance expectations

bull Help the facility ensure that a system is in place for monitoring the performance of health care practitioners and

bull Facilitate feedback to physicians and other health care practitioners on performance and practices

bull Patient Care - Clinical Leadership

bull Participate in administrative decision-making and the development of policies and procedures related to patient care

bull Help develop approve and implement specific clinical practices for the facility to incorporate into its care-related policies and procedures including areas required by laws and regulations

bull Develop procedures and guidance for facility staff regarding contacting practitioners including information gathering and presentation change in condition assessment and when to contact the medical director

bull Review consider andor act upon consultant recommendations as appropriate that affect the facilitys resident care policies and procedures or the care of an individual resident

bull Review respond to and participate in federal state local and other external surveys and inspections and

bull Help review policies and procedures regarding the adequate protection of patients rights advance care planning and other ethical issues48

PBJ Medical Director Rolebull Quality of Care

bull Help the facility establish systems and methods for reviewing the quality and appropriateness of clinical care and other health-related services and provide appropriate feedback and

bull Participate in the facilitys quality improvement process

bull Advise on infection control issues and approve specific infection control policies to be incorporated into facility policies and procedures

bull Help the facility provide a safe and caring environment

bull Help promote employee health and safety and

bull Assist in the development and implementation of employee health policies and programs

bull Education Information and Communication

bull Promote a learning culture within the facility by educating informing and communicating

bull Provide information to help the facility provide care consistent with current standards of practice (defined as approaches to care procedures techniques and treatments that are based on research and or expert consensus and that are contained in current manuals textbooks and or publications or that are accepted adopted or promulgated by recognized organizations or national bodies)

bull Help the facility develop medical information and communication systems with staff patients and families and others

bull Represent the facility to the professional and lay community on medical and patient care issues

bull Maintain knowledge of the changing social regulatory political and economic factors that affect medical and health services of long term care patients and

bull Help establish appropriate relationships with other health care organizations

49

Dietician

bull When the dietary or food services supervisor is other than a registered dietitian the supervisor shall receive routine consultation and technical assistance from a registered dietitian (RD) Consultation time shall not be less than 4 hours every 60 days Additional consultation time may be needed based on the total number of patients incidence of nutrition-related health problems and food service management needs of the facility

50

Pharmacy Consultant

bull At least once per month a licensed pharmacist must perform a drug regimen review (DRR) for each resident The pharmacist must report any irregularities to the attending physician or director of nursing Furthermore these reports must be acted upon

51

What are the names for the Medicare Numberbull OSCAR -Online Survey Certification and Reporting

bull PTAN-PTAN number is assigned by Medicare to authenticate the provider when using the local Medicare Administrative Contractorrsquos (MAC) self-help tools like the IVR internet portal on-line application status etc Provider Transactions Access Number

bull CCN- CMS Certification Number

bull Medicare Number- example 23-

bull All of the above mean the same thing

52

QTSO

bull Once you are logged in the QTSO site bull You will have a state login to the site to access the various site specific

to your facilitybull Installing you will need administrator rights to your network

53

Medicare UpdateWhat are we seeing

54

CMS Final Rule On Returning Credits

httpswwwfederalregistergovarticles201602122016-02789medicare-program-reporting-and-returning-of-overpayments

55

Over Payment Rule

bull Medicare payments for non covered services

bull Medicare payments in excess of the allowable amount for an identified covered service

bull Errors and non reimbursable expenditures in cost reportsbull Duplicate payment

bull Receipt of Medicare payments when another payor had the primary responsibility for payment

56

Questions to MAC

bull Does the Medicare credit balance report change with this overpayment rule

bull No Medicare Credit Balances are still required at the end of each quarter

bull Will that still be the communication to let CMS or the MAC know that we have received an overpayment

bull Submission of Medicare Credit Balance is one form of communicating overpayments to CMS Other methods include submitting a voluntary refund with required claim information or the submission of a standard overpayment form

57

Questions to MAC

bull Will the MAC still deduct from a future RAbull If the recovery of the overpayment includes adjusting a claim then

the overpayment would be netted against future claims payments and reflected on the RA

bull Or will that process change with this new rulebull Process will remain the samebull Will NGS send communication out on thisbull Yes NGS will communicate this once the final rule is communicated

to the MACs by CMS However this could change depending on final CMS instructions

58

Final Rule on Returning Credits

bull Providers will want to immediately update their current policies governing overpayments in order to comply with this new rule which will take effect on March 14 2016

bull Providers and suppliers are required to use reasonable diligence to investigate credible information regarding overpayments through both proactive compliance efforts and reactive investigations

bull If an overpayment is identified then it must be repaid within 60 days An overpayment is identified when a person has or should have through the exercise of reasonable diligence determined that the person received an overpayment and quantified the amount

bull Providers and suppliers have a maximum of 8 months to report and return overpayments ndash up to 6 months to investigate and quantify the overpayment (ie to identify it) and up to 60 days to report and return the overpayment

59

Final Rule on Returning Credits

bull Providers and suppliers are required to report and return all overpayments within a 6-year lookback period

bull The cause and amount of the overpayment is irrelevant for the determination eg it was due to a mistake it was someone elsersquos fault it is a minor amount An overpayment is an overpayment and must be returned

bull Providers and suppliers must make their own determination to which entity to report and return the overpayment ie to the Medicare contractor or using the OIG Self Disclosure Protocol or the CMS Self Referral Disclosure Protocol

60

Final Rule on Returning Credits

bull Providers and suppliers may use the claims adjustment credit balance self-reported refund process or another appropriate process to report and return overpayments At this time there is no standard refund form to use

bull Failure to report and return an overpayment could subject the provider or supplier to False Claims Act liability Civil Monetary Penalties Law liability and exclusion from federal health care programs

61

P S amp R-Accountants will be asking for this information

The location you login into has changed it is now on EIDM EIDM is the acronym for CMS Enterprise Identity Management system which includes Identity Verification Access Management Authorization Assistance Workflow Tools and Identity Lifecycle Management functions

httpswwwcmsgovResearch-Statistics-Data-and-SystemsCMS-Information-TechnologyIACSCMS-Applications-Loginhtml

Go down the page and click on the PSampRSTARThis will take you to the login pagewill look the same as the old P S amp R didChanges Affecting PSampR System Access (Please Read) (posted 01292015)(Updated 5262015)is changingThe system which controls your PSampR user ID (currently IACS)The new system is referred to as EIDMThis will result in a different way to create new accounts or change passwords to existing accountsIf you already have an account in EIDM you may have to use that account for accessing PSampR after the transitionWhen is the change effectiveJune 13 2015What is staying the sameThe internet address for accessing PSampR remains the sameThe PSampR systemfunctionality is NOT changing 62

Medicare Advantage Payorsbull Medicare Advantage payors are pullingdenying payments on admissions if the patient was readmitted within 30 days after discharge The

client believes that the payors systematically denying payments for all readmissions within 30 days They believe this practice denies them due process to address whether the readmissions were justified and not due to a premature discharge of patient The payors seem to want to act like a QIO without having the same accountabilities of the QIO related to determinations of non-payment

bull Heres the QIO process under section 4240 of the QIO Manualbull 4240 - Readmission Review - (Rev 2 07-11-03)bull Readmission review involves admissions to an acute general short-term hospital occurring less than 31 calendar days from the date of

discharge from the same or another acute general short-term hospital (see sect1154(a)(13) and 42 CFR 47671(a)(8)(ii)) Neither the day of discharge nor the day of admission is counted when determining whether a readmission has occurred

bull A Medical Review Proceduresbull Obtain the appropriate medical records for the initial admission and readmission Perform case review on both stays Analyze the cases

specifically to determine whether the patient was prematurely discharged from the first confinement thus causing readmission Perform an analysis of the stay at the first hospital to determine the cause(s) and extent of any problem(s) (eg incomplete or substandard treatment) Consider the information available to the attending physician who discharged the patient from the first confinement Do not base a determination of a premature discharge on information that the physician or provider could not have known or events that could not have been anticipated at the time of discharge

bull Review both the initial admission and the readmission at the same time unless one of them has previously been reviewed In these cases use at a minimum the PRAF case summary of the other admission in addition to the medical record of the case under review

bull C Denialsbull Deny readmissions under the following circumstancesbull If the readmission was medically unnecessarybull If the readmission resulted from a premature discharge from the same hospital orbull If the readmission was a result of circumvention of PPS by the same hospital (see sect4255)bull With the QIO process there is an appeal within the QIO here the hospital is getting no opportunity to challenge the denials

63

Medicare Provider Enrollment Feebull Provider Enrollment Application Fee Amount for CY 2016bull On December 3 CMS issued a notice Provider Enrollment Application

Fee Amount for CY 2016 [CMSndash6066ndashN] Effective January 1 2016 the CY 2016 application fee is $554 for institutional providers that are

bull Initially enrolling in the Medicare or Medicaid program or the Childrens Health Insurance Program (CHIP)

bull Revalidating their Medicare Medicaid or CHIP enrollmentbull Adding a new Medicare practice locationbull This fee is required with any enrollment application submitted from

January 1 through December 31 2016

64

Medicare MAC-Higlas

bull Effective 142016 CMS has implemented a change to begin netting (offsetting) provider money across workloads within a single organization What this means is that any related providers conducting business in two different workloads (example New York and Maine) will have their money applied to any account receivables (AR) with a remaining balance owed to Medicare within both workloads For example Provider ABC is located in New York and is scheduled to receive a payment of $1000 on todays remittance advice Provider XYZ is related to provider ABC but is located in Maine and has ARs with a balance owed of $200 Provider ABCs $1000 payment will have the $200 applied against provider XYZs ARs resulting in a net payment of $800 This will be reflected on the remittance advice by the same PLB code as seen today for offsets for the $200

65

Two Midnight RuleChange January 1 2016 httpswwwcmsgovMedicareMedicare-Fee-for-Service-PaymentHospitalOutpatientPPSHospital-Outpatient-Regulations-and-Notices-ItemsCMS-1633-FChtml

66

Two Midnight Rulebull However effective January 1 2016 CMS will allow exceptions to the

Two-Midnight Benchmark to be determined on a case-by-case basis by the physician responsible for the care of the beneficiary subject to medical review Said differently Part A payment may be appropriate in some circumstances even though there is no expectation by the physician (or qualified ordering practitioner) of a two-midnight stay and one of the two pre-existing categorical exceptions (CMS ldquoinpatient onlyrdquo list and newly initiated mechanical ventilation) does not apply CMS has indicated that this change to the Two Midnight Rule is in response to stakeholder concern and CMSrsquos continued efforts to develop the most appropriate standard for determining Medicare Part A payment

67

Two Midnight Rulebull A new 42 CFR sect4123(a) provides that a patient is considered an

inpatient of a hospitalhellipif formally admitted as an inpatient pursuant to an order for inpatient admission by a physician or other qualified practitionerhellip The physician orders inpatient status when he or she expects the patient to require a stay that crosses at least 2 midnights[10] Stays expected to be shorter than at least two midnights are generally inappropriate for inpatient admission and inpatient payment under Medicare Part A unless the surgical procedure is specified by Medicare as inpatient only under sect41922(n)[11] The physicians expectationhellipshould be based on such complex medical factors as patient history and comorbidities the severity of signs and symptoms current medical needs and the risk of an adverse event[12] The physician order is part of physician certification of the medical necessity of hospital inpatient serviceshellip[13]

68

InPatient Vs Observation Conthellip

bull Physician certification which begins with an order for inpatient admission requires the physician to certify the reasons for the hospitalization the estimated time the patient will remain in the hospital and plans for post-hospital care if appropriate[14] The certification must be completed signed and documented in the medical record prior to discharge[15]

bull A physicians admission order has no presumptive weight and both the admission order and the physician certification will be evaluated in the context of the evidence in the medical record[16] CMS intends to provide additional information about what evidence in the medical record means in future instructions and manual revisions[17]

69

Two Midnight Rulebull Although the new case-by-case exception appears to be inherently

subjective to a certain extent CMS states that the following factors (among others) would be relevant to determining whether a patient requires inpatient admission under the expanded policy

bull The severity of the signs and symptoms exhibited by the patient bull The medical predictability of something adverse happening to the patient

and bull The need for diagnostic studies that appropriately are outpatient services

(that is their performance does not ordinarily require the patient to remain at the hospital for 24 hours or more)

bull CMS also notes that an inpatient admission (and Part A payment) should be ldquorare and unusualrdquo for minor surgical procedures or other treatment that is expected to keep the patient in the hospital ldquofor only a few hoursrdquo or for a period of time that ldquodoes not span at least overnightrdquo (thus a subset of stays not meeting the Two Midnight Benchmark) CMS indicates that such cases will be prioritized for medical review

70

Health Data Insights amp Medicare Plus Blue

RAC (Retrospective Audits)

71

HDI Health Data amp Med Plus Blue

bull httpwwwhealthdatainsightscombull Blue Cross Medicare Advantage Auditsbull Facilities seeing 10 to 15 requests for Medical Recordsbull In January amp Feburarybull Selected Health Data Insights because they were a premier Audit

Vendor for CMS Recovery Audit Contractor (RAC) demonstration Project They are a audit vendor for Humana

bull Providers not sending Medical Record will get technical denial and lose payments

72

Health Data InSight

bull In 2010 they began the Hospital Reviewbull Medicare Advantage encounter datandashCMS oversight of data integrity OIG

2016bull We will review CMSs oversight of MA encounter data validation and assess

the extent to which CMSrsquos Integrated Data Repository contains timely valid and complete MA encounter data In 2012 CMS began collecting from MA organizations a more comprehensive set of encounter data reflecting the items and services provided to MA plan enrollees Prior CMS and OIG audits have indicated vulnerabilities in the accuracy of data reporting by MA organizations Realizing the potential benefits of the MA encounter data for payment and program integrity oversight is contingent upon the datarsquos completeness validity and timeliness (OEI 03-15-00060 expected issue date FY 2017)

73

Pepper Reports

bull httpswwwpepperresourcesorg

bull Program for Evaluating Payment Patterns Electronic Report ( PEPPER)

bull Annually on or about April 18 2016 will be released

bull Pepper Portal httpssecurefiletmforg

74

CGI Technologies and Solutions Inc httpracbcgicomContactInfoaspxst=1

bull Indiana bull Michiganbull Minnesotabull Illinoisbull Kentuckybull Ohiobull Wisconsin CGI Technologies and Solutions Incbull For general and administrative questions regarding client service outreach

quality assurance or project-specific issues contactbull 1877316RACB (7222)bull Email racbcgicom Tamara Tate Tamaratatecmshhsgovbull 4107861288

75

CGI Federal RAC

bull CGI Federal RAC Region Bbull Email racbcgicombull Phone 1-877-316-RACB (7222)bull Mailing Addressbull Send medical records as followsbull Medical records for Indiana Illinois Kentucky Michigan Ohio Wisconsin

Minnesota DME and Home Health CGI Federal Inc Attn RACB Imaging Dept 1001 Lakeside Ave Suite 800 Cleveland OH 44114

bull If submitting paper records please send medical records as follows For Therapy Reviews CGI Federal Inc Attn RACB Imaging 1001 Lakeside Avenue Suite 800 Cleveland OH 44114

76

How to survive RAC Audit

bull National health expenditures totaled $1679 Billion in 2003 bull National health expenditures were 153 of GROSS Domestic Product

(GDP) in 2003 bull Health care cost increasing at +9 per year bull Doomsday predictions of Medicare running out bull Congressional Action

77

RAC Audits

bull Medicare Modernization Act (MMA) of 2003Mandated a three year audit demonstration project 2005-2008

bull Appoint audit contractors to review Medicare billings for proper coding DRG assignment and medical necessity

bull Audits will apply to all health care providers (hospitals physicians homecare dme etc)

bull Audit contractors to be paid on a contingency basis a percentage of overpayments recovered

78

How Did we get here

bull Overpayments collected due to errors in Medically Unnecessary Services ndash 40

bull Incorrectly Coded ndash 35

bull Other ndash 17

bull NoInsufficient Documentation ndash 8

79

Where are we now

bull All RACrsquos completed required provider outreachAccess to Medicare billing data base given to all RAC RAC review methodology

bull Automated Review-Black amp White Issues (current) bull DRG Validation-complex review (current) bull Complex Review for coding errors (current) bull DME Medical Necessity Reviews ndashcomplex review (calendar year

2010) bull Medical Necessity Reviews-complex review (calendar year 2010)

80

RAC Reviews

bull Responsibilities of the Team Leader bull Must learn each insurance provider participating in a RAC or RAC type

program bull What are their operating rulesbull What is their appeal process Time limits

May be different process for each insurance provider bull Develop a response team

Identify who does what when why and alternate bull individual

Build and develop a manual process Review of computerized system

81

Priority Health SCIO Health Analytics

bull httpswwwsciohealthanalyticscomcore-capabilitiespayment-integrityfacility-auditsskilled-nursing-facility-audits

bull Claims for Medicare members treated at Skilled Nursing Facilities are reimbursed based on the patientsrsquo RUG (Resource Utilization Group) score which is determined using the Minimum Data Set (MDS) Using SCIOs robust analytics claims andor providers that merit review are selected for audit SCIOs auditors conduct a detailed review of the complete medical record and associated MDS to determine if the billed RUG score is valid In the event the review determines that an incorrect RUG score was billed SCIOreg provides the valid score reports the reason the change was necessary and calculates the resulting overpayment

82

+ Cheer

Onward and Upward she shall prevail We are here to care for the residents and provide a wonderful

service

13 83

84

References

bull Priority Healthbull Blue Crossbull Medicaidbull Medicare

85

  • Medicare Mange Care amp Medicaid Changes in the New World We Live In
  • Medicaid
  • NEW Medicaid Change MIlogin
  • Blueprint for Health Innovation MI
  • Provider Enrollment Electronic Signature Form Submission Process MSA 15-54
  • Provider Enrollment Electronic Signature Form Submission Process
  • Provider Enrollment Domain Administrator
  • Medicaid Coinsurance Medicare Advantage
  • Slide Number 9
  • Lawsuit DHS Changes on Caregivers
  • TPL Medicaid Change
  • CHAMPS Member Screen
  • LOC dropping off Not Due to MI Health
  • Issues
  • Secure Email Information
  • Medicaid amp Hospice
  • Medicaid
  • Medicaid Medicare Buy In
  • Manage Medicaid
  • Healthy Michigan Residents
  • Healthy Michigan Medicaid Days
  • McLaren Health Plan
  • Manage Medicaid Plans January 1
  • Slide Number 24
  • MI Health Link
  • MI Health Link 2565
  • What are the Names
  • MI Health Dual Eligible
  • MI Health LOC
  • LOC Medicaid
  • Medicaid Redetermination and MHL Enrollment
  • MI Health Link Portals
  • MI Health Authorizations
  • MI Health Issues
  • LOC 02 dropping MI Health Issues
  • PPA Offset
  • LOCD
  • MI Health Issues-New
  • ACO
  • Families Receiving Letters for ACO
  • ACO What is It
  • Payroll Based Journal
  • Slide Number 43
  • If you submit data manually should you also submit it through the XML
  • Staffing Submission Frequently Asked Questions
  • CMS defines
  • Slide Number 47
  • PBJ Medical Director Role
  • PBJ Medical Director Role
  • Dietician
  • Pharmacy Consultant
  • What are the names for the Medicare Number
  • QTSO
  • Medicare Update
  • CMS Final Rule On Returning Credits
  • Over Payment Rule
  • Questions to MAC
  • Questions to MAC
  • Final Rule on Returning Credits
  • Final Rule on Returning Credits
  • Final Rule on Returning Credits
  • Slide Number 62
  • Medicare Advantage Payors
  • Medicare Provider Enrollment Fee
  • Medicare MAC-Higlas
  • Two Midnight Rule
  • Two Midnight Rule
  • Two Midnight Rule
  • InPatient Vs Observation Conthellip
  • Two Midnight Rule
  • Health Data Insights amp Medicare Plus Blue
  • HDI Health Data amp Med Plus Blue
  • Health Data InSight
  • Pepper Reports
  • CGI Technologies and Solutions Inc httpracbcgicomContactInfoaspxst=1
  • CGI Federal RAC
  • How to survive RAC Audit
  • RAC Audits
  • How Did we get here
  • Where are we now
  • RAC Reviews
  • Priority Health SCIO Health Analytics
  • Cheer
  • References
Page 45: Medicare, Mange Care & Medicaid Changes in the New World we live in

45

Staffing Submission Frequently Asked Questions

bull ldquoWho are direct care staffrdquo (Who do we submit data for)bull Submission of data for contract staffbull Medical directors and consultantsbull Staff switching roles or tasks throughout the daybull Hours paid vs hours worked ndash Must be verifiablebull Public postingQuality MeasuresFive Starbull Enforcementbull Voluntary submission risks (noneSo register now)

CMS defines

bull 37 job title codes that are required to match employees to the number of hours each direct care function was performed It is important to work with your teams to define the workers that contribute to each job type and how those daily worked hours are recorded and converted to a PBJ submission

bull The PBJ does include some more specific job descriptions than the 671 For example the PBJ system includes job descriptions for RNs with administrative duties and LPNs with administrative duties versus the 671rsquos more general ldquoNurses with Administrative Duties

Page 46

47

PBJ Medical Director Rolebull Physician Leadership

bull Help the facility ensure that patients have appropriate physician coverage and ensure the provision of physician and health care practitioner services and

bull Help the facility develop a process for reviewing physician and health care practitioner credentials

bull Provide specific guidance for physician performance expectations

bull Help the facility ensure that a system is in place for monitoring the performance of health care practitioners and

bull Facilitate feedback to physicians and other health care practitioners on performance and practices

bull Patient Care - Clinical Leadership

bull Participate in administrative decision-making and the development of policies and procedures related to patient care

bull Help develop approve and implement specific clinical practices for the facility to incorporate into its care-related policies and procedures including areas required by laws and regulations

bull Develop procedures and guidance for facility staff regarding contacting practitioners including information gathering and presentation change in condition assessment and when to contact the medical director

bull Review consider andor act upon consultant recommendations as appropriate that affect the facilitys resident care policies and procedures or the care of an individual resident

bull Review respond to and participate in federal state local and other external surveys and inspections and

bull Help review policies and procedures regarding the adequate protection of patients rights advance care planning and other ethical issues48

PBJ Medical Director Rolebull Quality of Care

bull Help the facility establish systems and methods for reviewing the quality and appropriateness of clinical care and other health-related services and provide appropriate feedback and

bull Participate in the facilitys quality improvement process

bull Advise on infection control issues and approve specific infection control policies to be incorporated into facility policies and procedures

bull Help the facility provide a safe and caring environment

bull Help promote employee health and safety and

bull Assist in the development and implementation of employee health policies and programs

bull Education Information and Communication

bull Promote a learning culture within the facility by educating informing and communicating

bull Provide information to help the facility provide care consistent with current standards of practice (defined as approaches to care procedures techniques and treatments that are based on research and or expert consensus and that are contained in current manuals textbooks and or publications or that are accepted adopted or promulgated by recognized organizations or national bodies)

bull Help the facility develop medical information and communication systems with staff patients and families and others

bull Represent the facility to the professional and lay community on medical and patient care issues

bull Maintain knowledge of the changing social regulatory political and economic factors that affect medical and health services of long term care patients and

bull Help establish appropriate relationships with other health care organizations

49

Dietician

bull When the dietary or food services supervisor is other than a registered dietitian the supervisor shall receive routine consultation and technical assistance from a registered dietitian (RD) Consultation time shall not be less than 4 hours every 60 days Additional consultation time may be needed based on the total number of patients incidence of nutrition-related health problems and food service management needs of the facility

50

Pharmacy Consultant

bull At least once per month a licensed pharmacist must perform a drug regimen review (DRR) for each resident The pharmacist must report any irregularities to the attending physician or director of nursing Furthermore these reports must be acted upon

51

What are the names for the Medicare Numberbull OSCAR -Online Survey Certification and Reporting

bull PTAN-PTAN number is assigned by Medicare to authenticate the provider when using the local Medicare Administrative Contractorrsquos (MAC) self-help tools like the IVR internet portal on-line application status etc Provider Transactions Access Number

bull CCN- CMS Certification Number

bull Medicare Number- example 23-

bull All of the above mean the same thing

52

QTSO

bull Once you are logged in the QTSO site bull You will have a state login to the site to access the various site specific

to your facilitybull Installing you will need administrator rights to your network

53

Medicare UpdateWhat are we seeing

54

CMS Final Rule On Returning Credits

httpswwwfederalregistergovarticles201602122016-02789medicare-program-reporting-and-returning-of-overpayments

55

Over Payment Rule

bull Medicare payments for non covered services

bull Medicare payments in excess of the allowable amount for an identified covered service

bull Errors and non reimbursable expenditures in cost reportsbull Duplicate payment

bull Receipt of Medicare payments when another payor had the primary responsibility for payment

56

Questions to MAC

bull Does the Medicare credit balance report change with this overpayment rule

bull No Medicare Credit Balances are still required at the end of each quarter

bull Will that still be the communication to let CMS or the MAC know that we have received an overpayment

bull Submission of Medicare Credit Balance is one form of communicating overpayments to CMS Other methods include submitting a voluntary refund with required claim information or the submission of a standard overpayment form

57

Questions to MAC

bull Will the MAC still deduct from a future RAbull If the recovery of the overpayment includes adjusting a claim then

the overpayment would be netted against future claims payments and reflected on the RA

bull Or will that process change with this new rulebull Process will remain the samebull Will NGS send communication out on thisbull Yes NGS will communicate this once the final rule is communicated

to the MACs by CMS However this could change depending on final CMS instructions

58

Final Rule on Returning Credits

bull Providers will want to immediately update their current policies governing overpayments in order to comply with this new rule which will take effect on March 14 2016

bull Providers and suppliers are required to use reasonable diligence to investigate credible information regarding overpayments through both proactive compliance efforts and reactive investigations

bull If an overpayment is identified then it must be repaid within 60 days An overpayment is identified when a person has or should have through the exercise of reasonable diligence determined that the person received an overpayment and quantified the amount

bull Providers and suppliers have a maximum of 8 months to report and return overpayments ndash up to 6 months to investigate and quantify the overpayment (ie to identify it) and up to 60 days to report and return the overpayment

59

Final Rule on Returning Credits

bull Providers and suppliers are required to report and return all overpayments within a 6-year lookback period

bull The cause and amount of the overpayment is irrelevant for the determination eg it was due to a mistake it was someone elsersquos fault it is a minor amount An overpayment is an overpayment and must be returned

bull Providers and suppliers must make their own determination to which entity to report and return the overpayment ie to the Medicare contractor or using the OIG Self Disclosure Protocol or the CMS Self Referral Disclosure Protocol

60

Final Rule on Returning Credits

bull Providers and suppliers may use the claims adjustment credit balance self-reported refund process or another appropriate process to report and return overpayments At this time there is no standard refund form to use

bull Failure to report and return an overpayment could subject the provider or supplier to False Claims Act liability Civil Monetary Penalties Law liability and exclusion from federal health care programs

61

P S amp R-Accountants will be asking for this information

The location you login into has changed it is now on EIDM EIDM is the acronym for CMS Enterprise Identity Management system which includes Identity Verification Access Management Authorization Assistance Workflow Tools and Identity Lifecycle Management functions

httpswwwcmsgovResearch-Statistics-Data-and-SystemsCMS-Information-TechnologyIACSCMS-Applications-Loginhtml

Go down the page and click on the PSampRSTARThis will take you to the login pagewill look the same as the old P S amp R didChanges Affecting PSampR System Access (Please Read) (posted 01292015)(Updated 5262015)is changingThe system which controls your PSampR user ID (currently IACS)The new system is referred to as EIDMThis will result in a different way to create new accounts or change passwords to existing accountsIf you already have an account in EIDM you may have to use that account for accessing PSampR after the transitionWhen is the change effectiveJune 13 2015What is staying the sameThe internet address for accessing PSampR remains the sameThe PSampR systemfunctionality is NOT changing 62

Medicare Advantage Payorsbull Medicare Advantage payors are pullingdenying payments on admissions if the patient was readmitted within 30 days after discharge The

client believes that the payors systematically denying payments for all readmissions within 30 days They believe this practice denies them due process to address whether the readmissions were justified and not due to a premature discharge of patient The payors seem to want to act like a QIO without having the same accountabilities of the QIO related to determinations of non-payment

bull Heres the QIO process under section 4240 of the QIO Manualbull 4240 - Readmission Review - (Rev 2 07-11-03)bull Readmission review involves admissions to an acute general short-term hospital occurring less than 31 calendar days from the date of

discharge from the same or another acute general short-term hospital (see sect1154(a)(13) and 42 CFR 47671(a)(8)(ii)) Neither the day of discharge nor the day of admission is counted when determining whether a readmission has occurred

bull A Medical Review Proceduresbull Obtain the appropriate medical records for the initial admission and readmission Perform case review on both stays Analyze the cases

specifically to determine whether the patient was prematurely discharged from the first confinement thus causing readmission Perform an analysis of the stay at the first hospital to determine the cause(s) and extent of any problem(s) (eg incomplete or substandard treatment) Consider the information available to the attending physician who discharged the patient from the first confinement Do not base a determination of a premature discharge on information that the physician or provider could not have known or events that could not have been anticipated at the time of discharge

bull Review both the initial admission and the readmission at the same time unless one of them has previously been reviewed In these cases use at a minimum the PRAF case summary of the other admission in addition to the medical record of the case under review

bull C Denialsbull Deny readmissions under the following circumstancesbull If the readmission was medically unnecessarybull If the readmission resulted from a premature discharge from the same hospital orbull If the readmission was a result of circumvention of PPS by the same hospital (see sect4255)bull With the QIO process there is an appeal within the QIO here the hospital is getting no opportunity to challenge the denials

63

Medicare Provider Enrollment Feebull Provider Enrollment Application Fee Amount for CY 2016bull On December 3 CMS issued a notice Provider Enrollment Application

Fee Amount for CY 2016 [CMSndash6066ndashN] Effective January 1 2016 the CY 2016 application fee is $554 for institutional providers that are

bull Initially enrolling in the Medicare or Medicaid program or the Childrens Health Insurance Program (CHIP)

bull Revalidating their Medicare Medicaid or CHIP enrollmentbull Adding a new Medicare practice locationbull This fee is required with any enrollment application submitted from

January 1 through December 31 2016

64

Medicare MAC-Higlas

bull Effective 142016 CMS has implemented a change to begin netting (offsetting) provider money across workloads within a single organization What this means is that any related providers conducting business in two different workloads (example New York and Maine) will have their money applied to any account receivables (AR) with a remaining balance owed to Medicare within both workloads For example Provider ABC is located in New York and is scheduled to receive a payment of $1000 on todays remittance advice Provider XYZ is related to provider ABC but is located in Maine and has ARs with a balance owed of $200 Provider ABCs $1000 payment will have the $200 applied against provider XYZs ARs resulting in a net payment of $800 This will be reflected on the remittance advice by the same PLB code as seen today for offsets for the $200

65

Two Midnight RuleChange January 1 2016 httpswwwcmsgovMedicareMedicare-Fee-for-Service-PaymentHospitalOutpatientPPSHospital-Outpatient-Regulations-and-Notices-ItemsCMS-1633-FChtml

66

Two Midnight Rulebull However effective January 1 2016 CMS will allow exceptions to the

Two-Midnight Benchmark to be determined on a case-by-case basis by the physician responsible for the care of the beneficiary subject to medical review Said differently Part A payment may be appropriate in some circumstances even though there is no expectation by the physician (or qualified ordering practitioner) of a two-midnight stay and one of the two pre-existing categorical exceptions (CMS ldquoinpatient onlyrdquo list and newly initiated mechanical ventilation) does not apply CMS has indicated that this change to the Two Midnight Rule is in response to stakeholder concern and CMSrsquos continued efforts to develop the most appropriate standard for determining Medicare Part A payment

67

Two Midnight Rulebull A new 42 CFR sect4123(a) provides that a patient is considered an

inpatient of a hospitalhellipif formally admitted as an inpatient pursuant to an order for inpatient admission by a physician or other qualified practitionerhellip The physician orders inpatient status when he or she expects the patient to require a stay that crosses at least 2 midnights[10] Stays expected to be shorter than at least two midnights are generally inappropriate for inpatient admission and inpatient payment under Medicare Part A unless the surgical procedure is specified by Medicare as inpatient only under sect41922(n)[11] The physicians expectationhellipshould be based on such complex medical factors as patient history and comorbidities the severity of signs and symptoms current medical needs and the risk of an adverse event[12] The physician order is part of physician certification of the medical necessity of hospital inpatient serviceshellip[13]

68

InPatient Vs Observation Conthellip

bull Physician certification which begins with an order for inpatient admission requires the physician to certify the reasons for the hospitalization the estimated time the patient will remain in the hospital and plans for post-hospital care if appropriate[14] The certification must be completed signed and documented in the medical record prior to discharge[15]

bull A physicians admission order has no presumptive weight and both the admission order and the physician certification will be evaluated in the context of the evidence in the medical record[16] CMS intends to provide additional information about what evidence in the medical record means in future instructions and manual revisions[17]

69

Two Midnight Rulebull Although the new case-by-case exception appears to be inherently

subjective to a certain extent CMS states that the following factors (among others) would be relevant to determining whether a patient requires inpatient admission under the expanded policy

bull The severity of the signs and symptoms exhibited by the patient bull The medical predictability of something adverse happening to the patient

and bull The need for diagnostic studies that appropriately are outpatient services

(that is their performance does not ordinarily require the patient to remain at the hospital for 24 hours or more)

bull CMS also notes that an inpatient admission (and Part A payment) should be ldquorare and unusualrdquo for minor surgical procedures or other treatment that is expected to keep the patient in the hospital ldquofor only a few hoursrdquo or for a period of time that ldquodoes not span at least overnightrdquo (thus a subset of stays not meeting the Two Midnight Benchmark) CMS indicates that such cases will be prioritized for medical review

70

Health Data Insights amp Medicare Plus Blue

RAC (Retrospective Audits)

71

HDI Health Data amp Med Plus Blue

bull httpwwwhealthdatainsightscombull Blue Cross Medicare Advantage Auditsbull Facilities seeing 10 to 15 requests for Medical Recordsbull In January amp Feburarybull Selected Health Data Insights because they were a premier Audit

Vendor for CMS Recovery Audit Contractor (RAC) demonstration Project They are a audit vendor for Humana

bull Providers not sending Medical Record will get technical denial and lose payments

72

Health Data InSight

bull In 2010 they began the Hospital Reviewbull Medicare Advantage encounter datandashCMS oversight of data integrity OIG

2016bull We will review CMSs oversight of MA encounter data validation and assess

the extent to which CMSrsquos Integrated Data Repository contains timely valid and complete MA encounter data In 2012 CMS began collecting from MA organizations a more comprehensive set of encounter data reflecting the items and services provided to MA plan enrollees Prior CMS and OIG audits have indicated vulnerabilities in the accuracy of data reporting by MA organizations Realizing the potential benefits of the MA encounter data for payment and program integrity oversight is contingent upon the datarsquos completeness validity and timeliness (OEI 03-15-00060 expected issue date FY 2017)

73

Pepper Reports

bull httpswwwpepperresourcesorg

bull Program for Evaluating Payment Patterns Electronic Report ( PEPPER)

bull Annually on or about April 18 2016 will be released

bull Pepper Portal httpssecurefiletmforg

74

CGI Technologies and Solutions Inc httpracbcgicomContactInfoaspxst=1

bull Indiana bull Michiganbull Minnesotabull Illinoisbull Kentuckybull Ohiobull Wisconsin CGI Technologies and Solutions Incbull For general and administrative questions regarding client service outreach

quality assurance or project-specific issues contactbull 1877316RACB (7222)bull Email racbcgicom Tamara Tate Tamaratatecmshhsgovbull 4107861288

75

CGI Federal RAC

bull CGI Federal RAC Region Bbull Email racbcgicombull Phone 1-877-316-RACB (7222)bull Mailing Addressbull Send medical records as followsbull Medical records for Indiana Illinois Kentucky Michigan Ohio Wisconsin

Minnesota DME and Home Health CGI Federal Inc Attn RACB Imaging Dept 1001 Lakeside Ave Suite 800 Cleveland OH 44114

bull If submitting paper records please send medical records as follows For Therapy Reviews CGI Federal Inc Attn RACB Imaging 1001 Lakeside Avenue Suite 800 Cleveland OH 44114

76

How to survive RAC Audit

bull National health expenditures totaled $1679 Billion in 2003 bull National health expenditures were 153 of GROSS Domestic Product

(GDP) in 2003 bull Health care cost increasing at +9 per year bull Doomsday predictions of Medicare running out bull Congressional Action

77

RAC Audits

bull Medicare Modernization Act (MMA) of 2003Mandated a three year audit demonstration project 2005-2008

bull Appoint audit contractors to review Medicare billings for proper coding DRG assignment and medical necessity

bull Audits will apply to all health care providers (hospitals physicians homecare dme etc)

bull Audit contractors to be paid on a contingency basis a percentage of overpayments recovered

78

How Did we get here

bull Overpayments collected due to errors in Medically Unnecessary Services ndash 40

bull Incorrectly Coded ndash 35

bull Other ndash 17

bull NoInsufficient Documentation ndash 8

79

Where are we now

bull All RACrsquos completed required provider outreachAccess to Medicare billing data base given to all RAC RAC review methodology

bull Automated Review-Black amp White Issues (current) bull DRG Validation-complex review (current) bull Complex Review for coding errors (current) bull DME Medical Necessity Reviews ndashcomplex review (calendar year

2010) bull Medical Necessity Reviews-complex review (calendar year 2010)

80

RAC Reviews

bull Responsibilities of the Team Leader bull Must learn each insurance provider participating in a RAC or RAC type

program bull What are their operating rulesbull What is their appeal process Time limits

May be different process for each insurance provider bull Develop a response team

Identify who does what when why and alternate bull individual

Build and develop a manual process Review of computerized system

81

Priority Health SCIO Health Analytics

bull httpswwwsciohealthanalyticscomcore-capabilitiespayment-integrityfacility-auditsskilled-nursing-facility-audits

bull Claims for Medicare members treated at Skilled Nursing Facilities are reimbursed based on the patientsrsquo RUG (Resource Utilization Group) score which is determined using the Minimum Data Set (MDS) Using SCIOs robust analytics claims andor providers that merit review are selected for audit SCIOs auditors conduct a detailed review of the complete medical record and associated MDS to determine if the billed RUG score is valid In the event the review determines that an incorrect RUG score was billed SCIOreg provides the valid score reports the reason the change was necessary and calculates the resulting overpayment

82

+ Cheer

Onward and Upward she shall prevail We are here to care for the residents and provide a wonderful

service

13 83

84

References

bull Priority Healthbull Blue Crossbull Medicaidbull Medicare

85

  • Medicare Mange Care amp Medicaid Changes in the New World We Live In
  • Medicaid
  • NEW Medicaid Change MIlogin
  • Blueprint for Health Innovation MI
  • Provider Enrollment Electronic Signature Form Submission Process MSA 15-54
  • Provider Enrollment Electronic Signature Form Submission Process
  • Provider Enrollment Domain Administrator
  • Medicaid Coinsurance Medicare Advantage
  • Slide Number 9
  • Lawsuit DHS Changes on Caregivers
  • TPL Medicaid Change
  • CHAMPS Member Screen
  • LOC dropping off Not Due to MI Health
  • Issues
  • Secure Email Information
  • Medicaid amp Hospice
  • Medicaid
  • Medicaid Medicare Buy In
  • Manage Medicaid
  • Healthy Michigan Residents
  • Healthy Michigan Medicaid Days
  • McLaren Health Plan
  • Manage Medicaid Plans January 1
  • Slide Number 24
  • MI Health Link
  • MI Health Link 2565
  • What are the Names
  • MI Health Dual Eligible
  • MI Health LOC
  • LOC Medicaid
  • Medicaid Redetermination and MHL Enrollment
  • MI Health Link Portals
  • MI Health Authorizations
  • MI Health Issues
  • LOC 02 dropping MI Health Issues
  • PPA Offset
  • LOCD
  • MI Health Issues-New
  • ACO
  • Families Receiving Letters for ACO
  • ACO What is It
  • Payroll Based Journal
  • Slide Number 43
  • If you submit data manually should you also submit it through the XML
  • Staffing Submission Frequently Asked Questions
  • CMS defines
  • Slide Number 47
  • PBJ Medical Director Role
  • PBJ Medical Director Role
  • Dietician
  • Pharmacy Consultant
  • What are the names for the Medicare Number
  • QTSO
  • Medicare Update
  • CMS Final Rule On Returning Credits
  • Over Payment Rule
  • Questions to MAC
  • Questions to MAC
  • Final Rule on Returning Credits
  • Final Rule on Returning Credits
  • Final Rule on Returning Credits
  • Slide Number 62
  • Medicare Advantage Payors
  • Medicare Provider Enrollment Fee
  • Medicare MAC-Higlas
  • Two Midnight Rule
  • Two Midnight Rule
  • Two Midnight Rule
  • InPatient Vs Observation Conthellip
  • Two Midnight Rule
  • Health Data Insights amp Medicare Plus Blue
  • HDI Health Data amp Med Plus Blue
  • Health Data InSight
  • Pepper Reports
  • CGI Technologies and Solutions Inc httpracbcgicomContactInfoaspxst=1
  • CGI Federal RAC
  • How to survive RAC Audit
  • RAC Audits
  • How Did we get here
  • Where are we now
  • RAC Reviews
  • Priority Health SCIO Health Analytics
  • Cheer
  • References
Page 46: Medicare, Mange Care & Medicaid Changes in the New World we live in

CMS defines

bull 37 job title codes that are required to match employees to the number of hours each direct care function was performed It is important to work with your teams to define the workers that contribute to each job type and how those daily worked hours are recorded and converted to a PBJ submission

bull The PBJ does include some more specific job descriptions than the 671 For example the PBJ system includes job descriptions for RNs with administrative duties and LPNs with administrative duties versus the 671rsquos more general ldquoNurses with Administrative Duties

Page 46

47

PBJ Medical Director Rolebull Physician Leadership

bull Help the facility ensure that patients have appropriate physician coverage and ensure the provision of physician and health care practitioner services and

bull Help the facility develop a process for reviewing physician and health care practitioner credentials

bull Provide specific guidance for physician performance expectations

bull Help the facility ensure that a system is in place for monitoring the performance of health care practitioners and

bull Facilitate feedback to physicians and other health care practitioners on performance and practices

bull Patient Care - Clinical Leadership

bull Participate in administrative decision-making and the development of policies and procedures related to patient care

bull Help develop approve and implement specific clinical practices for the facility to incorporate into its care-related policies and procedures including areas required by laws and regulations

bull Develop procedures and guidance for facility staff regarding contacting practitioners including information gathering and presentation change in condition assessment and when to contact the medical director

bull Review consider andor act upon consultant recommendations as appropriate that affect the facilitys resident care policies and procedures or the care of an individual resident

bull Review respond to and participate in federal state local and other external surveys and inspections and

bull Help review policies and procedures regarding the adequate protection of patients rights advance care planning and other ethical issues48

PBJ Medical Director Rolebull Quality of Care

bull Help the facility establish systems and methods for reviewing the quality and appropriateness of clinical care and other health-related services and provide appropriate feedback and

bull Participate in the facilitys quality improvement process

bull Advise on infection control issues and approve specific infection control policies to be incorporated into facility policies and procedures

bull Help the facility provide a safe and caring environment

bull Help promote employee health and safety and

bull Assist in the development and implementation of employee health policies and programs

bull Education Information and Communication

bull Promote a learning culture within the facility by educating informing and communicating

bull Provide information to help the facility provide care consistent with current standards of practice (defined as approaches to care procedures techniques and treatments that are based on research and or expert consensus and that are contained in current manuals textbooks and or publications or that are accepted adopted or promulgated by recognized organizations or national bodies)

bull Help the facility develop medical information and communication systems with staff patients and families and others

bull Represent the facility to the professional and lay community on medical and patient care issues

bull Maintain knowledge of the changing social regulatory political and economic factors that affect medical and health services of long term care patients and

bull Help establish appropriate relationships with other health care organizations

49

Dietician

bull When the dietary or food services supervisor is other than a registered dietitian the supervisor shall receive routine consultation and technical assistance from a registered dietitian (RD) Consultation time shall not be less than 4 hours every 60 days Additional consultation time may be needed based on the total number of patients incidence of nutrition-related health problems and food service management needs of the facility

50

Pharmacy Consultant

bull At least once per month a licensed pharmacist must perform a drug regimen review (DRR) for each resident The pharmacist must report any irregularities to the attending physician or director of nursing Furthermore these reports must be acted upon

51

What are the names for the Medicare Numberbull OSCAR -Online Survey Certification and Reporting

bull PTAN-PTAN number is assigned by Medicare to authenticate the provider when using the local Medicare Administrative Contractorrsquos (MAC) self-help tools like the IVR internet portal on-line application status etc Provider Transactions Access Number

bull CCN- CMS Certification Number

bull Medicare Number- example 23-

bull All of the above mean the same thing

52

QTSO

bull Once you are logged in the QTSO site bull You will have a state login to the site to access the various site specific

to your facilitybull Installing you will need administrator rights to your network

53

Medicare UpdateWhat are we seeing

54

CMS Final Rule On Returning Credits

httpswwwfederalregistergovarticles201602122016-02789medicare-program-reporting-and-returning-of-overpayments

55

Over Payment Rule

bull Medicare payments for non covered services

bull Medicare payments in excess of the allowable amount for an identified covered service

bull Errors and non reimbursable expenditures in cost reportsbull Duplicate payment

bull Receipt of Medicare payments when another payor had the primary responsibility for payment

56

Questions to MAC

bull Does the Medicare credit balance report change with this overpayment rule

bull No Medicare Credit Balances are still required at the end of each quarter

bull Will that still be the communication to let CMS or the MAC know that we have received an overpayment

bull Submission of Medicare Credit Balance is one form of communicating overpayments to CMS Other methods include submitting a voluntary refund with required claim information or the submission of a standard overpayment form

57

Questions to MAC

bull Will the MAC still deduct from a future RAbull If the recovery of the overpayment includes adjusting a claim then

the overpayment would be netted against future claims payments and reflected on the RA

bull Or will that process change with this new rulebull Process will remain the samebull Will NGS send communication out on thisbull Yes NGS will communicate this once the final rule is communicated

to the MACs by CMS However this could change depending on final CMS instructions

58

Final Rule on Returning Credits

bull Providers will want to immediately update their current policies governing overpayments in order to comply with this new rule which will take effect on March 14 2016

bull Providers and suppliers are required to use reasonable diligence to investigate credible information regarding overpayments through both proactive compliance efforts and reactive investigations

bull If an overpayment is identified then it must be repaid within 60 days An overpayment is identified when a person has or should have through the exercise of reasonable diligence determined that the person received an overpayment and quantified the amount

bull Providers and suppliers have a maximum of 8 months to report and return overpayments ndash up to 6 months to investigate and quantify the overpayment (ie to identify it) and up to 60 days to report and return the overpayment

59

Final Rule on Returning Credits

bull Providers and suppliers are required to report and return all overpayments within a 6-year lookback period

bull The cause and amount of the overpayment is irrelevant for the determination eg it was due to a mistake it was someone elsersquos fault it is a minor amount An overpayment is an overpayment and must be returned

bull Providers and suppliers must make their own determination to which entity to report and return the overpayment ie to the Medicare contractor or using the OIG Self Disclosure Protocol or the CMS Self Referral Disclosure Protocol

60

Final Rule on Returning Credits

bull Providers and suppliers may use the claims adjustment credit balance self-reported refund process or another appropriate process to report and return overpayments At this time there is no standard refund form to use

bull Failure to report and return an overpayment could subject the provider or supplier to False Claims Act liability Civil Monetary Penalties Law liability and exclusion from federal health care programs

61

P S amp R-Accountants will be asking for this information

The location you login into has changed it is now on EIDM EIDM is the acronym for CMS Enterprise Identity Management system which includes Identity Verification Access Management Authorization Assistance Workflow Tools and Identity Lifecycle Management functions

httpswwwcmsgovResearch-Statistics-Data-and-SystemsCMS-Information-TechnologyIACSCMS-Applications-Loginhtml

Go down the page and click on the PSampRSTARThis will take you to the login pagewill look the same as the old P S amp R didChanges Affecting PSampR System Access (Please Read) (posted 01292015)(Updated 5262015)is changingThe system which controls your PSampR user ID (currently IACS)The new system is referred to as EIDMThis will result in a different way to create new accounts or change passwords to existing accountsIf you already have an account in EIDM you may have to use that account for accessing PSampR after the transitionWhen is the change effectiveJune 13 2015What is staying the sameThe internet address for accessing PSampR remains the sameThe PSampR systemfunctionality is NOT changing 62

Medicare Advantage Payorsbull Medicare Advantage payors are pullingdenying payments on admissions if the patient was readmitted within 30 days after discharge The

client believes that the payors systematically denying payments for all readmissions within 30 days They believe this practice denies them due process to address whether the readmissions were justified and not due to a premature discharge of patient The payors seem to want to act like a QIO without having the same accountabilities of the QIO related to determinations of non-payment

bull Heres the QIO process under section 4240 of the QIO Manualbull 4240 - Readmission Review - (Rev 2 07-11-03)bull Readmission review involves admissions to an acute general short-term hospital occurring less than 31 calendar days from the date of

discharge from the same or another acute general short-term hospital (see sect1154(a)(13) and 42 CFR 47671(a)(8)(ii)) Neither the day of discharge nor the day of admission is counted when determining whether a readmission has occurred

bull A Medical Review Proceduresbull Obtain the appropriate medical records for the initial admission and readmission Perform case review on both stays Analyze the cases

specifically to determine whether the patient was prematurely discharged from the first confinement thus causing readmission Perform an analysis of the stay at the first hospital to determine the cause(s) and extent of any problem(s) (eg incomplete or substandard treatment) Consider the information available to the attending physician who discharged the patient from the first confinement Do not base a determination of a premature discharge on information that the physician or provider could not have known or events that could not have been anticipated at the time of discharge

bull Review both the initial admission and the readmission at the same time unless one of them has previously been reviewed In these cases use at a minimum the PRAF case summary of the other admission in addition to the medical record of the case under review

bull C Denialsbull Deny readmissions under the following circumstancesbull If the readmission was medically unnecessarybull If the readmission resulted from a premature discharge from the same hospital orbull If the readmission was a result of circumvention of PPS by the same hospital (see sect4255)bull With the QIO process there is an appeal within the QIO here the hospital is getting no opportunity to challenge the denials

63

Medicare Provider Enrollment Feebull Provider Enrollment Application Fee Amount for CY 2016bull On December 3 CMS issued a notice Provider Enrollment Application

Fee Amount for CY 2016 [CMSndash6066ndashN] Effective January 1 2016 the CY 2016 application fee is $554 for institutional providers that are

bull Initially enrolling in the Medicare or Medicaid program or the Childrens Health Insurance Program (CHIP)

bull Revalidating their Medicare Medicaid or CHIP enrollmentbull Adding a new Medicare practice locationbull This fee is required with any enrollment application submitted from

January 1 through December 31 2016

64

Medicare MAC-Higlas

bull Effective 142016 CMS has implemented a change to begin netting (offsetting) provider money across workloads within a single organization What this means is that any related providers conducting business in two different workloads (example New York and Maine) will have their money applied to any account receivables (AR) with a remaining balance owed to Medicare within both workloads For example Provider ABC is located in New York and is scheduled to receive a payment of $1000 on todays remittance advice Provider XYZ is related to provider ABC but is located in Maine and has ARs with a balance owed of $200 Provider ABCs $1000 payment will have the $200 applied against provider XYZs ARs resulting in a net payment of $800 This will be reflected on the remittance advice by the same PLB code as seen today for offsets for the $200

65

Two Midnight RuleChange January 1 2016 httpswwwcmsgovMedicareMedicare-Fee-for-Service-PaymentHospitalOutpatientPPSHospital-Outpatient-Regulations-and-Notices-ItemsCMS-1633-FChtml

66

Two Midnight Rulebull However effective January 1 2016 CMS will allow exceptions to the

Two-Midnight Benchmark to be determined on a case-by-case basis by the physician responsible for the care of the beneficiary subject to medical review Said differently Part A payment may be appropriate in some circumstances even though there is no expectation by the physician (or qualified ordering practitioner) of a two-midnight stay and one of the two pre-existing categorical exceptions (CMS ldquoinpatient onlyrdquo list and newly initiated mechanical ventilation) does not apply CMS has indicated that this change to the Two Midnight Rule is in response to stakeholder concern and CMSrsquos continued efforts to develop the most appropriate standard for determining Medicare Part A payment

67

Two Midnight Rulebull A new 42 CFR sect4123(a) provides that a patient is considered an

inpatient of a hospitalhellipif formally admitted as an inpatient pursuant to an order for inpatient admission by a physician or other qualified practitionerhellip The physician orders inpatient status when he or she expects the patient to require a stay that crosses at least 2 midnights[10] Stays expected to be shorter than at least two midnights are generally inappropriate for inpatient admission and inpatient payment under Medicare Part A unless the surgical procedure is specified by Medicare as inpatient only under sect41922(n)[11] The physicians expectationhellipshould be based on such complex medical factors as patient history and comorbidities the severity of signs and symptoms current medical needs and the risk of an adverse event[12] The physician order is part of physician certification of the medical necessity of hospital inpatient serviceshellip[13]

68

InPatient Vs Observation Conthellip

bull Physician certification which begins with an order for inpatient admission requires the physician to certify the reasons for the hospitalization the estimated time the patient will remain in the hospital and plans for post-hospital care if appropriate[14] The certification must be completed signed and documented in the medical record prior to discharge[15]

bull A physicians admission order has no presumptive weight and both the admission order and the physician certification will be evaluated in the context of the evidence in the medical record[16] CMS intends to provide additional information about what evidence in the medical record means in future instructions and manual revisions[17]

69

Two Midnight Rulebull Although the new case-by-case exception appears to be inherently

subjective to a certain extent CMS states that the following factors (among others) would be relevant to determining whether a patient requires inpatient admission under the expanded policy

bull The severity of the signs and symptoms exhibited by the patient bull The medical predictability of something adverse happening to the patient

and bull The need for diagnostic studies that appropriately are outpatient services

(that is their performance does not ordinarily require the patient to remain at the hospital for 24 hours or more)

bull CMS also notes that an inpatient admission (and Part A payment) should be ldquorare and unusualrdquo for minor surgical procedures or other treatment that is expected to keep the patient in the hospital ldquofor only a few hoursrdquo or for a period of time that ldquodoes not span at least overnightrdquo (thus a subset of stays not meeting the Two Midnight Benchmark) CMS indicates that such cases will be prioritized for medical review

70

Health Data Insights amp Medicare Plus Blue

RAC (Retrospective Audits)

71

HDI Health Data amp Med Plus Blue

bull httpwwwhealthdatainsightscombull Blue Cross Medicare Advantage Auditsbull Facilities seeing 10 to 15 requests for Medical Recordsbull In January amp Feburarybull Selected Health Data Insights because they were a premier Audit

Vendor for CMS Recovery Audit Contractor (RAC) demonstration Project They are a audit vendor for Humana

bull Providers not sending Medical Record will get technical denial and lose payments

72

Health Data InSight

bull In 2010 they began the Hospital Reviewbull Medicare Advantage encounter datandashCMS oversight of data integrity OIG

2016bull We will review CMSs oversight of MA encounter data validation and assess

the extent to which CMSrsquos Integrated Data Repository contains timely valid and complete MA encounter data In 2012 CMS began collecting from MA organizations a more comprehensive set of encounter data reflecting the items and services provided to MA plan enrollees Prior CMS and OIG audits have indicated vulnerabilities in the accuracy of data reporting by MA organizations Realizing the potential benefits of the MA encounter data for payment and program integrity oversight is contingent upon the datarsquos completeness validity and timeliness (OEI 03-15-00060 expected issue date FY 2017)

73

Pepper Reports

bull httpswwwpepperresourcesorg

bull Program for Evaluating Payment Patterns Electronic Report ( PEPPER)

bull Annually on or about April 18 2016 will be released

bull Pepper Portal httpssecurefiletmforg

74

CGI Technologies and Solutions Inc httpracbcgicomContactInfoaspxst=1

bull Indiana bull Michiganbull Minnesotabull Illinoisbull Kentuckybull Ohiobull Wisconsin CGI Technologies and Solutions Incbull For general and administrative questions regarding client service outreach

quality assurance or project-specific issues contactbull 1877316RACB (7222)bull Email racbcgicom Tamara Tate Tamaratatecmshhsgovbull 4107861288

75

CGI Federal RAC

bull CGI Federal RAC Region Bbull Email racbcgicombull Phone 1-877-316-RACB (7222)bull Mailing Addressbull Send medical records as followsbull Medical records for Indiana Illinois Kentucky Michigan Ohio Wisconsin

Minnesota DME and Home Health CGI Federal Inc Attn RACB Imaging Dept 1001 Lakeside Ave Suite 800 Cleveland OH 44114

bull If submitting paper records please send medical records as follows For Therapy Reviews CGI Federal Inc Attn RACB Imaging 1001 Lakeside Avenue Suite 800 Cleveland OH 44114

76

How to survive RAC Audit

bull National health expenditures totaled $1679 Billion in 2003 bull National health expenditures were 153 of GROSS Domestic Product

(GDP) in 2003 bull Health care cost increasing at +9 per year bull Doomsday predictions of Medicare running out bull Congressional Action

77

RAC Audits

bull Medicare Modernization Act (MMA) of 2003Mandated a three year audit demonstration project 2005-2008

bull Appoint audit contractors to review Medicare billings for proper coding DRG assignment and medical necessity

bull Audits will apply to all health care providers (hospitals physicians homecare dme etc)

bull Audit contractors to be paid on a contingency basis a percentage of overpayments recovered

78

How Did we get here

bull Overpayments collected due to errors in Medically Unnecessary Services ndash 40

bull Incorrectly Coded ndash 35

bull Other ndash 17

bull NoInsufficient Documentation ndash 8

79

Where are we now

bull All RACrsquos completed required provider outreachAccess to Medicare billing data base given to all RAC RAC review methodology

bull Automated Review-Black amp White Issues (current) bull DRG Validation-complex review (current) bull Complex Review for coding errors (current) bull DME Medical Necessity Reviews ndashcomplex review (calendar year

2010) bull Medical Necessity Reviews-complex review (calendar year 2010)

80

RAC Reviews

bull Responsibilities of the Team Leader bull Must learn each insurance provider participating in a RAC or RAC type

program bull What are their operating rulesbull What is their appeal process Time limits

May be different process for each insurance provider bull Develop a response team

Identify who does what when why and alternate bull individual

Build and develop a manual process Review of computerized system

81

Priority Health SCIO Health Analytics

bull httpswwwsciohealthanalyticscomcore-capabilitiespayment-integrityfacility-auditsskilled-nursing-facility-audits

bull Claims for Medicare members treated at Skilled Nursing Facilities are reimbursed based on the patientsrsquo RUG (Resource Utilization Group) score which is determined using the Minimum Data Set (MDS) Using SCIOs robust analytics claims andor providers that merit review are selected for audit SCIOs auditors conduct a detailed review of the complete medical record and associated MDS to determine if the billed RUG score is valid In the event the review determines that an incorrect RUG score was billed SCIOreg provides the valid score reports the reason the change was necessary and calculates the resulting overpayment

82

+ Cheer

Onward and Upward she shall prevail We are here to care for the residents and provide a wonderful

service

13 83

84

References

bull Priority Healthbull Blue Crossbull Medicaidbull Medicare

85

  • Medicare Mange Care amp Medicaid Changes in the New World We Live In
  • Medicaid
  • NEW Medicaid Change MIlogin
  • Blueprint for Health Innovation MI
  • Provider Enrollment Electronic Signature Form Submission Process MSA 15-54
  • Provider Enrollment Electronic Signature Form Submission Process
  • Provider Enrollment Domain Administrator
  • Medicaid Coinsurance Medicare Advantage
  • Slide Number 9
  • Lawsuit DHS Changes on Caregivers
  • TPL Medicaid Change
  • CHAMPS Member Screen
  • LOC dropping off Not Due to MI Health
  • Issues
  • Secure Email Information
  • Medicaid amp Hospice
  • Medicaid
  • Medicaid Medicare Buy In
  • Manage Medicaid
  • Healthy Michigan Residents
  • Healthy Michigan Medicaid Days
  • McLaren Health Plan
  • Manage Medicaid Plans January 1
  • Slide Number 24
  • MI Health Link
  • MI Health Link 2565
  • What are the Names
  • MI Health Dual Eligible
  • MI Health LOC
  • LOC Medicaid
  • Medicaid Redetermination and MHL Enrollment
  • MI Health Link Portals
  • MI Health Authorizations
  • MI Health Issues
  • LOC 02 dropping MI Health Issues
  • PPA Offset
  • LOCD
  • MI Health Issues-New
  • ACO
  • Families Receiving Letters for ACO
  • ACO What is It
  • Payroll Based Journal
  • Slide Number 43
  • If you submit data manually should you also submit it through the XML
  • Staffing Submission Frequently Asked Questions
  • CMS defines
  • Slide Number 47
  • PBJ Medical Director Role
  • PBJ Medical Director Role
  • Dietician
  • Pharmacy Consultant
  • What are the names for the Medicare Number
  • QTSO
  • Medicare Update
  • CMS Final Rule On Returning Credits
  • Over Payment Rule
  • Questions to MAC
  • Questions to MAC
  • Final Rule on Returning Credits
  • Final Rule on Returning Credits
  • Final Rule on Returning Credits
  • Slide Number 62
  • Medicare Advantage Payors
  • Medicare Provider Enrollment Fee
  • Medicare MAC-Higlas
  • Two Midnight Rule
  • Two Midnight Rule
  • Two Midnight Rule
  • InPatient Vs Observation Conthellip
  • Two Midnight Rule
  • Health Data Insights amp Medicare Plus Blue
  • HDI Health Data amp Med Plus Blue
  • Health Data InSight
  • Pepper Reports
  • CGI Technologies and Solutions Inc httpracbcgicomContactInfoaspxst=1
  • CGI Federal RAC
  • How to survive RAC Audit
  • RAC Audits
  • How Did we get here
  • Where are we now
  • RAC Reviews
  • Priority Health SCIO Health Analytics
  • Cheer
  • References
Page 47: Medicare, Mange Care & Medicaid Changes in the New World we live in

47

PBJ Medical Director Rolebull Physician Leadership

bull Help the facility ensure that patients have appropriate physician coverage and ensure the provision of physician and health care practitioner services and

bull Help the facility develop a process for reviewing physician and health care practitioner credentials

bull Provide specific guidance for physician performance expectations

bull Help the facility ensure that a system is in place for monitoring the performance of health care practitioners and

bull Facilitate feedback to physicians and other health care practitioners on performance and practices

bull Patient Care - Clinical Leadership

bull Participate in administrative decision-making and the development of policies and procedures related to patient care

bull Help develop approve and implement specific clinical practices for the facility to incorporate into its care-related policies and procedures including areas required by laws and regulations

bull Develop procedures and guidance for facility staff regarding contacting practitioners including information gathering and presentation change in condition assessment and when to contact the medical director

bull Review consider andor act upon consultant recommendations as appropriate that affect the facilitys resident care policies and procedures or the care of an individual resident

bull Review respond to and participate in federal state local and other external surveys and inspections and

bull Help review policies and procedures regarding the adequate protection of patients rights advance care planning and other ethical issues48

PBJ Medical Director Rolebull Quality of Care

bull Help the facility establish systems and methods for reviewing the quality and appropriateness of clinical care and other health-related services and provide appropriate feedback and

bull Participate in the facilitys quality improvement process

bull Advise on infection control issues and approve specific infection control policies to be incorporated into facility policies and procedures

bull Help the facility provide a safe and caring environment

bull Help promote employee health and safety and

bull Assist in the development and implementation of employee health policies and programs

bull Education Information and Communication

bull Promote a learning culture within the facility by educating informing and communicating

bull Provide information to help the facility provide care consistent with current standards of practice (defined as approaches to care procedures techniques and treatments that are based on research and or expert consensus and that are contained in current manuals textbooks and or publications or that are accepted adopted or promulgated by recognized organizations or national bodies)

bull Help the facility develop medical information and communication systems with staff patients and families and others

bull Represent the facility to the professional and lay community on medical and patient care issues

bull Maintain knowledge of the changing social regulatory political and economic factors that affect medical and health services of long term care patients and

bull Help establish appropriate relationships with other health care organizations

49

Dietician

bull When the dietary or food services supervisor is other than a registered dietitian the supervisor shall receive routine consultation and technical assistance from a registered dietitian (RD) Consultation time shall not be less than 4 hours every 60 days Additional consultation time may be needed based on the total number of patients incidence of nutrition-related health problems and food service management needs of the facility

50

Pharmacy Consultant

bull At least once per month a licensed pharmacist must perform a drug regimen review (DRR) for each resident The pharmacist must report any irregularities to the attending physician or director of nursing Furthermore these reports must be acted upon

51

What are the names for the Medicare Numberbull OSCAR -Online Survey Certification and Reporting

bull PTAN-PTAN number is assigned by Medicare to authenticate the provider when using the local Medicare Administrative Contractorrsquos (MAC) self-help tools like the IVR internet portal on-line application status etc Provider Transactions Access Number

bull CCN- CMS Certification Number

bull Medicare Number- example 23-

bull All of the above mean the same thing

52

QTSO

bull Once you are logged in the QTSO site bull You will have a state login to the site to access the various site specific

to your facilitybull Installing you will need administrator rights to your network

53

Medicare UpdateWhat are we seeing

54

CMS Final Rule On Returning Credits

httpswwwfederalregistergovarticles201602122016-02789medicare-program-reporting-and-returning-of-overpayments

55

Over Payment Rule

bull Medicare payments for non covered services

bull Medicare payments in excess of the allowable amount for an identified covered service

bull Errors and non reimbursable expenditures in cost reportsbull Duplicate payment

bull Receipt of Medicare payments when another payor had the primary responsibility for payment

56

Questions to MAC

bull Does the Medicare credit balance report change with this overpayment rule

bull No Medicare Credit Balances are still required at the end of each quarter

bull Will that still be the communication to let CMS or the MAC know that we have received an overpayment

bull Submission of Medicare Credit Balance is one form of communicating overpayments to CMS Other methods include submitting a voluntary refund with required claim information or the submission of a standard overpayment form

57

Questions to MAC

bull Will the MAC still deduct from a future RAbull If the recovery of the overpayment includes adjusting a claim then

the overpayment would be netted against future claims payments and reflected on the RA

bull Or will that process change with this new rulebull Process will remain the samebull Will NGS send communication out on thisbull Yes NGS will communicate this once the final rule is communicated

to the MACs by CMS However this could change depending on final CMS instructions

58

Final Rule on Returning Credits

bull Providers will want to immediately update their current policies governing overpayments in order to comply with this new rule which will take effect on March 14 2016

bull Providers and suppliers are required to use reasonable diligence to investigate credible information regarding overpayments through both proactive compliance efforts and reactive investigations

bull If an overpayment is identified then it must be repaid within 60 days An overpayment is identified when a person has or should have through the exercise of reasonable diligence determined that the person received an overpayment and quantified the amount

bull Providers and suppliers have a maximum of 8 months to report and return overpayments ndash up to 6 months to investigate and quantify the overpayment (ie to identify it) and up to 60 days to report and return the overpayment

59

Final Rule on Returning Credits

bull Providers and suppliers are required to report and return all overpayments within a 6-year lookback period

bull The cause and amount of the overpayment is irrelevant for the determination eg it was due to a mistake it was someone elsersquos fault it is a minor amount An overpayment is an overpayment and must be returned

bull Providers and suppliers must make their own determination to which entity to report and return the overpayment ie to the Medicare contractor or using the OIG Self Disclosure Protocol or the CMS Self Referral Disclosure Protocol

60

Final Rule on Returning Credits

bull Providers and suppliers may use the claims adjustment credit balance self-reported refund process or another appropriate process to report and return overpayments At this time there is no standard refund form to use

bull Failure to report and return an overpayment could subject the provider or supplier to False Claims Act liability Civil Monetary Penalties Law liability and exclusion from federal health care programs

61

P S amp R-Accountants will be asking for this information

The location you login into has changed it is now on EIDM EIDM is the acronym for CMS Enterprise Identity Management system which includes Identity Verification Access Management Authorization Assistance Workflow Tools and Identity Lifecycle Management functions

httpswwwcmsgovResearch-Statistics-Data-and-SystemsCMS-Information-TechnologyIACSCMS-Applications-Loginhtml

Go down the page and click on the PSampRSTARThis will take you to the login pagewill look the same as the old P S amp R didChanges Affecting PSampR System Access (Please Read) (posted 01292015)(Updated 5262015)is changingThe system which controls your PSampR user ID (currently IACS)The new system is referred to as EIDMThis will result in a different way to create new accounts or change passwords to existing accountsIf you already have an account in EIDM you may have to use that account for accessing PSampR after the transitionWhen is the change effectiveJune 13 2015What is staying the sameThe internet address for accessing PSampR remains the sameThe PSampR systemfunctionality is NOT changing 62

Medicare Advantage Payorsbull Medicare Advantage payors are pullingdenying payments on admissions if the patient was readmitted within 30 days after discharge The

client believes that the payors systematically denying payments for all readmissions within 30 days They believe this practice denies them due process to address whether the readmissions were justified and not due to a premature discharge of patient The payors seem to want to act like a QIO without having the same accountabilities of the QIO related to determinations of non-payment

bull Heres the QIO process under section 4240 of the QIO Manualbull 4240 - Readmission Review - (Rev 2 07-11-03)bull Readmission review involves admissions to an acute general short-term hospital occurring less than 31 calendar days from the date of

discharge from the same or another acute general short-term hospital (see sect1154(a)(13) and 42 CFR 47671(a)(8)(ii)) Neither the day of discharge nor the day of admission is counted when determining whether a readmission has occurred

bull A Medical Review Proceduresbull Obtain the appropriate medical records for the initial admission and readmission Perform case review on both stays Analyze the cases

specifically to determine whether the patient was prematurely discharged from the first confinement thus causing readmission Perform an analysis of the stay at the first hospital to determine the cause(s) and extent of any problem(s) (eg incomplete or substandard treatment) Consider the information available to the attending physician who discharged the patient from the first confinement Do not base a determination of a premature discharge on information that the physician or provider could not have known or events that could not have been anticipated at the time of discharge

bull Review both the initial admission and the readmission at the same time unless one of them has previously been reviewed In these cases use at a minimum the PRAF case summary of the other admission in addition to the medical record of the case under review

bull C Denialsbull Deny readmissions under the following circumstancesbull If the readmission was medically unnecessarybull If the readmission resulted from a premature discharge from the same hospital orbull If the readmission was a result of circumvention of PPS by the same hospital (see sect4255)bull With the QIO process there is an appeal within the QIO here the hospital is getting no opportunity to challenge the denials

63

Medicare Provider Enrollment Feebull Provider Enrollment Application Fee Amount for CY 2016bull On December 3 CMS issued a notice Provider Enrollment Application

Fee Amount for CY 2016 [CMSndash6066ndashN] Effective January 1 2016 the CY 2016 application fee is $554 for institutional providers that are

bull Initially enrolling in the Medicare or Medicaid program or the Childrens Health Insurance Program (CHIP)

bull Revalidating their Medicare Medicaid or CHIP enrollmentbull Adding a new Medicare practice locationbull This fee is required with any enrollment application submitted from

January 1 through December 31 2016

64

Medicare MAC-Higlas

bull Effective 142016 CMS has implemented a change to begin netting (offsetting) provider money across workloads within a single organization What this means is that any related providers conducting business in two different workloads (example New York and Maine) will have their money applied to any account receivables (AR) with a remaining balance owed to Medicare within both workloads For example Provider ABC is located in New York and is scheduled to receive a payment of $1000 on todays remittance advice Provider XYZ is related to provider ABC but is located in Maine and has ARs with a balance owed of $200 Provider ABCs $1000 payment will have the $200 applied against provider XYZs ARs resulting in a net payment of $800 This will be reflected on the remittance advice by the same PLB code as seen today for offsets for the $200

65

Two Midnight RuleChange January 1 2016 httpswwwcmsgovMedicareMedicare-Fee-for-Service-PaymentHospitalOutpatientPPSHospital-Outpatient-Regulations-and-Notices-ItemsCMS-1633-FChtml

66

Two Midnight Rulebull However effective January 1 2016 CMS will allow exceptions to the

Two-Midnight Benchmark to be determined on a case-by-case basis by the physician responsible for the care of the beneficiary subject to medical review Said differently Part A payment may be appropriate in some circumstances even though there is no expectation by the physician (or qualified ordering practitioner) of a two-midnight stay and one of the two pre-existing categorical exceptions (CMS ldquoinpatient onlyrdquo list and newly initiated mechanical ventilation) does not apply CMS has indicated that this change to the Two Midnight Rule is in response to stakeholder concern and CMSrsquos continued efforts to develop the most appropriate standard for determining Medicare Part A payment

67

Two Midnight Rulebull A new 42 CFR sect4123(a) provides that a patient is considered an

inpatient of a hospitalhellipif formally admitted as an inpatient pursuant to an order for inpatient admission by a physician or other qualified practitionerhellip The physician orders inpatient status when he or she expects the patient to require a stay that crosses at least 2 midnights[10] Stays expected to be shorter than at least two midnights are generally inappropriate for inpatient admission and inpatient payment under Medicare Part A unless the surgical procedure is specified by Medicare as inpatient only under sect41922(n)[11] The physicians expectationhellipshould be based on such complex medical factors as patient history and comorbidities the severity of signs and symptoms current medical needs and the risk of an adverse event[12] The physician order is part of physician certification of the medical necessity of hospital inpatient serviceshellip[13]

68

InPatient Vs Observation Conthellip

bull Physician certification which begins with an order for inpatient admission requires the physician to certify the reasons for the hospitalization the estimated time the patient will remain in the hospital and plans for post-hospital care if appropriate[14] The certification must be completed signed and documented in the medical record prior to discharge[15]

bull A physicians admission order has no presumptive weight and both the admission order and the physician certification will be evaluated in the context of the evidence in the medical record[16] CMS intends to provide additional information about what evidence in the medical record means in future instructions and manual revisions[17]

69

Two Midnight Rulebull Although the new case-by-case exception appears to be inherently

subjective to a certain extent CMS states that the following factors (among others) would be relevant to determining whether a patient requires inpatient admission under the expanded policy

bull The severity of the signs and symptoms exhibited by the patient bull The medical predictability of something adverse happening to the patient

and bull The need for diagnostic studies that appropriately are outpatient services

(that is their performance does not ordinarily require the patient to remain at the hospital for 24 hours or more)

bull CMS also notes that an inpatient admission (and Part A payment) should be ldquorare and unusualrdquo for minor surgical procedures or other treatment that is expected to keep the patient in the hospital ldquofor only a few hoursrdquo or for a period of time that ldquodoes not span at least overnightrdquo (thus a subset of stays not meeting the Two Midnight Benchmark) CMS indicates that such cases will be prioritized for medical review

70

Health Data Insights amp Medicare Plus Blue

RAC (Retrospective Audits)

71

HDI Health Data amp Med Plus Blue

bull httpwwwhealthdatainsightscombull Blue Cross Medicare Advantage Auditsbull Facilities seeing 10 to 15 requests for Medical Recordsbull In January amp Feburarybull Selected Health Data Insights because they were a premier Audit

Vendor for CMS Recovery Audit Contractor (RAC) demonstration Project They are a audit vendor for Humana

bull Providers not sending Medical Record will get technical denial and lose payments

72

Health Data InSight

bull In 2010 they began the Hospital Reviewbull Medicare Advantage encounter datandashCMS oversight of data integrity OIG

2016bull We will review CMSs oversight of MA encounter data validation and assess

the extent to which CMSrsquos Integrated Data Repository contains timely valid and complete MA encounter data In 2012 CMS began collecting from MA organizations a more comprehensive set of encounter data reflecting the items and services provided to MA plan enrollees Prior CMS and OIG audits have indicated vulnerabilities in the accuracy of data reporting by MA organizations Realizing the potential benefits of the MA encounter data for payment and program integrity oversight is contingent upon the datarsquos completeness validity and timeliness (OEI 03-15-00060 expected issue date FY 2017)

73

Pepper Reports

bull httpswwwpepperresourcesorg

bull Program for Evaluating Payment Patterns Electronic Report ( PEPPER)

bull Annually on or about April 18 2016 will be released

bull Pepper Portal httpssecurefiletmforg

74

CGI Technologies and Solutions Inc httpracbcgicomContactInfoaspxst=1

bull Indiana bull Michiganbull Minnesotabull Illinoisbull Kentuckybull Ohiobull Wisconsin CGI Technologies and Solutions Incbull For general and administrative questions regarding client service outreach

quality assurance or project-specific issues contactbull 1877316RACB (7222)bull Email racbcgicom Tamara Tate Tamaratatecmshhsgovbull 4107861288

75

CGI Federal RAC

bull CGI Federal RAC Region Bbull Email racbcgicombull Phone 1-877-316-RACB (7222)bull Mailing Addressbull Send medical records as followsbull Medical records for Indiana Illinois Kentucky Michigan Ohio Wisconsin

Minnesota DME and Home Health CGI Federal Inc Attn RACB Imaging Dept 1001 Lakeside Ave Suite 800 Cleveland OH 44114

bull If submitting paper records please send medical records as follows For Therapy Reviews CGI Federal Inc Attn RACB Imaging 1001 Lakeside Avenue Suite 800 Cleveland OH 44114

76

How to survive RAC Audit

bull National health expenditures totaled $1679 Billion in 2003 bull National health expenditures were 153 of GROSS Domestic Product

(GDP) in 2003 bull Health care cost increasing at +9 per year bull Doomsday predictions of Medicare running out bull Congressional Action

77

RAC Audits

bull Medicare Modernization Act (MMA) of 2003Mandated a three year audit demonstration project 2005-2008

bull Appoint audit contractors to review Medicare billings for proper coding DRG assignment and medical necessity

bull Audits will apply to all health care providers (hospitals physicians homecare dme etc)

bull Audit contractors to be paid on a contingency basis a percentage of overpayments recovered

78

How Did we get here

bull Overpayments collected due to errors in Medically Unnecessary Services ndash 40

bull Incorrectly Coded ndash 35

bull Other ndash 17

bull NoInsufficient Documentation ndash 8

79

Where are we now

bull All RACrsquos completed required provider outreachAccess to Medicare billing data base given to all RAC RAC review methodology

bull Automated Review-Black amp White Issues (current) bull DRG Validation-complex review (current) bull Complex Review for coding errors (current) bull DME Medical Necessity Reviews ndashcomplex review (calendar year

2010) bull Medical Necessity Reviews-complex review (calendar year 2010)

80

RAC Reviews

bull Responsibilities of the Team Leader bull Must learn each insurance provider participating in a RAC or RAC type

program bull What are their operating rulesbull What is their appeal process Time limits

May be different process for each insurance provider bull Develop a response team

Identify who does what when why and alternate bull individual

Build and develop a manual process Review of computerized system

81

Priority Health SCIO Health Analytics

bull httpswwwsciohealthanalyticscomcore-capabilitiespayment-integrityfacility-auditsskilled-nursing-facility-audits

bull Claims for Medicare members treated at Skilled Nursing Facilities are reimbursed based on the patientsrsquo RUG (Resource Utilization Group) score which is determined using the Minimum Data Set (MDS) Using SCIOs robust analytics claims andor providers that merit review are selected for audit SCIOs auditors conduct a detailed review of the complete medical record and associated MDS to determine if the billed RUG score is valid In the event the review determines that an incorrect RUG score was billed SCIOreg provides the valid score reports the reason the change was necessary and calculates the resulting overpayment

82

+ Cheer

Onward and Upward she shall prevail We are here to care for the residents and provide a wonderful

service

13 83

84

References

bull Priority Healthbull Blue Crossbull Medicaidbull Medicare

85

  • Medicare Mange Care amp Medicaid Changes in the New World We Live In
  • Medicaid
  • NEW Medicaid Change MIlogin
  • Blueprint for Health Innovation MI
  • Provider Enrollment Electronic Signature Form Submission Process MSA 15-54
  • Provider Enrollment Electronic Signature Form Submission Process
  • Provider Enrollment Domain Administrator
  • Medicaid Coinsurance Medicare Advantage
  • Slide Number 9
  • Lawsuit DHS Changes on Caregivers
  • TPL Medicaid Change
  • CHAMPS Member Screen
  • LOC dropping off Not Due to MI Health
  • Issues
  • Secure Email Information
  • Medicaid amp Hospice
  • Medicaid
  • Medicaid Medicare Buy In
  • Manage Medicaid
  • Healthy Michigan Residents
  • Healthy Michigan Medicaid Days
  • McLaren Health Plan
  • Manage Medicaid Plans January 1
  • Slide Number 24
  • MI Health Link
  • MI Health Link 2565
  • What are the Names
  • MI Health Dual Eligible
  • MI Health LOC
  • LOC Medicaid
  • Medicaid Redetermination and MHL Enrollment
  • MI Health Link Portals
  • MI Health Authorizations
  • MI Health Issues
  • LOC 02 dropping MI Health Issues
  • PPA Offset
  • LOCD
  • MI Health Issues-New
  • ACO
  • Families Receiving Letters for ACO
  • ACO What is It
  • Payroll Based Journal
  • Slide Number 43
  • If you submit data manually should you also submit it through the XML
  • Staffing Submission Frequently Asked Questions
  • CMS defines
  • Slide Number 47
  • PBJ Medical Director Role
  • PBJ Medical Director Role
  • Dietician
  • Pharmacy Consultant
  • What are the names for the Medicare Number
  • QTSO
  • Medicare Update
  • CMS Final Rule On Returning Credits
  • Over Payment Rule
  • Questions to MAC
  • Questions to MAC
  • Final Rule on Returning Credits
  • Final Rule on Returning Credits
  • Final Rule on Returning Credits
  • Slide Number 62
  • Medicare Advantage Payors
  • Medicare Provider Enrollment Fee
  • Medicare MAC-Higlas
  • Two Midnight Rule
  • Two Midnight Rule
  • Two Midnight Rule
  • InPatient Vs Observation Conthellip
  • Two Midnight Rule
  • Health Data Insights amp Medicare Plus Blue
  • HDI Health Data amp Med Plus Blue
  • Health Data InSight
  • Pepper Reports
  • CGI Technologies and Solutions Inc httpracbcgicomContactInfoaspxst=1
  • CGI Federal RAC
  • How to survive RAC Audit
  • RAC Audits
  • How Did we get here
  • Where are we now
  • RAC Reviews
  • Priority Health SCIO Health Analytics
  • Cheer
  • References
Page 48: Medicare, Mange Care & Medicaid Changes in the New World we live in

PBJ Medical Director Rolebull Physician Leadership

bull Help the facility ensure that patients have appropriate physician coverage and ensure the provision of physician and health care practitioner services and

bull Help the facility develop a process for reviewing physician and health care practitioner credentials

bull Provide specific guidance for physician performance expectations

bull Help the facility ensure that a system is in place for monitoring the performance of health care practitioners and

bull Facilitate feedback to physicians and other health care practitioners on performance and practices

bull Patient Care - Clinical Leadership

bull Participate in administrative decision-making and the development of policies and procedures related to patient care

bull Help develop approve and implement specific clinical practices for the facility to incorporate into its care-related policies and procedures including areas required by laws and regulations

bull Develop procedures and guidance for facility staff regarding contacting practitioners including information gathering and presentation change in condition assessment and when to contact the medical director

bull Review consider andor act upon consultant recommendations as appropriate that affect the facilitys resident care policies and procedures or the care of an individual resident

bull Review respond to and participate in federal state local and other external surveys and inspections and

bull Help review policies and procedures regarding the adequate protection of patients rights advance care planning and other ethical issues48

PBJ Medical Director Rolebull Quality of Care

bull Help the facility establish systems and methods for reviewing the quality and appropriateness of clinical care and other health-related services and provide appropriate feedback and

bull Participate in the facilitys quality improvement process

bull Advise on infection control issues and approve specific infection control policies to be incorporated into facility policies and procedures

bull Help the facility provide a safe and caring environment

bull Help promote employee health and safety and

bull Assist in the development and implementation of employee health policies and programs

bull Education Information and Communication

bull Promote a learning culture within the facility by educating informing and communicating

bull Provide information to help the facility provide care consistent with current standards of practice (defined as approaches to care procedures techniques and treatments that are based on research and or expert consensus and that are contained in current manuals textbooks and or publications or that are accepted adopted or promulgated by recognized organizations or national bodies)

bull Help the facility develop medical information and communication systems with staff patients and families and others

bull Represent the facility to the professional and lay community on medical and patient care issues

bull Maintain knowledge of the changing social regulatory political and economic factors that affect medical and health services of long term care patients and

bull Help establish appropriate relationships with other health care organizations

49

Dietician

bull When the dietary or food services supervisor is other than a registered dietitian the supervisor shall receive routine consultation and technical assistance from a registered dietitian (RD) Consultation time shall not be less than 4 hours every 60 days Additional consultation time may be needed based on the total number of patients incidence of nutrition-related health problems and food service management needs of the facility

50

Pharmacy Consultant

bull At least once per month a licensed pharmacist must perform a drug regimen review (DRR) for each resident The pharmacist must report any irregularities to the attending physician or director of nursing Furthermore these reports must be acted upon

51

What are the names for the Medicare Numberbull OSCAR -Online Survey Certification and Reporting

bull PTAN-PTAN number is assigned by Medicare to authenticate the provider when using the local Medicare Administrative Contractorrsquos (MAC) self-help tools like the IVR internet portal on-line application status etc Provider Transactions Access Number

bull CCN- CMS Certification Number

bull Medicare Number- example 23-

bull All of the above mean the same thing

52

QTSO

bull Once you are logged in the QTSO site bull You will have a state login to the site to access the various site specific

to your facilitybull Installing you will need administrator rights to your network

53

Medicare UpdateWhat are we seeing

54

CMS Final Rule On Returning Credits

httpswwwfederalregistergovarticles201602122016-02789medicare-program-reporting-and-returning-of-overpayments

55

Over Payment Rule

bull Medicare payments for non covered services

bull Medicare payments in excess of the allowable amount for an identified covered service

bull Errors and non reimbursable expenditures in cost reportsbull Duplicate payment

bull Receipt of Medicare payments when another payor had the primary responsibility for payment

56

Questions to MAC

bull Does the Medicare credit balance report change with this overpayment rule

bull No Medicare Credit Balances are still required at the end of each quarter

bull Will that still be the communication to let CMS or the MAC know that we have received an overpayment

bull Submission of Medicare Credit Balance is one form of communicating overpayments to CMS Other methods include submitting a voluntary refund with required claim information or the submission of a standard overpayment form

57

Questions to MAC

bull Will the MAC still deduct from a future RAbull If the recovery of the overpayment includes adjusting a claim then

the overpayment would be netted against future claims payments and reflected on the RA

bull Or will that process change with this new rulebull Process will remain the samebull Will NGS send communication out on thisbull Yes NGS will communicate this once the final rule is communicated

to the MACs by CMS However this could change depending on final CMS instructions

58

Final Rule on Returning Credits

bull Providers will want to immediately update their current policies governing overpayments in order to comply with this new rule which will take effect on March 14 2016

bull Providers and suppliers are required to use reasonable diligence to investigate credible information regarding overpayments through both proactive compliance efforts and reactive investigations

bull If an overpayment is identified then it must be repaid within 60 days An overpayment is identified when a person has or should have through the exercise of reasonable diligence determined that the person received an overpayment and quantified the amount

bull Providers and suppliers have a maximum of 8 months to report and return overpayments ndash up to 6 months to investigate and quantify the overpayment (ie to identify it) and up to 60 days to report and return the overpayment

59

Final Rule on Returning Credits

bull Providers and suppliers are required to report and return all overpayments within a 6-year lookback period

bull The cause and amount of the overpayment is irrelevant for the determination eg it was due to a mistake it was someone elsersquos fault it is a minor amount An overpayment is an overpayment and must be returned

bull Providers and suppliers must make their own determination to which entity to report and return the overpayment ie to the Medicare contractor or using the OIG Self Disclosure Protocol or the CMS Self Referral Disclosure Protocol

60

Final Rule on Returning Credits

bull Providers and suppliers may use the claims adjustment credit balance self-reported refund process or another appropriate process to report and return overpayments At this time there is no standard refund form to use

bull Failure to report and return an overpayment could subject the provider or supplier to False Claims Act liability Civil Monetary Penalties Law liability and exclusion from federal health care programs

61

P S amp R-Accountants will be asking for this information

The location you login into has changed it is now on EIDM EIDM is the acronym for CMS Enterprise Identity Management system which includes Identity Verification Access Management Authorization Assistance Workflow Tools and Identity Lifecycle Management functions

httpswwwcmsgovResearch-Statistics-Data-and-SystemsCMS-Information-TechnologyIACSCMS-Applications-Loginhtml

Go down the page and click on the PSampRSTARThis will take you to the login pagewill look the same as the old P S amp R didChanges Affecting PSampR System Access (Please Read) (posted 01292015)(Updated 5262015)is changingThe system which controls your PSampR user ID (currently IACS)The new system is referred to as EIDMThis will result in a different way to create new accounts or change passwords to existing accountsIf you already have an account in EIDM you may have to use that account for accessing PSampR after the transitionWhen is the change effectiveJune 13 2015What is staying the sameThe internet address for accessing PSampR remains the sameThe PSampR systemfunctionality is NOT changing 62

Medicare Advantage Payorsbull Medicare Advantage payors are pullingdenying payments on admissions if the patient was readmitted within 30 days after discharge The

client believes that the payors systematically denying payments for all readmissions within 30 days They believe this practice denies them due process to address whether the readmissions were justified and not due to a premature discharge of patient The payors seem to want to act like a QIO without having the same accountabilities of the QIO related to determinations of non-payment

bull Heres the QIO process under section 4240 of the QIO Manualbull 4240 - Readmission Review - (Rev 2 07-11-03)bull Readmission review involves admissions to an acute general short-term hospital occurring less than 31 calendar days from the date of

discharge from the same or another acute general short-term hospital (see sect1154(a)(13) and 42 CFR 47671(a)(8)(ii)) Neither the day of discharge nor the day of admission is counted when determining whether a readmission has occurred

bull A Medical Review Proceduresbull Obtain the appropriate medical records for the initial admission and readmission Perform case review on both stays Analyze the cases

specifically to determine whether the patient was prematurely discharged from the first confinement thus causing readmission Perform an analysis of the stay at the first hospital to determine the cause(s) and extent of any problem(s) (eg incomplete or substandard treatment) Consider the information available to the attending physician who discharged the patient from the first confinement Do not base a determination of a premature discharge on information that the physician or provider could not have known or events that could not have been anticipated at the time of discharge

bull Review both the initial admission and the readmission at the same time unless one of them has previously been reviewed In these cases use at a minimum the PRAF case summary of the other admission in addition to the medical record of the case under review

bull C Denialsbull Deny readmissions under the following circumstancesbull If the readmission was medically unnecessarybull If the readmission resulted from a premature discharge from the same hospital orbull If the readmission was a result of circumvention of PPS by the same hospital (see sect4255)bull With the QIO process there is an appeal within the QIO here the hospital is getting no opportunity to challenge the denials

63

Medicare Provider Enrollment Feebull Provider Enrollment Application Fee Amount for CY 2016bull On December 3 CMS issued a notice Provider Enrollment Application

Fee Amount for CY 2016 [CMSndash6066ndashN] Effective January 1 2016 the CY 2016 application fee is $554 for institutional providers that are

bull Initially enrolling in the Medicare or Medicaid program or the Childrens Health Insurance Program (CHIP)

bull Revalidating their Medicare Medicaid or CHIP enrollmentbull Adding a new Medicare practice locationbull This fee is required with any enrollment application submitted from

January 1 through December 31 2016

64

Medicare MAC-Higlas

bull Effective 142016 CMS has implemented a change to begin netting (offsetting) provider money across workloads within a single organization What this means is that any related providers conducting business in two different workloads (example New York and Maine) will have their money applied to any account receivables (AR) with a remaining balance owed to Medicare within both workloads For example Provider ABC is located in New York and is scheduled to receive a payment of $1000 on todays remittance advice Provider XYZ is related to provider ABC but is located in Maine and has ARs with a balance owed of $200 Provider ABCs $1000 payment will have the $200 applied against provider XYZs ARs resulting in a net payment of $800 This will be reflected on the remittance advice by the same PLB code as seen today for offsets for the $200

65

Two Midnight RuleChange January 1 2016 httpswwwcmsgovMedicareMedicare-Fee-for-Service-PaymentHospitalOutpatientPPSHospital-Outpatient-Regulations-and-Notices-ItemsCMS-1633-FChtml

66

Two Midnight Rulebull However effective January 1 2016 CMS will allow exceptions to the

Two-Midnight Benchmark to be determined on a case-by-case basis by the physician responsible for the care of the beneficiary subject to medical review Said differently Part A payment may be appropriate in some circumstances even though there is no expectation by the physician (or qualified ordering practitioner) of a two-midnight stay and one of the two pre-existing categorical exceptions (CMS ldquoinpatient onlyrdquo list and newly initiated mechanical ventilation) does not apply CMS has indicated that this change to the Two Midnight Rule is in response to stakeholder concern and CMSrsquos continued efforts to develop the most appropriate standard for determining Medicare Part A payment

67

Two Midnight Rulebull A new 42 CFR sect4123(a) provides that a patient is considered an

inpatient of a hospitalhellipif formally admitted as an inpatient pursuant to an order for inpatient admission by a physician or other qualified practitionerhellip The physician orders inpatient status when he or she expects the patient to require a stay that crosses at least 2 midnights[10] Stays expected to be shorter than at least two midnights are generally inappropriate for inpatient admission and inpatient payment under Medicare Part A unless the surgical procedure is specified by Medicare as inpatient only under sect41922(n)[11] The physicians expectationhellipshould be based on such complex medical factors as patient history and comorbidities the severity of signs and symptoms current medical needs and the risk of an adverse event[12] The physician order is part of physician certification of the medical necessity of hospital inpatient serviceshellip[13]

68

InPatient Vs Observation Conthellip

bull Physician certification which begins with an order for inpatient admission requires the physician to certify the reasons for the hospitalization the estimated time the patient will remain in the hospital and plans for post-hospital care if appropriate[14] The certification must be completed signed and documented in the medical record prior to discharge[15]

bull A physicians admission order has no presumptive weight and both the admission order and the physician certification will be evaluated in the context of the evidence in the medical record[16] CMS intends to provide additional information about what evidence in the medical record means in future instructions and manual revisions[17]

69

Two Midnight Rulebull Although the new case-by-case exception appears to be inherently

subjective to a certain extent CMS states that the following factors (among others) would be relevant to determining whether a patient requires inpatient admission under the expanded policy

bull The severity of the signs and symptoms exhibited by the patient bull The medical predictability of something adverse happening to the patient

and bull The need for diagnostic studies that appropriately are outpatient services

(that is their performance does not ordinarily require the patient to remain at the hospital for 24 hours or more)

bull CMS also notes that an inpatient admission (and Part A payment) should be ldquorare and unusualrdquo for minor surgical procedures or other treatment that is expected to keep the patient in the hospital ldquofor only a few hoursrdquo or for a period of time that ldquodoes not span at least overnightrdquo (thus a subset of stays not meeting the Two Midnight Benchmark) CMS indicates that such cases will be prioritized for medical review

70

Health Data Insights amp Medicare Plus Blue

RAC (Retrospective Audits)

71

HDI Health Data amp Med Plus Blue

bull httpwwwhealthdatainsightscombull Blue Cross Medicare Advantage Auditsbull Facilities seeing 10 to 15 requests for Medical Recordsbull In January amp Feburarybull Selected Health Data Insights because they were a premier Audit

Vendor for CMS Recovery Audit Contractor (RAC) demonstration Project They are a audit vendor for Humana

bull Providers not sending Medical Record will get technical denial and lose payments

72

Health Data InSight

bull In 2010 they began the Hospital Reviewbull Medicare Advantage encounter datandashCMS oversight of data integrity OIG

2016bull We will review CMSs oversight of MA encounter data validation and assess

the extent to which CMSrsquos Integrated Data Repository contains timely valid and complete MA encounter data In 2012 CMS began collecting from MA organizations a more comprehensive set of encounter data reflecting the items and services provided to MA plan enrollees Prior CMS and OIG audits have indicated vulnerabilities in the accuracy of data reporting by MA organizations Realizing the potential benefits of the MA encounter data for payment and program integrity oversight is contingent upon the datarsquos completeness validity and timeliness (OEI 03-15-00060 expected issue date FY 2017)

73

Pepper Reports

bull httpswwwpepperresourcesorg

bull Program for Evaluating Payment Patterns Electronic Report ( PEPPER)

bull Annually on or about April 18 2016 will be released

bull Pepper Portal httpssecurefiletmforg

74

CGI Technologies and Solutions Inc httpracbcgicomContactInfoaspxst=1

bull Indiana bull Michiganbull Minnesotabull Illinoisbull Kentuckybull Ohiobull Wisconsin CGI Technologies and Solutions Incbull For general and administrative questions regarding client service outreach

quality assurance or project-specific issues contactbull 1877316RACB (7222)bull Email racbcgicom Tamara Tate Tamaratatecmshhsgovbull 4107861288

75

CGI Federal RAC

bull CGI Federal RAC Region Bbull Email racbcgicombull Phone 1-877-316-RACB (7222)bull Mailing Addressbull Send medical records as followsbull Medical records for Indiana Illinois Kentucky Michigan Ohio Wisconsin

Minnesota DME and Home Health CGI Federal Inc Attn RACB Imaging Dept 1001 Lakeside Ave Suite 800 Cleveland OH 44114

bull If submitting paper records please send medical records as follows For Therapy Reviews CGI Federal Inc Attn RACB Imaging 1001 Lakeside Avenue Suite 800 Cleveland OH 44114

76

How to survive RAC Audit

bull National health expenditures totaled $1679 Billion in 2003 bull National health expenditures were 153 of GROSS Domestic Product

(GDP) in 2003 bull Health care cost increasing at +9 per year bull Doomsday predictions of Medicare running out bull Congressional Action

77

RAC Audits

bull Medicare Modernization Act (MMA) of 2003Mandated a three year audit demonstration project 2005-2008

bull Appoint audit contractors to review Medicare billings for proper coding DRG assignment and medical necessity

bull Audits will apply to all health care providers (hospitals physicians homecare dme etc)

bull Audit contractors to be paid on a contingency basis a percentage of overpayments recovered

78

How Did we get here

bull Overpayments collected due to errors in Medically Unnecessary Services ndash 40

bull Incorrectly Coded ndash 35

bull Other ndash 17

bull NoInsufficient Documentation ndash 8

79

Where are we now

bull All RACrsquos completed required provider outreachAccess to Medicare billing data base given to all RAC RAC review methodology

bull Automated Review-Black amp White Issues (current) bull DRG Validation-complex review (current) bull Complex Review for coding errors (current) bull DME Medical Necessity Reviews ndashcomplex review (calendar year

2010) bull Medical Necessity Reviews-complex review (calendar year 2010)

80

RAC Reviews

bull Responsibilities of the Team Leader bull Must learn each insurance provider participating in a RAC or RAC type

program bull What are their operating rulesbull What is their appeal process Time limits

May be different process for each insurance provider bull Develop a response team

Identify who does what when why and alternate bull individual

Build and develop a manual process Review of computerized system

81

Priority Health SCIO Health Analytics

bull httpswwwsciohealthanalyticscomcore-capabilitiespayment-integrityfacility-auditsskilled-nursing-facility-audits

bull Claims for Medicare members treated at Skilled Nursing Facilities are reimbursed based on the patientsrsquo RUG (Resource Utilization Group) score which is determined using the Minimum Data Set (MDS) Using SCIOs robust analytics claims andor providers that merit review are selected for audit SCIOs auditors conduct a detailed review of the complete medical record and associated MDS to determine if the billed RUG score is valid In the event the review determines that an incorrect RUG score was billed SCIOreg provides the valid score reports the reason the change was necessary and calculates the resulting overpayment

82

+ Cheer

Onward and Upward she shall prevail We are here to care for the residents and provide a wonderful

service

13 83

84

References

bull Priority Healthbull Blue Crossbull Medicaidbull Medicare

85

  • Medicare Mange Care amp Medicaid Changes in the New World We Live In
  • Medicaid
  • NEW Medicaid Change MIlogin
  • Blueprint for Health Innovation MI
  • Provider Enrollment Electronic Signature Form Submission Process MSA 15-54
  • Provider Enrollment Electronic Signature Form Submission Process
  • Provider Enrollment Domain Administrator
  • Medicaid Coinsurance Medicare Advantage
  • Slide Number 9
  • Lawsuit DHS Changes on Caregivers
  • TPL Medicaid Change
  • CHAMPS Member Screen
  • LOC dropping off Not Due to MI Health
  • Issues
  • Secure Email Information
  • Medicaid amp Hospice
  • Medicaid
  • Medicaid Medicare Buy In
  • Manage Medicaid
  • Healthy Michigan Residents
  • Healthy Michigan Medicaid Days
  • McLaren Health Plan
  • Manage Medicaid Plans January 1
  • Slide Number 24
  • MI Health Link
  • MI Health Link 2565
  • What are the Names
  • MI Health Dual Eligible
  • MI Health LOC
  • LOC Medicaid
  • Medicaid Redetermination and MHL Enrollment
  • MI Health Link Portals
  • MI Health Authorizations
  • MI Health Issues
  • LOC 02 dropping MI Health Issues
  • PPA Offset
  • LOCD
  • MI Health Issues-New
  • ACO
  • Families Receiving Letters for ACO
  • ACO What is It
  • Payroll Based Journal
  • Slide Number 43
  • If you submit data manually should you also submit it through the XML
  • Staffing Submission Frequently Asked Questions
  • CMS defines
  • Slide Number 47
  • PBJ Medical Director Role
  • PBJ Medical Director Role
  • Dietician
  • Pharmacy Consultant
  • What are the names for the Medicare Number
  • QTSO
  • Medicare Update
  • CMS Final Rule On Returning Credits
  • Over Payment Rule
  • Questions to MAC
  • Questions to MAC
  • Final Rule on Returning Credits
  • Final Rule on Returning Credits
  • Final Rule on Returning Credits
  • Slide Number 62
  • Medicare Advantage Payors
  • Medicare Provider Enrollment Fee
  • Medicare MAC-Higlas
  • Two Midnight Rule
  • Two Midnight Rule
  • Two Midnight Rule
  • InPatient Vs Observation Conthellip
  • Two Midnight Rule
  • Health Data Insights amp Medicare Plus Blue
  • HDI Health Data amp Med Plus Blue
  • Health Data InSight
  • Pepper Reports
  • CGI Technologies and Solutions Inc httpracbcgicomContactInfoaspxst=1
  • CGI Federal RAC
  • How to survive RAC Audit
  • RAC Audits
  • How Did we get here
  • Where are we now
  • RAC Reviews
  • Priority Health SCIO Health Analytics
  • Cheer
  • References
Page 49: Medicare, Mange Care & Medicaid Changes in the New World we live in

PBJ Medical Director Rolebull Quality of Care

bull Help the facility establish systems and methods for reviewing the quality and appropriateness of clinical care and other health-related services and provide appropriate feedback and

bull Participate in the facilitys quality improvement process

bull Advise on infection control issues and approve specific infection control policies to be incorporated into facility policies and procedures

bull Help the facility provide a safe and caring environment

bull Help promote employee health and safety and

bull Assist in the development and implementation of employee health policies and programs

bull Education Information and Communication

bull Promote a learning culture within the facility by educating informing and communicating

bull Provide information to help the facility provide care consistent with current standards of practice (defined as approaches to care procedures techniques and treatments that are based on research and or expert consensus and that are contained in current manuals textbooks and or publications or that are accepted adopted or promulgated by recognized organizations or national bodies)

bull Help the facility develop medical information and communication systems with staff patients and families and others

bull Represent the facility to the professional and lay community on medical and patient care issues

bull Maintain knowledge of the changing social regulatory political and economic factors that affect medical and health services of long term care patients and

bull Help establish appropriate relationships with other health care organizations

49

Dietician

bull When the dietary or food services supervisor is other than a registered dietitian the supervisor shall receive routine consultation and technical assistance from a registered dietitian (RD) Consultation time shall not be less than 4 hours every 60 days Additional consultation time may be needed based on the total number of patients incidence of nutrition-related health problems and food service management needs of the facility

50

Pharmacy Consultant

bull At least once per month a licensed pharmacist must perform a drug regimen review (DRR) for each resident The pharmacist must report any irregularities to the attending physician or director of nursing Furthermore these reports must be acted upon

51

What are the names for the Medicare Numberbull OSCAR -Online Survey Certification and Reporting

bull PTAN-PTAN number is assigned by Medicare to authenticate the provider when using the local Medicare Administrative Contractorrsquos (MAC) self-help tools like the IVR internet portal on-line application status etc Provider Transactions Access Number

bull CCN- CMS Certification Number

bull Medicare Number- example 23-

bull All of the above mean the same thing

52

QTSO

bull Once you are logged in the QTSO site bull You will have a state login to the site to access the various site specific

to your facilitybull Installing you will need administrator rights to your network

53

Medicare UpdateWhat are we seeing

54

CMS Final Rule On Returning Credits

httpswwwfederalregistergovarticles201602122016-02789medicare-program-reporting-and-returning-of-overpayments

55

Over Payment Rule

bull Medicare payments for non covered services

bull Medicare payments in excess of the allowable amount for an identified covered service

bull Errors and non reimbursable expenditures in cost reportsbull Duplicate payment

bull Receipt of Medicare payments when another payor had the primary responsibility for payment

56

Questions to MAC

bull Does the Medicare credit balance report change with this overpayment rule

bull No Medicare Credit Balances are still required at the end of each quarter

bull Will that still be the communication to let CMS or the MAC know that we have received an overpayment

bull Submission of Medicare Credit Balance is one form of communicating overpayments to CMS Other methods include submitting a voluntary refund with required claim information or the submission of a standard overpayment form

57

Questions to MAC

bull Will the MAC still deduct from a future RAbull If the recovery of the overpayment includes adjusting a claim then

the overpayment would be netted against future claims payments and reflected on the RA

bull Or will that process change with this new rulebull Process will remain the samebull Will NGS send communication out on thisbull Yes NGS will communicate this once the final rule is communicated

to the MACs by CMS However this could change depending on final CMS instructions

58

Final Rule on Returning Credits

bull Providers will want to immediately update their current policies governing overpayments in order to comply with this new rule which will take effect on March 14 2016

bull Providers and suppliers are required to use reasonable diligence to investigate credible information regarding overpayments through both proactive compliance efforts and reactive investigations

bull If an overpayment is identified then it must be repaid within 60 days An overpayment is identified when a person has or should have through the exercise of reasonable diligence determined that the person received an overpayment and quantified the amount

bull Providers and suppliers have a maximum of 8 months to report and return overpayments ndash up to 6 months to investigate and quantify the overpayment (ie to identify it) and up to 60 days to report and return the overpayment

59

Final Rule on Returning Credits

bull Providers and suppliers are required to report and return all overpayments within a 6-year lookback period

bull The cause and amount of the overpayment is irrelevant for the determination eg it was due to a mistake it was someone elsersquos fault it is a minor amount An overpayment is an overpayment and must be returned

bull Providers and suppliers must make their own determination to which entity to report and return the overpayment ie to the Medicare contractor or using the OIG Self Disclosure Protocol or the CMS Self Referral Disclosure Protocol

60

Final Rule on Returning Credits

bull Providers and suppliers may use the claims adjustment credit balance self-reported refund process or another appropriate process to report and return overpayments At this time there is no standard refund form to use

bull Failure to report and return an overpayment could subject the provider or supplier to False Claims Act liability Civil Monetary Penalties Law liability and exclusion from federal health care programs

61

P S amp R-Accountants will be asking for this information

The location you login into has changed it is now on EIDM EIDM is the acronym for CMS Enterprise Identity Management system which includes Identity Verification Access Management Authorization Assistance Workflow Tools and Identity Lifecycle Management functions

httpswwwcmsgovResearch-Statistics-Data-and-SystemsCMS-Information-TechnologyIACSCMS-Applications-Loginhtml

Go down the page and click on the PSampRSTARThis will take you to the login pagewill look the same as the old P S amp R didChanges Affecting PSampR System Access (Please Read) (posted 01292015)(Updated 5262015)is changingThe system which controls your PSampR user ID (currently IACS)The new system is referred to as EIDMThis will result in a different way to create new accounts or change passwords to existing accountsIf you already have an account in EIDM you may have to use that account for accessing PSampR after the transitionWhen is the change effectiveJune 13 2015What is staying the sameThe internet address for accessing PSampR remains the sameThe PSampR systemfunctionality is NOT changing 62

Medicare Advantage Payorsbull Medicare Advantage payors are pullingdenying payments on admissions if the patient was readmitted within 30 days after discharge The

client believes that the payors systematically denying payments for all readmissions within 30 days They believe this practice denies them due process to address whether the readmissions were justified and not due to a premature discharge of patient The payors seem to want to act like a QIO without having the same accountabilities of the QIO related to determinations of non-payment

bull Heres the QIO process under section 4240 of the QIO Manualbull 4240 - Readmission Review - (Rev 2 07-11-03)bull Readmission review involves admissions to an acute general short-term hospital occurring less than 31 calendar days from the date of

discharge from the same or another acute general short-term hospital (see sect1154(a)(13) and 42 CFR 47671(a)(8)(ii)) Neither the day of discharge nor the day of admission is counted when determining whether a readmission has occurred

bull A Medical Review Proceduresbull Obtain the appropriate medical records for the initial admission and readmission Perform case review on both stays Analyze the cases

specifically to determine whether the patient was prematurely discharged from the first confinement thus causing readmission Perform an analysis of the stay at the first hospital to determine the cause(s) and extent of any problem(s) (eg incomplete or substandard treatment) Consider the information available to the attending physician who discharged the patient from the first confinement Do not base a determination of a premature discharge on information that the physician or provider could not have known or events that could not have been anticipated at the time of discharge

bull Review both the initial admission and the readmission at the same time unless one of them has previously been reviewed In these cases use at a minimum the PRAF case summary of the other admission in addition to the medical record of the case under review

bull C Denialsbull Deny readmissions under the following circumstancesbull If the readmission was medically unnecessarybull If the readmission resulted from a premature discharge from the same hospital orbull If the readmission was a result of circumvention of PPS by the same hospital (see sect4255)bull With the QIO process there is an appeal within the QIO here the hospital is getting no opportunity to challenge the denials

63

Medicare Provider Enrollment Feebull Provider Enrollment Application Fee Amount for CY 2016bull On December 3 CMS issued a notice Provider Enrollment Application

Fee Amount for CY 2016 [CMSndash6066ndashN] Effective January 1 2016 the CY 2016 application fee is $554 for institutional providers that are

bull Initially enrolling in the Medicare or Medicaid program or the Childrens Health Insurance Program (CHIP)

bull Revalidating their Medicare Medicaid or CHIP enrollmentbull Adding a new Medicare practice locationbull This fee is required with any enrollment application submitted from

January 1 through December 31 2016

64

Medicare MAC-Higlas

bull Effective 142016 CMS has implemented a change to begin netting (offsetting) provider money across workloads within a single organization What this means is that any related providers conducting business in two different workloads (example New York and Maine) will have their money applied to any account receivables (AR) with a remaining balance owed to Medicare within both workloads For example Provider ABC is located in New York and is scheduled to receive a payment of $1000 on todays remittance advice Provider XYZ is related to provider ABC but is located in Maine and has ARs with a balance owed of $200 Provider ABCs $1000 payment will have the $200 applied against provider XYZs ARs resulting in a net payment of $800 This will be reflected on the remittance advice by the same PLB code as seen today for offsets for the $200

65

Two Midnight RuleChange January 1 2016 httpswwwcmsgovMedicareMedicare-Fee-for-Service-PaymentHospitalOutpatientPPSHospital-Outpatient-Regulations-and-Notices-ItemsCMS-1633-FChtml

66

Two Midnight Rulebull However effective January 1 2016 CMS will allow exceptions to the

Two-Midnight Benchmark to be determined on a case-by-case basis by the physician responsible for the care of the beneficiary subject to medical review Said differently Part A payment may be appropriate in some circumstances even though there is no expectation by the physician (or qualified ordering practitioner) of a two-midnight stay and one of the two pre-existing categorical exceptions (CMS ldquoinpatient onlyrdquo list and newly initiated mechanical ventilation) does not apply CMS has indicated that this change to the Two Midnight Rule is in response to stakeholder concern and CMSrsquos continued efforts to develop the most appropriate standard for determining Medicare Part A payment

67

Two Midnight Rulebull A new 42 CFR sect4123(a) provides that a patient is considered an

inpatient of a hospitalhellipif formally admitted as an inpatient pursuant to an order for inpatient admission by a physician or other qualified practitionerhellip The physician orders inpatient status when he or she expects the patient to require a stay that crosses at least 2 midnights[10] Stays expected to be shorter than at least two midnights are generally inappropriate for inpatient admission and inpatient payment under Medicare Part A unless the surgical procedure is specified by Medicare as inpatient only under sect41922(n)[11] The physicians expectationhellipshould be based on such complex medical factors as patient history and comorbidities the severity of signs and symptoms current medical needs and the risk of an adverse event[12] The physician order is part of physician certification of the medical necessity of hospital inpatient serviceshellip[13]

68

InPatient Vs Observation Conthellip

bull Physician certification which begins with an order for inpatient admission requires the physician to certify the reasons for the hospitalization the estimated time the patient will remain in the hospital and plans for post-hospital care if appropriate[14] The certification must be completed signed and documented in the medical record prior to discharge[15]

bull A physicians admission order has no presumptive weight and both the admission order and the physician certification will be evaluated in the context of the evidence in the medical record[16] CMS intends to provide additional information about what evidence in the medical record means in future instructions and manual revisions[17]

69

Two Midnight Rulebull Although the new case-by-case exception appears to be inherently

subjective to a certain extent CMS states that the following factors (among others) would be relevant to determining whether a patient requires inpatient admission under the expanded policy

bull The severity of the signs and symptoms exhibited by the patient bull The medical predictability of something adverse happening to the patient

and bull The need for diagnostic studies that appropriately are outpatient services

(that is their performance does not ordinarily require the patient to remain at the hospital for 24 hours or more)

bull CMS also notes that an inpatient admission (and Part A payment) should be ldquorare and unusualrdquo for minor surgical procedures or other treatment that is expected to keep the patient in the hospital ldquofor only a few hoursrdquo or for a period of time that ldquodoes not span at least overnightrdquo (thus a subset of stays not meeting the Two Midnight Benchmark) CMS indicates that such cases will be prioritized for medical review

70

Health Data Insights amp Medicare Plus Blue

RAC (Retrospective Audits)

71

HDI Health Data amp Med Plus Blue

bull httpwwwhealthdatainsightscombull Blue Cross Medicare Advantage Auditsbull Facilities seeing 10 to 15 requests for Medical Recordsbull In January amp Feburarybull Selected Health Data Insights because they were a premier Audit

Vendor for CMS Recovery Audit Contractor (RAC) demonstration Project They are a audit vendor for Humana

bull Providers not sending Medical Record will get technical denial and lose payments

72

Health Data InSight

bull In 2010 they began the Hospital Reviewbull Medicare Advantage encounter datandashCMS oversight of data integrity OIG

2016bull We will review CMSs oversight of MA encounter data validation and assess

the extent to which CMSrsquos Integrated Data Repository contains timely valid and complete MA encounter data In 2012 CMS began collecting from MA organizations a more comprehensive set of encounter data reflecting the items and services provided to MA plan enrollees Prior CMS and OIG audits have indicated vulnerabilities in the accuracy of data reporting by MA organizations Realizing the potential benefits of the MA encounter data for payment and program integrity oversight is contingent upon the datarsquos completeness validity and timeliness (OEI 03-15-00060 expected issue date FY 2017)

73

Pepper Reports

bull httpswwwpepperresourcesorg

bull Program for Evaluating Payment Patterns Electronic Report ( PEPPER)

bull Annually on or about April 18 2016 will be released

bull Pepper Portal httpssecurefiletmforg

74

CGI Technologies and Solutions Inc httpracbcgicomContactInfoaspxst=1

bull Indiana bull Michiganbull Minnesotabull Illinoisbull Kentuckybull Ohiobull Wisconsin CGI Technologies and Solutions Incbull For general and administrative questions regarding client service outreach

quality assurance or project-specific issues contactbull 1877316RACB (7222)bull Email racbcgicom Tamara Tate Tamaratatecmshhsgovbull 4107861288

75

CGI Federal RAC

bull CGI Federal RAC Region Bbull Email racbcgicombull Phone 1-877-316-RACB (7222)bull Mailing Addressbull Send medical records as followsbull Medical records for Indiana Illinois Kentucky Michigan Ohio Wisconsin

Minnesota DME and Home Health CGI Federal Inc Attn RACB Imaging Dept 1001 Lakeside Ave Suite 800 Cleveland OH 44114

bull If submitting paper records please send medical records as follows For Therapy Reviews CGI Federal Inc Attn RACB Imaging 1001 Lakeside Avenue Suite 800 Cleveland OH 44114

76

How to survive RAC Audit

bull National health expenditures totaled $1679 Billion in 2003 bull National health expenditures were 153 of GROSS Domestic Product

(GDP) in 2003 bull Health care cost increasing at +9 per year bull Doomsday predictions of Medicare running out bull Congressional Action

77

RAC Audits

bull Medicare Modernization Act (MMA) of 2003Mandated a three year audit demonstration project 2005-2008

bull Appoint audit contractors to review Medicare billings for proper coding DRG assignment and medical necessity

bull Audits will apply to all health care providers (hospitals physicians homecare dme etc)

bull Audit contractors to be paid on a contingency basis a percentage of overpayments recovered

78

How Did we get here

bull Overpayments collected due to errors in Medically Unnecessary Services ndash 40

bull Incorrectly Coded ndash 35

bull Other ndash 17

bull NoInsufficient Documentation ndash 8

79

Where are we now

bull All RACrsquos completed required provider outreachAccess to Medicare billing data base given to all RAC RAC review methodology

bull Automated Review-Black amp White Issues (current) bull DRG Validation-complex review (current) bull Complex Review for coding errors (current) bull DME Medical Necessity Reviews ndashcomplex review (calendar year

2010) bull Medical Necessity Reviews-complex review (calendar year 2010)

80

RAC Reviews

bull Responsibilities of the Team Leader bull Must learn each insurance provider participating in a RAC or RAC type

program bull What are their operating rulesbull What is their appeal process Time limits

May be different process for each insurance provider bull Develop a response team

Identify who does what when why and alternate bull individual

Build and develop a manual process Review of computerized system

81

Priority Health SCIO Health Analytics

bull httpswwwsciohealthanalyticscomcore-capabilitiespayment-integrityfacility-auditsskilled-nursing-facility-audits

bull Claims for Medicare members treated at Skilled Nursing Facilities are reimbursed based on the patientsrsquo RUG (Resource Utilization Group) score which is determined using the Minimum Data Set (MDS) Using SCIOs robust analytics claims andor providers that merit review are selected for audit SCIOs auditors conduct a detailed review of the complete medical record and associated MDS to determine if the billed RUG score is valid In the event the review determines that an incorrect RUG score was billed SCIOreg provides the valid score reports the reason the change was necessary and calculates the resulting overpayment

82

+ Cheer

Onward and Upward she shall prevail We are here to care for the residents and provide a wonderful

service

13 83

84

References

bull Priority Healthbull Blue Crossbull Medicaidbull Medicare

85

  • Medicare Mange Care amp Medicaid Changes in the New World We Live In
  • Medicaid
  • NEW Medicaid Change MIlogin
  • Blueprint for Health Innovation MI
  • Provider Enrollment Electronic Signature Form Submission Process MSA 15-54
  • Provider Enrollment Electronic Signature Form Submission Process
  • Provider Enrollment Domain Administrator
  • Medicaid Coinsurance Medicare Advantage
  • Slide Number 9
  • Lawsuit DHS Changes on Caregivers
  • TPL Medicaid Change
  • CHAMPS Member Screen
  • LOC dropping off Not Due to MI Health
  • Issues
  • Secure Email Information
  • Medicaid amp Hospice
  • Medicaid
  • Medicaid Medicare Buy In
  • Manage Medicaid
  • Healthy Michigan Residents
  • Healthy Michigan Medicaid Days
  • McLaren Health Plan
  • Manage Medicaid Plans January 1
  • Slide Number 24
  • MI Health Link
  • MI Health Link 2565
  • What are the Names
  • MI Health Dual Eligible
  • MI Health LOC
  • LOC Medicaid
  • Medicaid Redetermination and MHL Enrollment
  • MI Health Link Portals
  • MI Health Authorizations
  • MI Health Issues
  • LOC 02 dropping MI Health Issues
  • PPA Offset
  • LOCD
  • MI Health Issues-New
  • ACO
  • Families Receiving Letters for ACO
  • ACO What is It
  • Payroll Based Journal
  • Slide Number 43
  • If you submit data manually should you also submit it through the XML
  • Staffing Submission Frequently Asked Questions
  • CMS defines
  • Slide Number 47
  • PBJ Medical Director Role
  • PBJ Medical Director Role
  • Dietician
  • Pharmacy Consultant
  • What are the names for the Medicare Number
  • QTSO
  • Medicare Update
  • CMS Final Rule On Returning Credits
  • Over Payment Rule
  • Questions to MAC
  • Questions to MAC
  • Final Rule on Returning Credits
  • Final Rule on Returning Credits
  • Final Rule on Returning Credits
  • Slide Number 62
  • Medicare Advantage Payors
  • Medicare Provider Enrollment Fee
  • Medicare MAC-Higlas
  • Two Midnight Rule
  • Two Midnight Rule
  • Two Midnight Rule
  • InPatient Vs Observation Conthellip
  • Two Midnight Rule
  • Health Data Insights amp Medicare Plus Blue
  • HDI Health Data amp Med Plus Blue
  • Health Data InSight
  • Pepper Reports
  • CGI Technologies and Solutions Inc httpracbcgicomContactInfoaspxst=1
  • CGI Federal RAC
  • How to survive RAC Audit
  • RAC Audits
  • How Did we get here
  • Where are we now
  • RAC Reviews
  • Priority Health SCIO Health Analytics
  • Cheer
  • References
Page 50: Medicare, Mange Care & Medicaid Changes in the New World we live in

Dietician

bull When the dietary or food services supervisor is other than a registered dietitian the supervisor shall receive routine consultation and technical assistance from a registered dietitian (RD) Consultation time shall not be less than 4 hours every 60 days Additional consultation time may be needed based on the total number of patients incidence of nutrition-related health problems and food service management needs of the facility

50

Pharmacy Consultant

bull At least once per month a licensed pharmacist must perform a drug regimen review (DRR) for each resident The pharmacist must report any irregularities to the attending physician or director of nursing Furthermore these reports must be acted upon

51

What are the names for the Medicare Numberbull OSCAR -Online Survey Certification and Reporting

bull PTAN-PTAN number is assigned by Medicare to authenticate the provider when using the local Medicare Administrative Contractorrsquos (MAC) self-help tools like the IVR internet portal on-line application status etc Provider Transactions Access Number

bull CCN- CMS Certification Number

bull Medicare Number- example 23-

bull All of the above mean the same thing

52

QTSO

bull Once you are logged in the QTSO site bull You will have a state login to the site to access the various site specific

to your facilitybull Installing you will need administrator rights to your network

53

Medicare UpdateWhat are we seeing

54

CMS Final Rule On Returning Credits

httpswwwfederalregistergovarticles201602122016-02789medicare-program-reporting-and-returning-of-overpayments

55

Over Payment Rule

bull Medicare payments for non covered services

bull Medicare payments in excess of the allowable amount for an identified covered service

bull Errors and non reimbursable expenditures in cost reportsbull Duplicate payment

bull Receipt of Medicare payments when another payor had the primary responsibility for payment

56

Questions to MAC

bull Does the Medicare credit balance report change with this overpayment rule

bull No Medicare Credit Balances are still required at the end of each quarter

bull Will that still be the communication to let CMS or the MAC know that we have received an overpayment

bull Submission of Medicare Credit Balance is one form of communicating overpayments to CMS Other methods include submitting a voluntary refund with required claim information or the submission of a standard overpayment form

57

Questions to MAC

bull Will the MAC still deduct from a future RAbull If the recovery of the overpayment includes adjusting a claim then

the overpayment would be netted against future claims payments and reflected on the RA

bull Or will that process change with this new rulebull Process will remain the samebull Will NGS send communication out on thisbull Yes NGS will communicate this once the final rule is communicated

to the MACs by CMS However this could change depending on final CMS instructions

58

Final Rule on Returning Credits

bull Providers will want to immediately update their current policies governing overpayments in order to comply with this new rule which will take effect on March 14 2016

bull Providers and suppliers are required to use reasonable diligence to investigate credible information regarding overpayments through both proactive compliance efforts and reactive investigations

bull If an overpayment is identified then it must be repaid within 60 days An overpayment is identified when a person has or should have through the exercise of reasonable diligence determined that the person received an overpayment and quantified the amount

bull Providers and suppliers have a maximum of 8 months to report and return overpayments ndash up to 6 months to investigate and quantify the overpayment (ie to identify it) and up to 60 days to report and return the overpayment

59

Final Rule on Returning Credits

bull Providers and suppliers are required to report and return all overpayments within a 6-year lookback period

bull The cause and amount of the overpayment is irrelevant for the determination eg it was due to a mistake it was someone elsersquos fault it is a minor amount An overpayment is an overpayment and must be returned

bull Providers and suppliers must make their own determination to which entity to report and return the overpayment ie to the Medicare contractor or using the OIG Self Disclosure Protocol or the CMS Self Referral Disclosure Protocol

60

Final Rule on Returning Credits

bull Providers and suppliers may use the claims adjustment credit balance self-reported refund process or another appropriate process to report and return overpayments At this time there is no standard refund form to use

bull Failure to report and return an overpayment could subject the provider or supplier to False Claims Act liability Civil Monetary Penalties Law liability and exclusion from federal health care programs

61

P S amp R-Accountants will be asking for this information

The location you login into has changed it is now on EIDM EIDM is the acronym for CMS Enterprise Identity Management system which includes Identity Verification Access Management Authorization Assistance Workflow Tools and Identity Lifecycle Management functions

httpswwwcmsgovResearch-Statistics-Data-and-SystemsCMS-Information-TechnologyIACSCMS-Applications-Loginhtml

Go down the page and click on the PSampRSTARThis will take you to the login pagewill look the same as the old P S amp R didChanges Affecting PSampR System Access (Please Read) (posted 01292015)(Updated 5262015)is changingThe system which controls your PSampR user ID (currently IACS)The new system is referred to as EIDMThis will result in a different way to create new accounts or change passwords to existing accountsIf you already have an account in EIDM you may have to use that account for accessing PSampR after the transitionWhen is the change effectiveJune 13 2015What is staying the sameThe internet address for accessing PSampR remains the sameThe PSampR systemfunctionality is NOT changing 62

Medicare Advantage Payorsbull Medicare Advantage payors are pullingdenying payments on admissions if the patient was readmitted within 30 days after discharge The

client believes that the payors systematically denying payments for all readmissions within 30 days They believe this practice denies them due process to address whether the readmissions were justified and not due to a premature discharge of patient The payors seem to want to act like a QIO without having the same accountabilities of the QIO related to determinations of non-payment

bull Heres the QIO process under section 4240 of the QIO Manualbull 4240 - Readmission Review - (Rev 2 07-11-03)bull Readmission review involves admissions to an acute general short-term hospital occurring less than 31 calendar days from the date of

discharge from the same or another acute general short-term hospital (see sect1154(a)(13) and 42 CFR 47671(a)(8)(ii)) Neither the day of discharge nor the day of admission is counted when determining whether a readmission has occurred

bull A Medical Review Proceduresbull Obtain the appropriate medical records for the initial admission and readmission Perform case review on both stays Analyze the cases

specifically to determine whether the patient was prematurely discharged from the first confinement thus causing readmission Perform an analysis of the stay at the first hospital to determine the cause(s) and extent of any problem(s) (eg incomplete or substandard treatment) Consider the information available to the attending physician who discharged the patient from the first confinement Do not base a determination of a premature discharge on information that the physician or provider could not have known or events that could not have been anticipated at the time of discharge

bull Review both the initial admission and the readmission at the same time unless one of them has previously been reviewed In these cases use at a minimum the PRAF case summary of the other admission in addition to the medical record of the case under review

bull C Denialsbull Deny readmissions under the following circumstancesbull If the readmission was medically unnecessarybull If the readmission resulted from a premature discharge from the same hospital orbull If the readmission was a result of circumvention of PPS by the same hospital (see sect4255)bull With the QIO process there is an appeal within the QIO here the hospital is getting no opportunity to challenge the denials

63

Medicare Provider Enrollment Feebull Provider Enrollment Application Fee Amount for CY 2016bull On December 3 CMS issued a notice Provider Enrollment Application

Fee Amount for CY 2016 [CMSndash6066ndashN] Effective January 1 2016 the CY 2016 application fee is $554 for institutional providers that are

bull Initially enrolling in the Medicare or Medicaid program or the Childrens Health Insurance Program (CHIP)

bull Revalidating their Medicare Medicaid or CHIP enrollmentbull Adding a new Medicare practice locationbull This fee is required with any enrollment application submitted from

January 1 through December 31 2016

64

Medicare MAC-Higlas

bull Effective 142016 CMS has implemented a change to begin netting (offsetting) provider money across workloads within a single organization What this means is that any related providers conducting business in two different workloads (example New York and Maine) will have their money applied to any account receivables (AR) with a remaining balance owed to Medicare within both workloads For example Provider ABC is located in New York and is scheduled to receive a payment of $1000 on todays remittance advice Provider XYZ is related to provider ABC but is located in Maine and has ARs with a balance owed of $200 Provider ABCs $1000 payment will have the $200 applied against provider XYZs ARs resulting in a net payment of $800 This will be reflected on the remittance advice by the same PLB code as seen today for offsets for the $200

65

Two Midnight RuleChange January 1 2016 httpswwwcmsgovMedicareMedicare-Fee-for-Service-PaymentHospitalOutpatientPPSHospital-Outpatient-Regulations-and-Notices-ItemsCMS-1633-FChtml

66

Two Midnight Rulebull However effective January 1 2016 CMS will allow exceptions to the

Two-Midnight Benchmark to be determined on a case-by-case basis by the physician responsible for the care of the beneficiary subject to medical review Said differently Part A payment may be appropriate in some circumstances even though there is no expectation by the physician (or qualified ordering practitioner) of a two-midnight stay and one of the two pre-existing categorical exceptions (CMS ldquoinpatient onlyrdquo list and newly initiated mechanical ventilation) does not apply CMS has indicated that this change to the Two Midnight Rule is in response to stakeholder concern and CMSrsquos continued efforts to develop the most appropriate standard for determining Medicare Part A payment

67

Two Midnight Rulebull A new 42 CFR sect4123(a) provides that a patient is considered an

inpatient of a hospitalhellipif formally admitted as an inpatient pursuant to an order for inpatient admission by a physician or other qualified practitionerhellip The physician orders inpatient status when he or she expects the patient to require a stay that crosses at least 2 midnights[10] Stays expected to be shorter than at least two midnights are generally inappropriate for inpatient admission and inpatient payment under Medicare Part A unless the surgical procedure is specified by Medicare as inpatient only under sect41922(n)[11] The physicians expectationhellipshould be based on such complex medical factors as patient history and comorbidities the severity of signs and symptoms current medical needs and the risk of an adverse event[12] The physician order is part of physician certification of the medical necessity of hospital inpatient serviceshellip[13]

68

InPatient Vs Observation Conthellip

bull Physician certification which begins with an order for inpatient admission requires the physician to certify the reasons for the hospitalization the estimated time the patient will remain in the hospital and plans for post-hospital care if appropriate[14] The certification must be completed signed and documented in the medical record prior to discharge[15]

bull A physicians admission order has no presumptive weight and both the admission order and the physician certification will be evaluated in the context of the evidence in the medical record[16] CMS intends to provide additional information about what evidence in the medical record means in future instructions and manual revisions[17]

69

Two Midnight Rulebull Although the new case-by-case exception appears to be inherently

subjective to a certain extent CMS states that the following factors (among others) would be relevant to determining whether a patient requires inpatient admission under the expanded policy

bull The severity of the signs and symptoms exhibited by the patient bull The medical predictability of something adverse happening to the patient

and bull The need for diagnostic studies that appropriately are outpatient services

(that is their performance does not ordinarily require the patient to remain at the hospital for 24 hours or more)

bull CMS also notes that an inpatient admission (and Part A payment) should be ldquorare and unusualrdquo for minor surgical procedures or other treatment that is expected to keep the patient in the hospital ldquofor only a few hoursrdquo or for a period of time that ldquodoes not span at least overnightrdquo (thus a subset of stays not meeting the Two Midnight Benchmark) CMS indicates that such cases will be prioritized for medical review

70

Health Data Insights amp Medicare Plus Blue

RAC (Retrospective Audits)

71

HDI Health Data amp Med Plus Blue

bull httpwwwhealthdatainsightscombull Blue Cross Medicare Advantage Auditsbull Facilities seeing 10 to 15 requests for Medical Recordsbull In January amp Feburarybull Selected Health Data Insights because they were a premier Audit

Vendor for CMS Recovery Audit Contractor (RAC) demonstration Project They are a audit vendor for Humana

bull Providers not sending Medical Record will get technical denial and lose payments

72

Health Data InSight

bull In 2010 they began the Hospital Reviewbull Medicare Advantage encounter datandashCMS oversight of data integrity OIG

2016bull We will review CMSs oversight of MA encounter data validation and assess

the extent to which CMSrsquos Integrated Data Repository contains timely valid and complete MA encounter data In 2012 CMS began collecting from MA organizations a more comprehensive set of encounter data reflecting the items and services provided to MA plan enrollees Prior CMS and OIG audits have indicated vulnerabilities in the accuracy of data reporting by MA organizations Realizing the potential benefits of the MA encounter data for payment and program integrity oversight is contingent upon the datarsquos completeness validity and timeliness (OEI 03-15-00060 expected issue date FY 2017)

73

Pepper Reports

bull httpswwwpepperresourcesorg

bull Program for Evaluating Payment Patterns Electronic Report ( PEPPER)

bull Annually on or about April 18 2016 will be released

bull Pepper Portal httpssecurefiletmforg

74

CGI Technologies and Solutions Inc httpracbcgicomContactInfoaspxst=1

bull Indiana bull Michiganbull Minnesotabull Illinoisbull Kentuckybull Ohiobull Wisconsin CGI Technologies and Solutions Incbull For general and administrative questions regarding client service outreach

quality assurance or project-specific issues contactbull 1877316RACB (7222)bull Email racbcgicom Tamara Tate Tamaratatecmshhsgovbull 4107861288

75

CGI Federal RAC

bull CGI Federal RAC Region Bbull Email racbcgicombull Phone 1-877-316-RACB (7222)bull Mailing Addressbull Send medical records as followsbull Medical records for Indiana Illinois Kentucky Michigan Ohio Wisconsin

Minnesota DME and Home Health CGI Federal Inc Attn RACB Imaging Dept 1001 Lakeside Ave Suite 800 Cleveland OH 44114

bull If submitting paper records please send medical records as follows For Therapy Reviews CGI Federal Inc Attn RACB Imaging 1001 Lakeside Avenue Suite 800 Cleveland OH 44114

76

How to survive RAC Audit

bull National health expenditures totaled $1679 Billion in 2003 bull National health expenditures were 153 of GROSS Domestic Product

(GDP) in 2003 bull Health care cost increasing at +9 per year bull Doomsday predictions of Medicare running out bull Congressional Action

77

RAC Audits

bull Medicare Modernization Act (MMA) of 2003Mandated a three year audit demonstration project 2005-2008

bull Appoint audit contractors to review Medicare billings for proper coding DRG assignment and medical necessity

bull Audits will apply to all health care providers (hospitals physicians homecare dme etc)

bull Audit contractors to be paid on a contingency basis a percentage of overpayments recovered

78

How Did we get here

bull Overpayments collected due to errors in Medically Unnecessary Services ndash 40

bull Incorrectly Coded ndash 35

bull Other ndash 17

bull NoInsufficient Documentation ndash 8

79

Where are we now

bull All RACrsquos completed required provider outreachAccess to Medicare billing data base given to all RAC RAC review methodology

bull Automated Review-Black amp White Issues (current) bull DRG Validation-complex review (current) bull Complex Review for coding errors (current) bull DME Medical Necessity Reviews ndashcomplex review (calendar year

2010) bull Medical Necessity Reviews-complex review (calendar year 2010)

80

RAC Reviews

bull Responsibilities of the Team Leader bull Must learn each insurance provider participating in a RAC or RAC type

program bull What are their operating rulesbull What is their appeal process Time limits

May be different process for each insurance provider bull Develop a response team

Identify who does what when why and alternate bull individual

Build and develop a manual process Review of computerized system

81

Priority Health SCIO Health Analytics

bull httpswwwsciohealthanalyticscomcore-capabilitiespayment-integrityfacility-auditsskilled-nursing-facility-audits

bull Claims for Medicare members treated at Skilled Nursing Facilities are reimbursed based on the patientsrsquo RUG (Resource Utilization Group) score which is determined using the Minimum Data Set (MDS) Using SCIOs robust analytics claims andor providers that merit review are selected for audit SCIOs auditors conduct a detailed review of the complete medical record and associated MDS to determine if the billed RUG score is valid In the event the review determines that an incorrect RUG score was billed SCIOreg provides the valid score reports the reason the change was necessary and calculates the resulting overpayment

82

+ Cheer

Onward and Upward she shall prevail We are here to care for the residents and provide a wonderful

service

13 83

84

References

bull Priority Healthbull Blue Crossbull Medicaidbull Medicare

85

  • Medicare Mange Care amp Medicaid Changes in the New World We Live In
  • Medicaid
  • NEW Medicaid Change MIlogin
  • Blueprint for Health Innovation MI
  • Provider Enrollment Electronic Signature Form Submission Process MSA 15-54
  • Provider Enrollment Electronic Signature Form Submission Process
  • Provider Enrollment Domain Administrator
  • Medicaid Coinsurance Medicare Advantage
  • Slide Number 9
  • Lawsuit DHS Changes on Caregivers
  • TPL Medicaid Change
  • CHAMPS Member Screen
  • LOC dropping off Not Due to MI Health
  • Issues
  • Secure Email Information
  • Medicaid amp Hospice
  • Medicaid
  • Medicaid Medicare Buy In
  • Manage Medicaid
  • Healthy Michigan Residents
  • Healthy Michigan Medicaid Days
  • McLaren Health Plan
  • Manage Medicaid Plans January 1
  • Slide Number 24
  • MI Health Link
  • MI Health Link 2565
  • What are the Names
  • MI Health Dual Eligible
  • MI Health LOC
  • LOC Medicaid
  • Medicaid Redetermination and MHL Enrollment
  • MI Health Link Portals
  • MI Health Authorizations
  • MI Health Issues
  • LOC 02 dropping MI Health Issues
  • PPA Offset
  • LOCD
  • MI Health Issues-New
  • ACO
  • Families Receiving Letters for ACO
  • ACO What is It
  • Payroll Based Journal
  • Slide Number 43
  • If you submit data manually should you also submit it through the XML
  • Staffing Submission Frequently Asked Questions
  • CMS defines
  • Slide Number 47
  • PBJ Medical Director Role
  • PBJ Medical Director Role
  • Dietician
  • Pharmacy Consultant
  • What are the names for the Medicare Number
  • QTSO
  • Medicare Update
  • CMS Final Rule On Returning Credits
  • Over Payment Rule
  • Questions to MAC
  • Questions to MAC
  • Final Rule on Returning Credits
  • Final Rule on Returning Credits
  • Final Rule on Returning Credits
  • Slide Number 62
  • Medicare Advantage Payors
  • Medicare Provider Enrollment Fee
  • Medicare MAC-Higlas
  • Two Midnight Rule
  • Two Midnight Rule
  • Two Midnight Rule
  • InPatient Vs Observation Conthellip
  • Two Midnight Rule
  • Health Data Insights amp Medicare Plus Blue
  • HDI Health Data amp Med Plus Blue
  • Health Data InSight
  • Pepper Reports
  • CGI Technologies and Solutions Inc httpracbcgicomContactInfoaspxst=1
  • CGI Federal RAC
  • How to survive RAC Audit
  • RAC Audits
  • How Did we get here
  • Where are we now
  • RAC Reviews
  • Priority Health SCIO Health Analytics
  • Cheer
  • References
Page 51: Medicare, Mange Care & Medicaid Changes in the New World we live in

Pharmacy Consultant

bull At least once per month a licensed pharmacist must perform a drug regimen review (DRR) for each resident The pharmacist must report any irregularities to the attending physician or director of nursing Furthermore these reports must be acted upon

51

What are the names for the Medicare Numberbull OSCAR -Online Survey Certification and Reporting

bull PTAN-PTAN number is assigned by Medicare to authenticate the provider when using the local Medicare Administrative Contractorrsquos (MAC) self-help tools like the IVR internet portal on-line application status etc Provider Transactions Access Number

bull CCN- CMS Certification Number

bull Medicare Number- example 23-

bull All of the above mean the same thing

52

QTSO

bull Once you are logged in the QTSO site bull You will have a state login to the site to access the various site specific

to your facilitybull Installing you will need administrator rights to your network

53

Medicare UpdateWhat are we seeing

54

CMS Final Rule On Returning Credits

httpswwwfederalregistergovarticles201602122016-02789medicare-program-reporting-and-returning-of-overpayments

55

Over Payment Rule

bull Medicare payments for non covered services

bull Medicare payments in excess of the allowable amount for an identified covered service

bull Errors and non reimbursable expenditures in cost reportsbull Duplicate payment

bull Receipt of Medicare payments when another payor had the primary responsibility for payment

56

Questions to MAC

bull Does the Medicare credit balance report change with this overpayment rule

bull No Medicare Credit Balances are still required at the end of each quarter

bull Will that still be the communication to let CMS or the MAC know that we have received an overpayment

bull Submission of Medicare Credit Balance is one form of communicating overpayments to CMS Other methods include submitting a voluntary refund with required claim information or the submission of a standard overpayment form

57

Questions to MAC

bull Will the MAC still deduct from a future RAbull If the recovery of the overpayment includes adjusting a claim then

the overpayment would be netted against future claims payments and reflected on the RA

bull Or will that process change with this new rulebull Process will remain the samebull Will NGS send communication out on thisbull Yes NGS will communicate this once the final rule is communicated

to the MACs by CMS However this could change depending on final CMS instructions

58

Final Rule on Returning Credits

bull Providers will want to immediately update their current policies governing overpayments in order to comply with this new rule which will take effect on March 14 2016

bull Providers and suppliers are required to use reasonable diligence to investigate credible information regarding overpayments through both proactive compliance efforts and reactive investigations

bull If an overpayment is identified then it must be repaid within 60 days An overpayment is identified when a person has or should have through the exercise of reasonable diligence determined that the person received an overpayment and quantified the amount

bull Providers and suppliers have a maximum of 8 months to report and return overpayments ndash up to 6 months to investigate and quantify the overpayment (ie to identify it) and up to 60 days to report and return the overpayment

59

Final Rule on Returning Credits

bull Providers and suppliers are required to report and return all overpayments within a 6-year lookback period

bull The cause and amount of the overpayment is irrelevant for the determination eg it was due to a mistake it was someone elsersquos fault it is a minor amount An overpayment is an overpayment and must be returned

bull Providers and suppliers must make their own determination to which entity to report and return the overpayment ie to the Medicare contractor or using the OIG Self Disclosure Protocol or the CMS Self Referral Disclosure Protocol

60

Final Rule on Returning Credits

bull Providers and suppliers may use the claims adjustment credit balance self-reported refund process or another appropriate process to report and return overpayments At this time there is no standard refund form to use

bull Failure to report and return an overpayment could subject the provider or supplier to False Claims Act liability Civil Monetary Penalties Law liability and exclusion from federal health care programs

61

P S amp R-Accountants will be asking for this information

The location you login into has changed it is now on EIDM EIDM is the acronym for CMS Enterprise Identity Management system which includes Identity Verification Access Management Authorization Assistance Workflow Tools and Identity Lifecycle Management functions

httpswwwcmsgovResearch-Statistics-Data-and-SystemsCMS-Information-TechnologyIACSCMS-Applications-Loginhtml

Go down the page and click on the PSampRSTARThis will take you to the login pagewill look the same as the old P S amp R didChanges Affecting PSampR System Access (Please Read) (posted 01292015)(Updated 5262015)is changingThe system which controls your PSampR user ID (currently IACS)The new system is referred to as EIDMThis will result in a different way to create new accounts or change passwords to existing accountsIf you already have an account in EIDM you may have to use that account for accessing PSampR after the transitionWhen is the change effectiveJune 13 2015What is staying the sameThe internet address for accessing PSampR remains the sameThe PSampR systemfunctionality is NOT changing 62

Medicare Advantage Payorsbull Medicare Advantage payors are pullingdenying payments on admissions if the patient was readmitted within 30 days after discharge The

client believes that the payors systematically denying payments for all readmissions within 30 days They believe this practice denies them due process to address whether the readmissions were justified and not due to a premature discharge of patient The payors seem to want to act like a QIO without having the same accountabilities of the QIO related to determinations of non-payment

bull Heres the QIO process under section 4240 of the QIO Manualbull 4240 - Readmission Review - (Rev 2 07-11-03)bull Readmission review involves admissions to an acute general short-term hospital occurring less than 31 calendar days from the date of

discharge from the same or another acute general short-term hospital (see sect1154(a)(13) and 42 CFR 47671(a)(8)(ii)) Neither the day of discharge nor the day of admission is counted when determining whether a readmission has occurred

bull A Medical Review Proceduresbull Obtain the appropriate medical records for the initial admission and readmission Perform case review on both stays Analyze the cases

specifically to determine whether the patient was prematurely discharged from the first confinement thus causing readmission Perform an analysis of the stay at the first hospital to determine the cause(s) and extent of any problem(s) (eg incomplete or substandard treatment) Consider the information available to the attending physician who discharged the patient from the first confinement Do not base a determination of a premature discharge on information that the physician or provider could not have known or events that could not have been anticipated at the time of discharge

bull Review both the initial admission and the readmission at the same time unless one of them has previously been reviewed In these cases use at a minimum the PRAF case summary of the other admission in addition to the medical record of the case under review

bull C Denialsbull Deny readmissions under the following circumstancesbull If the readmission was medically unnecessarybull If the readmission resulted from a premature discharge from the same hospital orbull If the readmission was a result of circumvention of PPS by the same hospital (see sect4255)bull With the QIO process there is an appeal within the QIO here the hospital is getting no opportunity to challenge the denials

63

Medicare Provider Enrollment Feebull Provider Enrollment Application Fee Amount for CY 2016bull On December 3 CMS issued a notice Provider Enrollment Application

Fee Amount for CY 2016 [CMSndash6066ndashN] Effective January 1 2016 the CY 2016 application fee is $554 for institutional providers that are

bull Initially enrolling in the Medicare or Medicaid program or the Childrens Health Insurance Program (CHIP)

bull Revalidating their Medicare Medicaid or CHIP enrollmentbull Adding a new Medicare practice locationbull This fee is required with any enrollment application submitted from

January 1 through December 31 2016

64

Medicare MAC-Higlas

bull Effective 142016 CMS has implemented a change to begin netting (offsetting) provider money across workloads within a single organization What this means is that any related providers conducting business in two different workloads (example New York and Maine) will have their money applied to any account receivables (AR) with a remaining balance owed to Medicare within both workloads For example Provider ABC is located in New York and is scheduled to receive a payment of $1000 on todays remittance advice Provider XYZ is related to provider ABC but is located in Maine and has ARs with a balance owed of $200 Provider ABCs $1000 payment will have the $200 applied against provider XYZs ARs resulting in a net payment of $800 This will be reflected on the remittance advice by the same PLB code as seen today for offsets for the $200

65

Two Midnight RuleChange January 1 2016 httpswwwcmsgovMedicareMedicare-Fee-for-Service-PaymentHospitalOutpatientPPSHospital-Outpatient-Regulations-and-Notices-ItemsCMS-1633-FChtml

66

Two Midnight Rulebull However effective January 1 2016 CMS will allow exceptions to the

Two-Midnight Benchmark to be determined on a case-by-case basis by the physician responsible for the care of the beneficiary subject to medical review Said differently Part A payment may be appropriate in some circumstances even though there is no expectation by the physician (or qualified ordering practitioner) of a two-midnight stay and one of the two pre-existing categorical exceptions (CMS ldquoinpatient onlyrdquo list and newly initiated mechanical ventilation) does not apply CMS has indicated that this change to the Two Midnight Rule is in response to stakeholder concern and CMSrsquos continued efforts to develop the most appropriate standard for determining Medicare Part A payment

67

Two Midnight Rulebull A new 42 CFR sect4123(a) provides that a patient is considered an

inpatient of a hospitalhellipif formally admitted as an inpatient pursuant to an order for inpatient admission by a physician or other qualified practitionerhellip The physician orders inpatient status when he or she expects the patient to require a stay that crosses at least 2 midnights[10] Stays expected to be shorter than at least two midnights are generally inappropriate for inpatient admission and inpatient payment under Medicare Part A unless the surgical procedure is specified by Medicare as inpatient only under sect41922(n)[11] The physicians expectationhellipshould be based on such complex medical factors as patient history and comorbidities the severity of signs and symptoms current medical needs and the risk of an adverse event[12] The physician order is part of physician certification of the medical necessity of hospital inpatient serviceshellip[13]

68

InPatient Vs Observation Conthellip

bull Physician certification which begins with an order for inpatient admission requires the physician to certify the reasons for the hospitalization the estimated time the patient will remain in the hospital and plans for post-hospital care if appropriate[14] The certification must be completed signed and documented in the medical record prior to discharge[15]

bull A physicians admission order has no presumptive weight and both the admission order and the physician certification will be evaluated in the context of the evidence in the medical record[16] CMS intends to provide additional information about what evidence in the medical record means in future instructions and manual revisions[17]

69

Two Midnight Rulebull Although the new case-by-case exception appears to be inherently

subjective to a certain extent CMS states that the following factors (among others) would be relevant to determining whether a patient requires inpatient admission under the expanded policy

bull The severity of the signs and symptoms exhibited by the patient bull The medical predictability of something adverse happening to the patient

and bull The need for diagnostic studies that appropriately are outpatient services

(that is their performance does not ordinarily require the patient to remain at the hospital for 24 hours or more)

bull CMS also notes that an inpatient admission (and Part A payment) should be ldquorare and unusualrdquo for minor surgical procedures or other treatment that is expected to keep the patient in the hospital ldquofor only a few hoursrdquo or for a period of time that ldquodoes not span at least overnightrdquo (thus a subset of stays not meeting the Two Midnight Benchmark) CMS indicates that such cases will be prioritized for medical review

70

Health Data Insights amp Medicare Plus Blue

RAC (Retrospective Audits)

71

HDI Health Data amp Med Plus Blue

bull httpwwwhealthdatainsightscombull Blue Cross Medicare Advantage Auditsbull Facilities seeing 10 to 15 requests for Medical Recordsbull In January amp Feburarybull Selected Health Data Insights because they were a premier Audit

Vendor for CMS Recovery Audit Contractor (RAC) demonstration Project They are a audit vendor for Humana

bull Providers not sending Medical Record will get technical denial and lose payments

72

Health Data InSight

bull In 2010 they began the Hospital Reviewbull Medicare Advantage encounter datandashCMS oversight of data integrity OIG

2016bull We will review CMSs oversight of MA encounter data validation and assess

the extent to which CMSrsquos Integrated Data Repository contains timely valid and complete MA encounter data In 2012 CMS began collecting from MA organizations a more comprehensive set of encounter data reflecting the items and services provided to MA plan enrollees Prior CMS and OIG audits have indicated vulnerabilities in the accuracy of data reporting by MA organizations Realizing the potential benefits of the MA encounter data for payment and program integrity oversight is contingent upon the datarsquos completeness validity and timeliness (OEI 03-15-00060 expected issue date FY 2017)

73

Pepper Reports

bull httpswwwpepperresourcesorg

bull Program for Evaluating Payment Patterns Electronic Report ( PEPPER)

bull Annually on or about April 18 2016 will be released

bull Pepper Portal httpssecurefiletmforg

74

CGI Technologies and Solutions Inc httpracbcgicomContactInfoaspxst=1

bull Indiana bull Michiganbull Minnesotabull Illinoisbull Kentuckybull Ohiobull Wisconsin CGI Technologies and Solutions Incbull For general and administrative questions regarding client service outreach

quality assurance or project-specific issues contactbull 1877316RACB (7222)bull Email racbcgicom Tamara Tate Tamaratatecmshhsgovbull 4107861288

75

CGI Federal RAC

bull CGI Federal RAC Region Bbull Email racbcgicombull Phone 1-877-316-RACB (7222)bull Mailing Addressbull Send medical records as followsbull Medical records for Indiana Illinois Kentucky Michigan Ohio Wisconsin

Minnesota DME and Home Health CGI Federal Inc Attn RACB Imaging Dept 1001 Lakeside Ave Suite 800 Cleveland OH 44114

bull If submitting paper records please send medical records as follows For Therapy Reviews CGI Federal Inc Attn RACB Imaging 1001 Lakeside Avenue Suite 800 Cleveland OH 44114

76

How to survive RAC Audit

bull National health expenditures totaled $1679 Billion in 2003 bull National health expenditures were 153 of GROSS Domestic Product

(GDP) in 2003 bull Health care cost increasing at +9 per year bull Doomsday predictions of Medicare running out bull Congressional Action

77

RAC Audits

bull Medicare Modernization Act (MMA) of 2003Mandated a three year audit demonstration project 2005-2008

bull Appoint audit contractors to review Medicare billings for proper coding DRG assignment and medical necessity

bull Audits will apply to all health care providers (hospitals physicians homecare dme etc)

bull Audit contractors to be paid on a contingency basis a percentage of overpayments recovered

78

How Did we get here

bull Overpayments collected due to errors in Medically Unnecessary Services ndash 40

bull Incorrectly Coded ndash 35

bull Other ndash 17

bull NoInsufficient Documentation ndash 8

79

Where are we now

bull All RACrsquos completed required provider outreachAccess to Medicare billing data base given to all RAC RAC review methodology

bull Automated Review-Black amp White Issues (current) bull DRG Validation-complex review (current) bull Complex Review for coding errors (current) bull DME Medical Necessity Reviews ndashcomplex review (calendar year

2010) bull Medical Necessity Reviews-complex review (calendar year 2010)

80

RAC Reviews

bull Responsibilities of the Team Leader bull Must learn each insurance provider participating in a RAC or RAC type

program bull What are their operating rulesbull What is their appeal process Time limits

May be different process for each insurance provider bull Develop a response team

Identify who does what when why and alternate bull individual

Build and develop a manual process Review of computerized system

81

Priority Health SCIO Health Analytics

bull httpswwwsciohealthanalyticscomcore-capabilitiespayment-integrityfacility-auditsskilled-nursing-facility-audits

bull Claims for Medicare members treated at Skilled Nursing Facilities are reimbursed based on the patientsrsquo RUG (Resource Utilization Group) score which is determined using the Minimum Data Set (MDS) Using SCIOs robust analytics claims andor providers that merit review are selected for audit SCIOs auditors conduct a detailed review of the complete medical record and associated MDS to determine if the billed RUG score is valid In the event the review determines that an incorrect RUG score was billed SCIOreg provides the valid score reports the reason the change was necessary and calculates the resulting overpayment

82

+ Cheer

Onward and Upward she shall prevail We are here to care for the residents and provide a wonderful

service

13 83

84

References

bull Priority Healthbull Blue Crossbull Medicaidbull Medicare

85

  • Medicare Mange Care amp Medicaid Changes in the New World We Live In
  • Medicaid
  • NEW Medicaid Change MIlogin
  • Blueprint for Health Innovation MI
  • Provider Enrollment Electronic Signature Form Submission Process MSA 15-54
  • Provider Enrollment Electronic Signature Form Submission Process
  • Provider Enrollment Domain Administrator
  • Medicaid Coinsurance Medicare Advantage
  • Slide Number 9
  • Lawsuit DHS Changes on Caregivers
  • TPL Medicaid Change
  • CHAMPS Member Screen
  • LOC dropping off Not Due to MI Health
  • Issues
  • Secure Email Information
  • Medicaid amp Hospice
  • Medicaid
  • Medicaid Medicare Buy In
  • Manage Medicaid
  • Healthy Michigan Residents
  • Healthy Michigan Medicaid Days
  • McLaren Health Plan
  • Manage Medicaid Plans January 1
  • Slide Number 24
  • MI Health Link
  • MI Health Link 2565
  • What are the Names
  • MI Health Dual Eligible
  • MI Health LOC
  • LOC Medicaid
  • Medicaid Redetermination and MHL Enrollment
  • MI Health Link Portals
  • MI Health Authorizations
  • MI Health Issues
  • LOC 02 dropping MI Health Issues
  • PPA Offset
  • LOCD
  • MI Health Issues-New
  • ACO
  • Families Receiving Letters for ACO
  • ACO What is It
  • Payroll Based Journal
  • Slide Number 43
  • If you submit data manually should you also submit it through the XML
  • Staffing Submission Frequently Asked Questions
  • CMS defines
  • Slide Number 47
  • PBJ Medical Director Role
  • PBJ Medical Director Role
  • Dietician
  • Pharmacy Consultant
  • What are the names for the Medicare Number
  • QTSO
  • Medicare Update
  • CMS Final Rule On Returning Credits
  • Over Payment Rule
  • Questions to MAC
  • Questions to MAC
  • Final Rule on Returning Credits
  • Final Rule on Returning Credits
  • Final Rule on Returning Credits
  • Slide Number 62
  • Medicare Advantage Payors
  • Medicare Provider Enrollment Fee
  • Medicare MAC-Higlas
  • Two Midnight Rule
  • Two Midnight Rule
  • Two Midnight Rule
  • InPatient Vs Observation Conthellip
  • Two Midnight Rule
  • Health Data Insights amp Medicare Plus Blue
  • HDI Health Data amp Med Plus Blue
  • Health Data InSight
  • Pepper Reports
  • CGI Technologies and Solutions Inc httpracbcgicomContactInfoaspxst=1
  • CGI Federal RAC
  • How to survive RAC Audit
  • RAC Audits
  • How Did we get here
  • Where are we now
  • RAC Reviews
  • Priority Health SCIO Health Analytics
  • Cheer
  • References
Page 52: Medicare, Mange Care & Medicaid Changes in the New World we live in

What are the names for the Medicare Numberbull OSCAR -Online Survey Certification and Reporting

bull PTAN-PTAN number is assigned by Medicare to authenticate the provider when using the local Medicare Administrative Contractorrsquos (MAC) self-help tools like the IVR internet portal on-line application status etc Provider Transactions Access Number

bull CCN- CMS Certification Number

bull Medicare Number- example 23-

bull All of the above mean the same thing

52

QTSO

bull Once you are logged in the QTSO site bull You will have a state login to the site to access the various site specific

to your facilitybull Installing you will need administrator rights to your network

53

Medicare UpdateWhat are we seeing

54

CMS Final Rule On Returning Credits

httpswwwfederalregistergovarticles201602122016-02789medicare-program-reporting-and-returning-of-overpayments

55

Over Payment Rule

bull Medicare payments for non covered services

bull Medicare payments in excess of the allowable amount for an identified covered service

bull Errors and non reimbursable expenditures in cost reportsbull Duplicate payment

bull Receipt of Medicare payments when another payor had the primary responsibility for payment

56

Questions to MAC

bull Does the Medicare credit balance report change with this overpayment rule

bull No Medicare Credit Balances are still required at the end of each quarter

bull Will that still be the communication to let CMS or the MAC know that we have received an overpayment

bull Submission of Medicare Credit Balance is one form of communicating overpayments to CMS Other methods include submitting a voluntary refund with required claim information or the submission of a standard overpayment form

57

Questions to MAC

bull Will the MAC still deduct from a future RAbull If the recovery of the overpayment includes adjusting a claim then

the overpayment would be netted against future claims payments and reflected on the RA

bull Or will that process change with this new rulebull Process will remain the samebull Will NGS send communication out on thisbull Yes NGS will communicate this once the final rule is communicated

to the MACs by CMS However this could change depending on final CMS instructions

58

Final Rule on Returning Credits

bull Providers will want to immediately update their current policies governing overpayments in order to comply with this new rule which will take effect on March 14 2016

bull Providers and suppliers are required to use reasonable diligence to investigate credible information regarding overpayments through both proactive compliance efforts and reactive investigations

bull If an overpayment is identified then it must be repaid within 60 days An overpayment is identified when a person has or should have through the exercise of reasonable diligence determined that the person received an overpayment and quantified the amount

bull Providers and suppliers have a maximum of 8 months to report and return overpayments ndash up to 6 months to investigate and quantify the overpayment (ie to identify it) and up to 60 days to report and return the overpayment

59

Final Rule on Returning Credits

bull Providers and suppliers are required to report and return all overpayments within a 6-year lookback period

bull The cause and amount of the overpayment is irrelevant for the determination eg it was due to a mistake it was someone elsersquos fault it is a minor amount An overpayment is an overpayment and must be returned

bull Providers and suppliers must make their own determination to which entity to report and return the overpayment ie to the Medicare contractor or using the OIG Self Disclosure Protocol or the CMS Self Referral Disclosure Protocol

60

Final Rule on Returning Credits

bull Providers and suppliers may use the claims adjustment credit balance self-reported refund process or another appropriate process to report and return overpayments At this time there is no standard refund form to use

bull Failure to report and return an overpayment could subject the provider or supplier to False Claims Act liability Civil Monetary Penalties Law liability and exclusion from federal health care programs

61

P S amp R-Accountants will be asking for this information

The location you login into has changed it is now on EIDM EIDM is the acronym for CMS Enterprise Identity Management system which includes Identity Verification Access Management Authorization Assistance Workflow Tools and Identity Lifecycle Management functions

httpswwwcmsgovResearch-Statistics-Data-and-SystemsCMS-Information-TechnologyIACSCMS-Applications-Loginhtml

Go down the page and click on the PSampRSTARThis will take you to the login pagewill look the same as the old P S amp R didChanges Affecting PSampR System Access (Please Read) (posted 01292015)(Updated 5262015)is changingThe system which controls your PSampR user ID (currently IACS)The new system is referred to as EIDMThis will result in a different way to create new accounts or change passwords to existing accountsIf you already have an account in EIDM you may have to use that account for accessing PSampR after the transitionWhen is the change effectiveJune 13 2015What is staying the sameThe internet address for accessing PSampR remains the sameThe PSampR systemfunctionality is NOT changing 62

Medicare Advantage Payorsbull Medicare Advantage payors are pullingdenying payments on admissions if the patient was readmitted within 30 days after discharge The

client believes that the payors systematically denying payments for all readmissions within 30 days They believe this practice denies them due process to address whether the readmissions were justified and not due to a premature discharge of patient The payors seem to want to act like a QIO without having the same accountabilities of the QIO related to determinations of non-payment

bull Heres the QIO process under section 4240 of the QIO Manualbull 4240 - Readmission Review - (Rev 2 07-11-03)bull Readmission review involves admissions to an acute general short-term hospital occurring less than 31 calendar days from the date of

discharge from the same or another acute general short-term hospital (see sect1154(a)(13) and 42 CFR 47671(a)(8)(ii)) Neither the day of discharge nor the day of admission is counted when determining whether a readmission has occurred

bull A Medical Review Proceduresbull Obtain the appropriate medical records for the initial admission and readmission Perform case review on both stays Analyze the cases

specifically to determine whether the patient was prematurely discharged from the first confinement thus causing readmission Perform an analysis of the stay at the first hospital to determine the cause(s) and extent of any problem(s) (eg incomplete or substandard treatment) Consider the information available to the attending physician who discharged the patient from the first confinement Do not base a determination of a premature discharge on information that the physician or provider could not have known or events that could not have been anticipated at the time of discharge

bull Review both the initial admission and the readmission at the same time unless one of them has previously been reviewed In these cases use at a minimum the PRAF case summary of the other admission in addition to the medical record of the case under review

bull C Denialsbull Deny readmissions under the following circumstancesbull If the readmission was medically unnecessarybull If the readmission resulted from a premature discharge from the same hospital orbull If the readmission was a result of circumvention of PPS by the same hospital (see sect4255)bull With the QIO process there is an appeal within the QIO here the hospital is getting no opportunity to challenge the denials

63

Medicare Provider Enrollment Feebull Provider Enrollment Application Fee Amount for CY 2016bull On December 3 CMS issued a notice Provider Enrollment Application

Fee Amount for CY 2016 [CMSndash6066ndashN] Effective January 1 2016 the CY 2016 application fee is $554 for institutional providers that are

bull Initially enrolling in the Medicare or Medicaid program or the Childrens Health Insurance Program (CHIP)

bull Revalidating their Medicare Medicaid or CHIP enrollmentbull Adding a new Medicare practice locationbull This fee is required with any enrollment application submitted from

January 1 through December 31 2016

64

Medicare MAC-Higlas

bull Effective 142016 CMS has implemented a change to begin netting (offsetting) provider money across workloads within a single organization What this means is that any related providers conducting business in two different workloads (example New York and Maine) will have their money applied to any account receivables (AR) with a remaining balance owed to Medicare within both workloads For example Provider ABC is located in New York and is scheduled to receive a payment of $1000 on todays remittance advice Provider XYZ is related to provider ABC but is located in Maine and has ARs with a balance owed of $200 Provider ABCs $1000 payment will have the $200 applied against provider XYZs ARs resulting in a net payment of $800 This will be reflected on the remittance advice by the same PLB code as seen today for offsets for the $200

65

Two Midnight RuleChange January 1 2016 httpswwwcmsgovMedicareMedicare-Fee-for-Service-PaymentHospitalOutpatientPPSHospital-Outpatient-Regulations-and-Notices-ItemsCMS-1633-FChtml

66

Two Midnight Rulebull However effective January 1 2016 CMS will allow exceptions to the

Two-Midnight Benchmark to be determined on a case-by-case basis by the physician responsible for the care of the beneficiary subject to medical review Said differently Part A payment may be appropriate in some circumstances even though there is no expectation by the physician (or qualified ordering practitioner) of a two-midnight stay and one of the two pre-existing categorical exceptions (CMS ldquoinpatient onlyrdquo list and newly initiated mechanical ventilation) does not apply CMS has indicated that this change to the Two Midnight Rule is in response to stakeholder concern and CMSrsquos continued efforts to develop the most appropriate standard for determining Medicare Part A payment

67

Two Midnight Rulebull A new 42 CFR sect4123(a) provides that a patient is considered an

inpatient of a hospitalhellipif formally admitted as an inpatient pursuant to an order for inpatient admission by a physician or other qualified practitionerhellip The physician orders inpatient status when he or she expects the patient to require a stay that crosses at least 2 midnights[10] Stays expected to be shorter than at least two midnights are generally inappropriate for inpatient admission and inpatient payment under Medicare Part A unless the surgical procedure is specified by Medicare as inpatient only under sect41922(n)[11] The physicians expectationhellipshould be based on such complex medical factors as patient history and comorbidities the severity of signs and symptoms current medical needs and the risk of an adverse event[12] The physician order is part of physician certification of the medical necessity of hospital inpatient serviceshellip[13]

68

InPatient Vs Observation Conthellip

bull Physician certification which begins with an order for inpatient admission requires the physician to certify the reasons for the hospitalization the estimated time the patient will remain in the hospital and plans for post-hospital care if appropriate[14] The certification must be completed signed and documented in the medical record prior to discharge[15]

bull A physicians admission order has no presumptive weight and both the admission order and the physician certification will be evaluated in the context of the evidence in the medical record[16] CMS intends to provide additional information about what evidence in the medical record means in future instructions and manual revisions[17]

69

Two Midnight Rulebull Although the new case-by-case exception appears to be inherently

subjective to a certain extent CMS states that the following factors (among others) would be relevant to determining whether a patient requires inpatient admission under the expanded policy

bull The severity of the signs and symptoms exhibited by the patient bull The medical predictability of something adverse happening to the patient

and bull The need for diagnostic studies that appropriately are outpatient services

(that is their performance does not ordinarily require the patient to remain at the hospital for 24 hours or more)

bull CMS also notes that an inpatient admission (and Part A payment) should be ldquorare and unusualrdquo for minor surgical procedures or other treatment that is expected to keep the patient in the hospital ldquofor only a few hoursrdquo or for a period of time that ldquodoes not span at least overnightrdquo (thus a subset of stays not meeting the Two Midnight Benchmark) CMS indicates that such cases will be prioritized for medical review

70

Health Data Insights amp Medicare Plus Blue

RAC (Retrospective Audits)

71

HDI Health Data amp Med Plus Blue

bull httpwwwhealthdatainsightscombull Blue Cross Medicare Advantage Auditsbull Facilities seeing 10 to 15 requests for Medical Recordsbull In January amp Feburarybull Selected Health Data Insights because they were a premier Audit

Vendor for CMS Recovery Audit Contractor (RAC) demonstration Project They are a audit vendor for Humana

bull Providers not sending Medical Record will get technical denial and lose payments

72

Health Data InSight

bull In 2010 they began the Hospital Reviewbull Medicare Advantage encounter datandashCMS oversight of data integrity OIG

2016bull We will review CMSs oversight of MA encounter data validation and assess

the extent to which CMSrsquos Integrated Data Repository contains timely valid and complete MA encounter data In 2012 CMS began collecting from MA organizations a more comprehensive set of encounter data reflecting the items and services provided to MA plan enrollees Prior CMS and OIG audits have indicated vulnerabilities in the accuracy of data reporting by MA organizations Realizing the potential benefits of the MA encounter data for payment and program integrity oversight is contingent upon the datarsquos completeness validity and timeliness (OEI 03-15-00060 expected issue date FY 2017)

73

Pepper Reports

bull httpswwwpepperresourcesorg

bull Program for Evaluating Payment Patterns Electronic Report ( PEPPER)

bull Annually on or about April 18 2016 will be released

bull Pepper Portal httpssecurefiletmforg

74

CGI Technologies and Solutions Inc httpracbcgicomContactInfoaspxst=1

bull Indiana bull Michiganbull Minnesotabull Illinoisbull Kentuckybull Ohiobull Wisconsin CGI Technologies and Solutions Incbull For general and administrative questions regarding client service outreach

quality assurance or project-specific issues contactbull 1877316RACB (7222)bull Email racbcgicom Tamara Tate Tamaratatecmshhsgovbull 4107861288

75

CGI Federal RAC

bull CGI Federal RAC Region Bbull Email racbcgicombull Phone 1-877-316-RACB (7222)bull Mailing Addressbull Send medical records as followsbull Medical records for Indiana Illinois Kentucky Michigan Ohio Wisconsin

Minnesota DME and Home Health CGI Federal Inc Attn RACB Imaging Dept 1001 Lakeside Ave Suite 800 Cleveland OH 44114

bull If submitting paper records please send medical records as follows For Therapy Reviews CGI Federal Inc Attn RACB Imaging 1001 Lakeside Avenue Suite 800 Cleveland OH 44114

76

How to survive RAC Audit

bull National health expenditures totaled $1679 Billion in 2003 bull National health expenditures were 153 of GROSS Domestic Product

(GDP) in 2003 bull Health care cost increasing at +9 per year bull Doomsday predictions of Medicare running out bull Congressional Action

77

RAC Audits

bull Medicare Modernization Act (MMA) of 2003Mandated a three year audit demonstration project 2005-2008

bull Appoint audit contractors to review Medicare billings for proper coding DRG assignment and medical necessity

bull Audits will apply to all health care providers (hospitals physicians homecare dme etc)

bull Audit contractors to be paid on a contingency basis a percentage of overpayments recovered

78

How Did we get here

bull Overpayments collected due to errors in Medically Unnecessary Services ndash 40

bull Incorrectly Coded ndash 35

bull Other ndash 17

bull NoInsufficient Documentation ndash 8

79

Where are we now

bull All RACrsquos completed required provider outreachAccess to Medicare billing data base given to all RAC RAC review methodology

bull Automated Review-Black amp White Issues (current) bull DRG Validation-complex review (current) bull Complex Review for coding errors (current) bull DME Medical Necessity Reviews ndashcomplex review (calendar year

2010) bull Medical Necessity Reviews-complex review (calendar year 2010)

80

RAC Reviews

bull Responsibilities of the Team Leader bull Must learn each insurance provider participating in a RAC or RAC type

program bull What are their operating rulesbull What is their appeal process Time limits

May be different process for each insurance provider bull Develop a response team

Identify who does what when why and alternate bull individual

Build and develop a manual process Review of computerized system

81

Priority Health SCIO Health Analytics

bull httpswwwsciohealthanalyticscomcore-capabilitiespayment-integrityfacility-auditsskilled-nursing-facility-audits

bull Claims for Medicare members treated at Skilled Nursing Facilities are reimbursed based on the patientsrsquo RUG (Resource Utilization Group) score which is determined using the Minimum Data Set (MDS) Using SCIOs robust analytics claims andor providers that merit review are selected for audit SCIOs auditors conduct a detailed review of the complete medical record and associated MDS to determine if the billed RUG score is valid In the event the review determines that an incorrect RUG score was billed SCIOreg provides the valid score reports the reason the change was necessary and calculates the resulting overpayment

82

+ Cheer

Onward and Upward she shall prevail We are here to care for the residents and provide a wonderful

service

13 83

84

References

bull Priority Healthbull Blue Crossbull Medicaidbull Medicare

85

  • Medicare Mange Care amp Medicaid Changes in the New World We Live In
  • Medicaid
  • NEW Medicaid Change MIlogin
  • Blueprint for Health Innovation MI
  • Provider Enrollment Electronic Signature Form Submission Process MSA 15-54
  • Provider Enrollment Electronic Signature Form Submission Process
  • Provider Enrollment Domain Administrator
  • Medicaid Coinsurance Medicare Advantage
  • Slide Number 9
  • Lawsuit DHS Changes on Caregivers
  • TPL Medicaid Change
  • CHAMPS Member Screen
  • LOC dropping off Not Due to MI Health
  • Issues
  • Secure Email Information
  • Medicaid amp Hospice
  • Medicaid
  • Medicaid Medicare Buy In
  • Manage Medicaid
  • Healthy Michigan Residents
  • Healthy Michigan Medicaid Days
  • McLaren Health Plan
  • Manage Medicaid Plans January 1
  • Slide Number 24
  • MI Health Link
  • MI Health Link 2565
  • What are the Names
  • MI Health Dual Eligible
  • MI Health LOC
  • LOC Medicaid
  • Medicaid Redetermination and MHL Enrollment
  • MI Health Link Portals
  • MI Health Authorizations
  • MI Health Issues
  • LOC 02 dropping MI Health Issues
  • PPA Offset
  • LOCD
  • MI Health Issues-New
  • ACO
  • Families Receiving Letters for ACO
  • ACO What is It
  • Payroll Based Journal
  • Slide Number 43
  • If you submit data manually should you also submit it through the XML
  • Staffing Submission Frequently Asked Questions
  • CMS defines
  • Slide Number 47
  • PBJ Medical Director Role
  • PBJ Medical Director Role
  • Dietician
  • Pharmacy Consultant
  • What are the names for the Medicare Number
  • QTSO
  • Medicare Update
  • CMS Final Rule On Returning Credits
  • Over Payment Rule
  • Questions to MAC
  • Questions to MAC
  • Final Rule on Returning Credits
  • Final Rule on Returning Credits
  • Final Rule on Returning Credits
  • Slide Number 62
  • Medicare Advantage Payors
  • Medicare Provider Enrollment Fee
  • Medicare MAC-Higlas
  • Two Midnight Rule
  • Two Midnight Rule
  • Two Midnight Rule
  • InPatient Vs Observation Conthellip
  • Two Midnight Rule
  • Health Data Insights amp Medicare Plus Blue
  • HDI Health Data amp Med Plus Blue
  • Health Data InSight
  • Pepper Reports
  • CGI Technologies and Solutions Inc httpracbcgicomContactInfoaspxst=1
  • CGI Federal RAC
  • How to survive RAC Audit
  • RAC Audits
  • How Did we get here
  • Where are we now
  • RAC Reviews
  • Priority Health SCIO Health Analytics
  • Cheer
  • References
Page 53: Medicare, Mange Care & Medicaid Changes in the New World we live in
Page 54: Medicare, Mange Care & Medicaid Changes in the New World we live in
Page 55: Medicare, Mange Care & Medicaid Changes in the New World we live in
Page 56: Medicare, Mange Care & Medicaid Changes in the New World we live in
Page 57: Medicare, Mange Care & Medicaid Changes in the New World we live in
Page 58: Medicare, Mange Care & Medicaid Changes in the New World we live in
Page 59: Medicare, Mange Care & Medicaid Changes in the New World we live in
Page 60: Medicare, Mange Care & Medicaid Changes in the New World we live in
Page 61: Medicare, Mange Care & Medicaid Changes in the New World we live in
Page 62: Medicare, Mange Care & Medicaid Changes in the New World we live in
Page 63: Medicare, Mange Care & Medicaid Changes in the New World we live in
Page 64: Medicare, Mange Care & Medicaid Changes in the New World we live in
Page 65: Medicare, Mange Care & Medicaid Changes in the New World we live in
Page 66: Medicare, Mange Care & Medicaid Changes in the New World we live in
Page 67: Medicare, Mange Care & Medicaid Changes in the New World we live in
Page 68: Medicare, Mange Care & Medicaid Changes in the New World we live in
Page 69: Medicare, Mange Care & Medicaid Changes in the New World we live in
Page 70: Medicare, Mange Care & Medicaid Changes in the New World we live in
Page 71: Medicare, Mange Care & Medicaid Changes in the New World we live in
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Page 73: Medicare, Mange Care & Medicaid Changes in the New World we live in
Page 74: Medicare, Mange Care & Medicaid Changes in the New World we live in
Page 75: Medicare, Mange Care & Medicaid Changes in the New World we live in
Page 76: Medicare, Mange Care & Medicaid Changes in the New World we live in
Page 77: Medicare, Mange Care & Medicaid Changes in the New World we live in
Page 78: Medicare, Mange Care & Medicaid Changes in the New World we live in
Page 79: Medicare, Mange Care & Medicaid Changes in the New World we live in
Page 80: Medicare, Mange Care & Medicaid Changes in the New World we live in
Page 81: Medicare, Mange Care & Medicaid Changes in the New World we live in
Page 82: Medicare, Mange Care & Medicaid Changes in the New World we live in
Page 83: Medicare, Mange Care & Medicaid Changes in the New World we live in
Page 84: Medicare, Mange Care & Medicaid Changes in the New World we live in
Page 85: Medicare, Mange Care & Medicaid Changes in the New World we live in