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The OIG determination that E&M coding, especially the determination of new patient vs. established patient criteria will become an increasingly important area for physician practices, especially inside institutions that are switching EMR and billing records. Many of these conversions have led to erroneous classification. 

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The number of uninsured is expected to decline by nearly half from 45 million in 2012 to 23million by 2023 as a result of the coverage expansions associated with the Affordable Care Act, according to a report from the Centers for Medicare & Medicaid Services (CMS) Office of the Actuary. The report is being published today in Health Affairs.  

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The Centers for Medicare & Medicaid Services (CMS) today announced changes to the Medicare home health prospective payment system (HH PPS) for calendar year (CY) 2015 that will foster greater efficiency, flexibility, payment accuracy, and improved quality. Approximately 3.5 million beneficiaries received home health services from nearly 12,000 home health agencies, costing Medicare approximately $18 billion in 2013.  

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The goal of the Centers for Medicare & Medicaid Services (CMS) Administrative Simplification initiatives is to standardize certain transactions in order to lower costs, increase efficiency and accuracy, and reduce the clerical burden on providers. A new report, the 2013 U.S. Healthcare Efficiency Index, which tracks data from health care transactions, shows the potential of Administrative Simplification to achieve this goal and realize savings across the health care industry.

2013 Index Results
The study shows that in many cases, switching to electronic processes for health care administrative transactions presents an opportunity to greatly reduce costs: 

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After attending the AICPA’s Banking and Saving Institution’s Annual Conference in Washington, D.C. in September 2014, financial institutions have expressed concern over preparation for the FASB’s proposed Current Expected Credit Loss (“CECL”). Significant differences exist between the current historical loss rate method used to calculate the allowance for loan and lease losses (“ALLL”) and the new CECL model proposed by the FASB. Due to the proposed changes, the CECL model will require financial institutions of all sizes to recognize an immediate allowance for credit losses that represents all expected losses. The proposed model would likely increase a bank’s ALLL by 30-50%, as stated by the OCC’s Thomas Curry and includes gathering and computing a significantly higher volume of data.  Additionally, it was noted that Institution’s should began preparing for the impact of the issuance of the CECL model, in 2018-2019, by beginning the accumulation of this data now.  For additional information or assistance please contact James Dowling (James.Dowling@marcumllp.com) of the Marcum Financial Institutions Services Group.     

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Administration has closed approximately 450,000 citizenship and immigration status data matching cases and another 210,000 are in progress; warns remaining consumers to respond quickly or their Marketplace coverage could end.

The Federal Health Insurance Marketplace began sending notices this week to consumers with a citizenship or immigration data matching issue (also called an inconsistency) who have not responded to previous notices via mail, email, and phone. While the Federal Marketplace has already received documents and cleared a large number of data inconsistencies related to citizenship or immigration status, consumers who have not yet responded must act now and submit supporting documents by September 5 or their Marketplace coverage will end on September 30.

A citizenship or immigration data matching issue can happen when the information reported in a consumer’s application, such as a Social Security or Permanent Resident Card number, is incomplete or different than the information the government has on file. A data inconsistency does not necessarily mean there is a problem with an individual’s eligibility for enrollment; it means that additional information is needed to verify the information provided in an application. However, if these supporting documents are not received, health insurance plans will be terminated in order to ensure program integrity and protect taxpayer dollars. 

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Administration redoubles its efforts to improve quality of post-acute care for Medicare beneficiaries

Today, the Centers for Medicare & Medicaid Services (CMS) announced two initiatives to improve the quality of post-acute care. First, the expansion and strengthening of the agency’s widely-used Five Star Quality Rating System for Nursing Homes will improve consumer information about individual nursing homes’ quality. Second, proposed new conditions of participation for home health agencies will modernize Medicare’s Home Health Agency Conditions of Participation to ensure safe delivery of quality care to home health patients.

“We are focused on using as many tools as are available to promote quality improvement and better outcomes for Medicare beneficiaries,” said Marilyn Tavenner, CMS administrator. “Whether it is the regulations that guide provider practices or the information we provide directly to consumers, our primary goal is improving outcomes.” 

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On December 30, 2013, the Internal Revenue Service (IRS) issued guidance explaining the circumstances in which it will not challenge partnership allocations to its partners under IRC Section 47, The Rehabilitation Credit. The IRS, within a recent revenue procedure (Rev. Proc. 2014-12, 2014-3 IRB) establishes the requirements of a “safe harbor,” meaning that if the provisions in the Rev. Proc. are followed, the IRS will not challenge the partnerships’ allocation of the IRC Section 47 Rehabilitation Tax Credits to the partnerships’ partners.

Under IRC Section 47, the owner of a qualified rehabilitated building is entitled to claim a tax credit of 10 percent of the qualified rehabilitation expenditures starting in the year in which the property is placed in service.  The amount of the credit increases to 20 percent of the qualified rehabilitation expenditures made with respect to a certified historic structure.   

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The issues around patient data security are many – the message simple; the need to constantly consider the electronic threats to your data has never been greater. Many of our clients have done their checking on a regular basis and find that there are periodic lapses in procedures or in installation of "patches". The bottom line is you need to make sure your IT integrity is always up to date. Call us if you need to get some help.

Federal agency monitoring EHR certification leaves door open to hackers by not requiring the use of strong passwords and other safety standards
Published Date: August 8, 2014
By Lisa Smith

Strong passwords are the first line of defense against computer hackers. But a government report warns that patients are at risk because the certification process for electronic health records (EHRs) doesn’t require the use of a strong password. 

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Final rule strengthens tie between payment and quality improvement

The final rule issued on August 4 by CMS adopts improvements in the quality of care that limit payment for hospital acquired conditions (HACs) and readmissions. The rule, which updates Medicare payment policies and rates for inpatient stays at general acute care and long-term care hospitals (LTCHs) for FY 2015, builds on the administration’s efforts for better hospital patient outcomes and slowing the long-term health care cost growth.  

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