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BILLING & CODING

Updated info for Pfizer-BioNTech vaccine

On Dec. 11, 2020, the U.S. Food and Drug Administration issued an Emergency Use Authorization (EUA) for the Pfizer-BioNTech COVID‑19 Vaccine for the prevention of COVID-19 for individuals 16 years of age and older. Review Pfizer’s Fact Sheet for Healthcare Providers Administering Vaccine (Vaccination Providers) regarding the limitations of authorized use. During the COVID-19 Public Health Emergency (PHE), Medicare will cover and pay for the administration of the vaccine (when furnished consistent with the EUA). Review the CMS updated payment and HCPCS Level I CPT code structure for specific COVID-19 vaccine information. Only bill for the vaccine administration codes when you submit claims to Medicare; don’t include the vaccine product codes when vaccines are free. Related links: CMS COVID-19 Provider Toolkit CMS COVID-19 FAQs CDC COVID-19 Vaccination Communication Toolkit for medical centers, clinics, and clinicians FDA COVID-19 Vaccines webpage

STAFF MANAGEMENT

Try skip-level meetings to get straight answers

By Lynne Curry bio Question: The three of us run a mid-sized practice. Despite the pandemic, we’re doing well. We’re hiring, in part because we’re growing, and in part because we’ve had resignations. We don’t understand why so many employees have resigned since mid-October. We have a bright future, but sense we have a problem. As we don’t know what it is, we can’t fix it. It’s not that our employees are choosing unemployment; they’re leaving for jobs in other practices. We’ve tried to exit interview the employees who’ve quit, but only reached two of them. Both said negative things, but when we brought what they’d said up with their former managers, the managers convinced us we’d talked to disgruntled employees whom they’d disciplined for performance problems. We’ve tried an… . . . read more.

HUMAN RESOURCES

5 people problems and how to solve them

By Lynne Curry bio We can’t guess all the challenges facing us as office managers in this new year, but we can assume that we will be dealing with an old one: people and their personalities. Whether working together virtually or in-person, chances are good you will be dealing with people problems. Here are five common problems and strategies for dealing with them. Stopping a bully senior manager without losing your job Question: I face a situation that has no easy answer and no easy solution. As the office manager and human resources director, I supposedly enforce our corporation’s code of conduct and oversee the human resource issues. I report to the report to the chief operating officer, a bully who runs roughshod over any employee unlucky enough to cross… . . . read more.

Tool

Model waiver of COVID-19 infection liability sign to post at your medical office

As long as COVID-19 remains a threat, you run the risk of being sued by clients, vendors, guests and other visitors (“visitors”) who claim they contracted the virus at your office facility as a result of your inadequate safety measures. One way to limit liability is by conspicuously posting a sign at the entry of your facility indicating visitors’ agreement to waive their rights to sue you for COVID-19 infections by entering the office. Although there’s no guarantee that a court would enforce such a waiver, the Model Sign below uses fairly conservative language that has been found to be enforceable in other situations. Caveat: The inclusion of the phrase purporting to insulate you against your own negligence in Sections 3 and 4 is fairly risky and you may want… . . . read more.

EMPLOYMENT LAW UPDATE

EEOC issues COVID-19 vaccine guidance

By Mike O’Brien bio On Dec. 16, 2020, the Equal Employment Opportunity Commission (EEOC) updated its COVID-19 guidance to include a section devoted to vaccinations. The EEOC’s guidance answers these and other COVID-19 vaccine questions: “Is asking or requiring an employee to show proof of receipt of a COVID-19 vaccination a disability-related inquiry?” “If an employer requires vaccinations when they are available, how should it respond to an employee who indicates that he or she is unable to receive a COVID-19 vaccination because of a disability?” “If an employer requires vaccinations when they are available, how should it respond to an employee who indicates that he or she is unable to receive a COVID-19 vaccination because of a sincerely held religious practice or belief?” “What happens if an employer cannot… . . . read more.

COMPLIANCE

Using waivers to avoid getting sued for COVID-19 infections

PLEASE READ NOTICE TO ALL ENTRANTS AND USERS OF THESE FACILITIES EXCLUSION OF LIABILITY – ASSUMPTION OF RISK THESE CONDITIONS WILL AFFECT YOUR LEGAL RIGHTS INCLUDING THE RIGHT TO SUE OR CLAIM COMPENSATION FOR AN INJURY OR ILLNESS In these times of pandemic, signs and forms like this purporting to shield the owner of a facility against liability have become a fixture in workplaces and other facilities. You might even be using them at your own office. The idea is to notify patients, vendors and other visitors (which, for simplicity’s sake, we’ll refer to collectively as “visitors”) that they’re entering the facility at their own risk and in so doing, waiving their rights to sue the owner for any illness or injury they suffer while on the premises. Of course,… . . . read more.

WORKPLACE SAFETY

“COVID captains” keep the focus on safe work practices

By Dan Scungio The year 2020 has roared to a close, and COVID-19 is unfortunately still around. We have made changes to our lives at home, in public, and at work. Healthcare workers, in particular, made several changes early on with PPE use and work practices that are still in effect today. A great deal of work had to be done early on this year to provide information to staff in healthcare facilities regarding this updated safety information. At this point, the initial work that needed to be done by safety professionals has been completed. Employees have been educated regarding the continued use of Standard Precautions and how they create protection from pathogens every day. However, as can happen with safety programs, staff become tired of following the regulations, they… . . . read more.

MEDICAL RECORDS

5 lessons learned From 5 HIPAA fines in one day

By Danika Brinda bio The Office for Civil Rights (OCR) of the Department of Health and Human Services (HHS) hit a new record on Sept. 15, 2020—five HIPAA Fines with Corrective Action Plans in one day. The fines and corrective action plans had one main theme in common—not supplying patients with a copy of requested medical records in a timely fashion. The other thing of note from the action of the OCR is that these were not large multi-million dollar fines that are based on data breaches. These were fines that ranged from $3,500–$70,000 and were all based on a patient making a complaint to the federal government, which upon investigation, lead to the findings of noncompliance with HIPAA and patient’s rights defined by HIPAA. 5 lessons learned: Patients have a right… . . . read more.

CODING

Impact of reimbursement and compliance to WRVU-based compensation

By John McDaniel bio All physician contracts including any form of WRVU based compensation may need to be reviewed and probably amended because of the increase in WRVUʹs (work relative value units) associated with E&M CPT codes effective Jan. 1, 2021. This has been necessitated by CMS whereby the final decision involved eliminating CPT Code 99201 and leaving CPT Code 99211 unchanged. The changes for CPT Codes 99202‐99205 and 99212‐99215 have resulted in increased physician/provider reimbursement since the WRVUs for these codes have been significantly changed. Indeed, this increase in the WRVU component will certainly affect physician compensation. While the major commercial payers have not yet announced their intention to utilize the 2021 E&M codes, those decisions will greatly impact both provider reimbursement and WRVU utilization. It should be noted… . . . read more.

MIPS

Extreme Circumstances Exception application deadline stretched to Feb. 1

To support clinicians during the COVID-19 public health emergency, the Centers for Medicare & Medicaid Services (CMS) is extending the 2020 Merit-based Incentive Payment System (MIPS) Extreme and Uncontrollable Circumstances Exception application deadline to Feb. 1, 2021. For the 2020 performance year, CMS will be using its Extreme and Uncontrollable Circumstances policy to allow MIPS eligible clinicians, groups, and virtual groups to submit an application requesting reweighting of one or more MIPS performance categories to 0% due to the current COVID-19 public health emergency. If your practice has any concerns about the effect of the COVID-19 public health emergency on your performance data, including cost measures, for the 2020 performance period, submit an application now and cite COVID-19 as the reason for your application. If you have an approved application, you can… . . . read more.


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