ACO discussion with HCCA at the 17th Annual Compliance Conference

Listening to a panel discussion on ACO's
with Shawn DeGroot, Frank Sheeder, Troy Barsky, and Mary Fischer

Interesting Points

• They are run by providers no VC money involved
• Their board has to be made up of 75% of membership
• ACO's are involved in shared savings, shared risks models
• They are judged on performance benchmarks as a measure of success
• ACO's don't totally follow the OIG 7 elements for compliance but have their own structure and a mandatory compliance position that reports to the board.
•  Privacy concerns along with standard federal guidelines are all still present
• Anti-trust concerns with ACO's DOJ and FTC have published papers on this
• ACO's and physicians share money which raises concerns but waivers are available
• Need to focus on quality data
• Potential for false claims based on bad data(IT Data warehouse be aware!!)
• Need to think about Stark and anti-kickback more about co-mingling of money
• Compliance concern needs to be at the table early and often because of the multiple of potential issues.
• ACO  has to service at least 5000 members 
• Litigation's will be a concern with ACO's if they run a foul of regulations
• Serving people vs. financials concerns are a tightrope
• Compliance is a critical part of making an ACO a success
  

Day 3 HCCA National Conference - Personal Reflection

All I can say it is such an uplifting experience to spend time with people in the same field, who go through the same aggravations and give you inspiration to be passionate about what you do.

Day 2 Social Media and Compliance

Social Media and Compliance

Let's just say this was a popular topic for behavioral health organizations

Excellent discussion on issues people have faced and efforts done to avert issues.

Key points

• Social Media is the wild west for compliance
• Organizations struggle to monitor
• Policies are constantly be changed
• National Labor Relations board needs to be checked for social media policies.  It's rulings have directly affected policies and proceedures.
• Social monitoring is now a clear and present issue for compliance
• Training is a big part of averting issues.

Just a great discussion.

Day 2 HCCA National Conference Dan Levinson Speaks

Key Note Speaker
Dan Levinson Inspector General for OIG HHS
Great Speaker Key Points

• Compliance is charting a new course moving into the quality and efficiency fields
• Self Reporting is more important
• EHR's are the road to interoperability 

A lot of networking going on. I'm done to 5 business cards..

Sitting in the program on how to build a compliance program

8 core elements..

More to come

First Session Compliance and Health Care Reform

First Session Compliance and Health Care Reform

Great Session!!!

Informative discussion on how the environment is changing.  Compliance needs to take a greater roll in reviewing contracts and BAA's.  Need compliance review of revenue for tax exempt organizations.  Need better control over medical records and their availability.  People need to put better thought into compliance when thinking mergers and acquisitions.  Never want to get into a situation when the acquisition may not be compliant or may be exclusionary with HHS.  Do your due Diligence!!!!

National Health Care Compliance Convention this week in National Harbor Maryland

National Health Care Compliance Convention this week in National Harbor Maryland

I'll be blogging while I'm there!

Fundus Photgraphy Vs, Rentinal Image and other musings

Sorry I've been absent for a while.. things got busy for a bit and I'm wearing some IT hats right now

I ran into something today that made me laugh.  This is total HEDIS nerdy dorkyness but I thought you might enjoy this.   We had one of our health coaches ask about this procedure for the DREE measure(Dilated Retinal Eye exam) and should we allow it to be captured for HEDIS supplemental data in our disease management registry system.  She was asking about a “Ultra wide field retinal image” being used as a DREE.  Now this didn't ring any bells and a quick scan of the HEDIS CPT codes didn't turn anything up.  The clinical staff thought we shouldn't record it because it most likely isn't re-reimbursed by medicare.  Just on a hunch I did a Google search on “Ultra wide field retinal image” and "medicare". Sure enough I found this

http://www.optos.com/Global/documents/P200C_Brochure.pdf

A company called optos sell this optomap utra-widefield retinal imaging product and in their pdf they explain that this prodcut can be billed under CPT code 92250 for reimbursement with medicare.  A quick search in the HEDIS specs for DREE shows CPT code 92250 listed for DREE.

Now what is the description of CPT code?


FUNDUS PHOTOGRAPHY WITH INTERPRETATION AND REPORT.

Gotta love intuitive descriptions ...


I can now say I had some HEDIS FUNDUS today at work.

Enjoy,

Andy