As 2021 comes to an end, it is vital that practice managers are well-equipped with the skills and knowledge they need as they move forward into 2022. Over the past year, it has been my privilege to have worked with so many talented professionals to provide content to Oncology Practice Management through a partnership between Practice Management Institute (www.pmimd.com) and Michigan Society of Hematology and Oncology (www.msho.org). In case you missed any of these articles, see the sidebar for a list of titles.
I want to thank everyone who shared their expertise to create these articles, and I look forward to collaborating with you to provide more meaningful content in 2022.
The upcoming year will no doubt present new challenges and opportunities for oncology practice managers and their teams. The following provides an overview of some of the key topics to keep on your radar.
Telehealth in 2022
Kem Tolliver, CMPE, CPC, CMOM, President, Hyattsville/Prince George’s County, American Academy of Professional Coders, and President and Chief Executive Officer, Medical Revenue Cycle Specialists, Washington, DC.
Providers have depended on telehealth technology, security, and reimbursement to coordinate, improve, and expand healthcare services throughout the Public Health Emergency (PHE). As we move into calendar year (CY) 2022, leaders are encouraged to develop internal operational strategic planning based on the following 4 factors:
- Optimize all features of telehealth technology to enhance the user experience, which will result in improved provider–patient interaction.
- Protect healthcare organizations from rising cybersecurity threats while continuing to expand the use and reliance on technology for daily operations, which will include a long-term remote workforce.
- Enhance care coordination among provider organizations and facilities to minimize gaps in care, which will reduce overall healthcare costs by improving quality of care.
- Expand services through the use of technology by creating a virtual extension of care to those who require alternative care modalities.
On November 2, 2021, information was made available through an unpublished rule by the Centers for Medicare & Medicaid Services (CMS) on the Federal Register regarding the Medicare Program; CY 2022 Payment Policies Under the Physician Fee Schedule and Other Changes to Part B Payment Policies; Medicare Shared Savings Program Requirements; Provider Enrollment Regulation Updates; and Provider and Supplier Prepayment and Post-Payment Medical Review Requirements. This rule includes modifications to reimbursement for both telehealth services and audio-only services. It can be found at https://public-inspection.federalregister.gov/2021-23972.pdf.
Coding and Reimbursement in 2022
Jan Hailey, MHL, CMCO, CMC, CMIS, CMOM, Director, Ambulatory Care Management, Saint Joseph Health System/Select Health Network, Mishawaka, IN.
Accurate reimbursement begins with accurate medical coding. The International Classification of Diseases, Tenth Edition (ICD-10) diagnosis codes submitted on a claim should support medical necessity of the service performed and be reported at the highest level of specificity. ICD-10 codes allow healthcare providers to report the clinical complexity of their patients to the government and other third-party payers. There are 159 additions, 25 deletions, and 27 revisions in ICD-10 for 2022, which went into effect October 1, 2021.
Every medical, diagnostic, or surgical procedure or service has an associated 5-digit Current Procedural Terminology (CPT) code assigned to it.1 CPT codes offer physicians and other healthcare professionals a uniform language for coding medical services and procedures to streamline reporting, increase accuracy, and improve efficiency.2 Each procedure code must be supported by a valid diagnosis code. There are 405 editorial changes in the 2022 CPT code set, including 249 new codes, 63 deletions, and 93 revisions, as well as new COVID-19 vaccine and administration codes to report the type and dose for better tracking and reporting. Forty-three percent of the editorial changes for 2022 are category 3 CPT codes in the area of new technology services. The 2022 CPT codes are effective January 1, 2022.
Medical record documentation is required to support the ICD-10 and CPT codes submitted on a claim. Clinical documentation should accurately reflect what transpired during the patient encounter and can be used to justify reimbursement for claim disputes.
Payer policies. Each payer can develop its own coverage policies and change them often. Therefore, it is critical to review payer notices. This can be accomplished by signing up for e-mail updates or routinely checking payer websites.
CMS developed the National Coverage Determinations to describe Medicare coverage nationwide for specific medical services. Medicare Administrative Contractors develop Local Coverage Determinations to describe coverage for specific medical services at the Medicare Administrative Contractor level. In the event of a conflict, National Coverage Determinations override Local Coverage Determinations.
Value of certified coders. Certified medical coders are highly qualified professionals who can help a medical practice stay compliant with regulatory requirements. They understand complex coding guidelines and know how to appropriately apply them when choosing codes for reimbursement. Each year, diagnosis and procedure codes are added, deleted, and updated. Certified coders are required to participate in ongoing education and recertification, so they remain up-to-date with coding and regulatory changes. A certified coder can reduce the number of denied claims, increase the rate of collections, and lower the risk for fraud and abuse allegations.
Compliance in 2022
Shawntea (Taya) Moheiser, MBA, CMPE, CMOM, Owner, ITS Healthcare, Omaha, NE.
CMS released the 2022 Physician Fee Schedule (PFS) and Quality Payment Program rules in early November 2021, and with them, a lot of change for the upcoming year.
With the implementation of the COVID-19 PHE in 2020, many of us have become accustomed to certain leniencies, flexibilities, and expansions related to the Health Insurance Portability and Accountability Act (HIPAA), such as provider licensure and telehealth, to name a few. It is important to note that any flexibilities tied to the PHE that were not finalized in the 2022 PFS will expire when the PHE does. The current expiration date of the PHE is January 16, 2022, if it is not renewed for another 90-day period by the US Department of Health and Human Services’ (HHS) Secretary Xavier Becerra.
Expiring with PHE. Providers can find resources on COVID-19 guidelines, PHE best practices, and what to do at the time of expiration of the PHE at the HHS’ emergency preparedness gateway TRACIE (https://asprtracie.hhs.gov/COVID-19#covid-19-healthcare-planning-resource-collections).
The following are some highlights related to items that will change upon expiration:
- During the PHE, covered providers would not be subject to penalties for HIPAA violations related to telehealth services where good faith could be evidenced. This will expire when the PHE does, at which time traditional HIPAA regulations and penalties will apply.
- CMS did finalize expansion of certain nonphysician providers to supervise and delegate certain telehealth services within state and federal law and scope of practice, but there are boundaries and not all provider flexibilities issued during the PHE will be retained long-term.
- Audio-only telehealth visits are going away after the PHE expires for all services except mental health services. Telehealth services in an audio-only format have been finalized as extended if the provider has full audio-visual capabilities and it is the patient who has the limitation to audio only.
- During the PHE, Medicare beneficiaries receiving telehealth services could have certain coinsurances waived. This is going away when the PHE expires, and copays must again be collected with evidenced good faith.
- License reciprocity is also returning to the norm, where licensed physicians could provide services to Medicare beneficiaries outside of their enrollment state during the PHE. Traditional licensure and validation processes with Medicare will resume at the expiration of the emergency.
- Flexibility for telehealth platforms (ie, Apple’s FaceTime or Facebook’s Messenger Video Chat) will revert to standard HIPAA requirements. This means facilities must perform vendor due diligence, confirm the security of data being shared, and establish Business Associate Agreements with vendors. HHS has made it very clear that the responsibility of verifying vendor HIPAA compliance is on the provider/practice to perform and to audit.
CMS 2022 PFS changes. As always, the 2022 CMS PFS is a hefty document, weighing in at more than 2400 pages. If you do not have the time or desire to read through all of it, I suggest that you review the following overview, and then dig into the sections of the PFS that will signficantly affect you:
- Conversion Factor Reduction. With the expiration of the Consolidated Appropriations Act (CAA) and the decrease required to maintain budget neutrality, the conversion factor for 2022 comes to just $34.89, a decrease of approximately 3%. There is always the chance that the US Congress could ingest funds into the budget for 2022, but at this time, there has been no such documentation of that occurring for the upcoming year.
- Split/Shared Visits. CMS refined their definition of split/shared visits to make it clear in 2022 that these visits can be for new or established patients, whether visits are initial or subsequent, as well as for prolonged services as long as the billing providers are within the same group. The substantive portion would include more than half of the history, physical, or exam, or more than half of the total time, and the visit should be billed by the provider who performed the substantive portion. A modifier is required to signify that 2 separate providers performed services and the documentation in the record must clearly identify the 2 separate providers with signature from the substantive provider. There are very specific requirements around critical care, what time counts, and more, so please read through this section carefully if it applies to you.
- Critical Care Services. Critical care services may be paid on the same day as other evaluation and management services in the same group now under several sets of circumstances. If you provide critical care services, closely review the new allowances for same specialty same-day billing, different specialty same-day billing, and separate billing in addition to a global period that is unrelated to the critical care visit.
- Telehealth. Statutory amendments in CAA have been finalized to remove geographic restrictions and to add a patient’s home as an originating site for telehealth services related to diagnosis, treatment, and evaluation of a mental health disorder. Audio-only interactive communication services were also finalized as documented above.
- Physician Assistants. CMS finalized another amendment from the CAA which now allows physician assistants (PAs) to directly bill CMS for professional services rendered to Part B beneficiaries beginning January 1, 2022. This amendment also allows PAs to reassign payments for professional services and to incorporate with other PAs and bill Medicare as well.
- Appropriate Use Criteria. CMS finalized a delay of the penalty phase of the appropriate use criteria program, pushing it back to January 1, 2023.
Please note that it would be impossible to cover everything in this overview, so what is most important is that you are aware of the far-reaching impact of these rules and dive in where necessary.
The Human Resource Perspective for 2022
Bettinna Signori, CMOM-HEM/ONC, Regional Practice Administrator, Beaumont Medical Group, Southfield, MI.
The post-pandemic labor shortages are being felt nationwide, but even more so in the healthcare industry. Challenges, such as burnout, pandemic fatigue, and access to childcare services for working parents, are just some of the many factors that have contributed to these shortages. Some data points of note include the following:
- By 2030, the World Health Organization expects a net shortage of 15 million healthcare workers across the industry.3
- The nation’s hospitals lost roughly 8000 jobs in September 2021, according to a recent report by the US Bureau of Labor Statistics.4
- A report from Morning Consult shows that 18% of healthcare workers have quit their jobs during the COVID-19 pandemic, and that 31% of those healthcare workers who have kept their jobs during the pandemic have considered leaving.5
The labor shortage is clearly here to stay, at least for a while, so administrators need to take steps to mitigate the impact on operations. An option that should be considered is an increased use of technology.
Most practices utilize an electronic medical record system which has options and functionality that can help workflows. One such functionality is the ability to enable eCheck-in for patients, which allows them to complete many of the check-in tasks before coming in for their appointment. Patients can use the eCheck-in functionality to review and update personal information, such as insurance, address, or pharmacy of choice; they are also able to pay copays or balances. Having patients complete some of these tasks ahead of time helps to shorten the check-in process, which results in a more streamlined flow, especially when practices are short-staffed at the front desk.
Implementing an eCheck-in process may not solve all of the staffing shortages administrators are facing, but it can help the workload for those who are still working in the practice.
Navigating Change in 2022
Jason B. Lockard, CMOM-HEM/ONC, Regional Practice Administrator-Specialty, Beaumont Medical Group, Southfield, MI.
There is no question that 2021 has been a year of continued change. As leaders, it is our responsibility to support our team members to the best of our ability as we navigate these challenging times. As the adage goes, “the only constant is change.” As such, it is important to recognize the 5 stages of change (precontemplation, contemplation, preparation, action, and maintenance), as well as the 5 stages of grief (denial, anger, bargaining, depression, and acceptance), in response to our constantly evolving environment. It is also critical that we know how to identify which stages our team members are in, so that we can take steps to provide them with the best support possible. Navigating the 5 stages of change can be difficult and is often iterative in that the stages can be nonlinear depending on the situation. However, knowing where your team members are in these stages can help in the process.
Throughout the past year, not only have we needed to make changes at a moment’s notice, but the circumstances which guided these changes were difficult to understand and often anxiety-provoking. The reality of the pandemic, related staffing challenges, and frequent adjustments to protocols in response to evolving situations has been strenuous but necessary. Indeed, this has been a challenge, but understanding your personal feelings on change (as well as those of your team members and other colleagues) is important to charting a successful course for the future.
- Capitol Imaging Services. CPT codes and why you need to know what they are. https://capitolimagingservices.com/what-are-cpt-codes/. Accessed November 5, 2021.
- American Medical Association. CPT overview and code approval. https://www.ama-assn.org/print/pdf/node/34456. Accessed November 6, 2021.
- Liu JX, Goryakin Y, Maeda A, et al. Global health workforce labor market projects for 2030. Hum Resour Health. 2017;15:11. Erratum in: Hum Resour Health. 2017;15:18.
- US Bureau of Labor Statistics. The employment situation—October 2021. www.bls.gov/news.release/pdf/empsit.pdf. Accessed November 9, 2021.
- Galvin G. Nearly 1 in 5 health care workers have quit their jobs during the pandemic. October 4, 2021. https://morningconsult.com/2021/10/04/health-care-workers-series-part-2-workforce/. Accessed November 7, 2021.