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July 30, 2021

Inside this Issue:

President’s Message

What a 2021 MSHIMA Conference we had! Thank you if you were able to attend. We had some informative talks and surprises along the way. I’d like to once again congratulate all the award winners who surely are deserving of the honors. There is still time to register and view the recorded sessions if you have not done so yet.
If you’ve been paying attention to the news, your internal facility communications or Facebook posts, COVID variants have made their way into our communities. I too felt like things were getting back to normal only to mask-up and hit those discount retailers who have on-hand sanitizer. I urge you all to stay vigilant with your efforts to keep COVID out of your homes and workplaces. We will get through this together but even if you’ve been inoculated, you’re still not 100% safe from getting the COVID virus. You’re only safe if you do not interact with other people, how is that possible?

As the summer winds down and the vacationers go home and as school starts for the kids (and us perpetual adult students) I find myself looking forward to the job I face as your MSHIMA President. I have been watching the news and hoping that CMS, our lawmakers and the powers that be, come to a common ground with those of us on the front lines. No facility is set out to deceive the government or any other payor out of money. Facilities have Coders, Billing Offices, Compliance Offers and other HIM professionals who work by a code of ethics and all stand staunchly beside those codes. Constant auditing is not the answer for anyone and the only entities that are benefiting are the RACs. Even though things have somewhat quieted down, I assure you, they’re looking for the low hanging fruit and will jump when they get the chance.
As I mentioned in my speech at the MSHIMA Conference last month, change is coming. I hope that the changes we face this year are not as drastic as those we overcame in 2020; those changes were much, much too costly. Remember to face all your forthcoming deviations with optimism. Change is coming with or without us, so it's best to enter with an open mind rather than with resistance. Who wants to get left in the dust?
Have a wonderful remainder of your sunny days. Summer isn’t hanging on for much longer. Wear those masks, sanitize those hands and remember to stay positive!

Jeanette Taylor, RHIT, CPC

Save the Date

2022 MSHIMA Annual Conference

June | Jackson, MS
This event will be held in-person with more details to come.

2021 CCS Bootcamp

September 18, 2021
More details to come!

HHS Announces Rule to Protect Consumers from Surprise Medical Bills

Announcement is the first in a series of regulations aimed at shielding patients from increased financial hardships stemming from surprise medical bills.

Today, the Biden-Harris Administration, through the U.S. Departments of Health and Human Services (HHS), Labor, and Treasury, and the Office of Personnel Management, issued "Requirements Related to Surprise Billing; Part I," an interim final rule that will restrict excessive out of pocket costs to consumers from surprise billing and balance billing. Surprise billing happens when people unknowingly get care from providers that are outside of their health plan's network and can happen for both emergency and non-emergency care. Balance billing, when a provider charges a patient the remainder of what their insurance does not pay, is currently prohibited in both Medicare and Medicaid. This rule will extend similar protections to Americans insured through employer-sponsored and commercial health plans.

"No patient should forgo care for fear of surprise billing," said HHS Secretary Becerra. "Health insurance should offer patients peace of mind that they won't be saddled with unexpected costs. The Biden-Harris Administration remains committed to ensuring transparency and affordable care, and with this rule, Americans will get the assurance of no surprises."

Among other provisions, today's interim final rule:
  • Bans surprise billing for emergency services. Emergency services, regardless of where they are provided, must be treated on an in-network basis without requirements for prior authorization.
  • Bans high out-of-network cost-sharing for emergency and non-emergency services. Patient cost-sharing, such as co-insurance or a deductible, cannot be higher than if such services were provided by an in-network doctor, and any coinsurance or deductible must be based on in-network provider rates.
  • Bans out-of-network charges for ancillary care (like an anesthesiologist or assistant surgeon) at an in-network facility in all circumstances.
  • Bans other out-of-network charges without advance notice. Health care providers and facilities must provide patients with a plain-language consumer notice explaining that patient consent is required to receive care on an out-of-network basis before that provider can bill at the higher out-of-network rate.
These provisions will provide patients with financial peace of mind while seeking emergency care as well as safeguard them from unknowingly accepting out-of-network care and subsequently incurring surprise billing expenses.

Tackling surprise billing is critically important, as it often has devastating financial consequences for individuals and their families. Two-thirds  of all bankruptcies filed in the United States are tied to medical expenses.  Researchers estimate that 1 of every 6 emergency room visits and inpatient hospital stays involve care from at least one out-of-network provider, resulting in surprise medical bills. And a 2019 study by the Government Accountability Office (GAO) - PDF, found that the median price charged by air ambulance providers ranged from $36,400 to more than $40,000, and over 70% of these transports were furnished out-of-network, meaning most or all costs fell to the insured individual alone. Thanks to the Biden-Harris Administration and bipartisan congressional support, HHS, Labor, Treasury, and OPM are promulgating rules that will protect consumers from financial ruin simply because they could not ask for an in-network provider during their treatment.

"No one should ever be threatened with financial ruin simply for seeking needed medical care," said U.S. Secretary of Labor Marty Walsh. "Today's Interim Final Rule is a major step in implementing the bipartisan No Surprises Act that will protect Americans from exorbitant health costs for unknowingly receiving care from out-of-network providers."

"Facing a difficult medical situation is challenging enough – no one should then face a surprise medical bill when they get home," said OPM Director Kiran Ahuja. "This interim rule helps to protect Americans from financial ruin and honors federal employees, retirees, their covered family members and other enrollees who receive healthcare through the FEHB Program, the largest employer-sponsored plan, by giving them new protections from unexpected medical bills."

Today's interim final rule with request for comments implements the first of several requirements passed with bipartisan support in title I (the "No Surprises Act") of division BB of the Consolidated Appropriations Act, 2021. The regulations issued today will take effect for health care providers and facilities January 1, 2022. For group health plans, health insurance issuers, and Federal Employees Health Benefits Program carriers, the provisions will take effect for plan, policy, or contract years beginning on or after January 1, 2022.

Fact sheets on this interim final rule can be found here and here.

The interim final rule with comment period can be accessed here - PDF.

AHIMA21: Registration is Open for the Award-Winning AHIMA Virtual Conference

Registration is now open for the AHIMA21 Virtual Conference. Taking place Sept. 20-22, 2021, the award-winning virtual conference will feature dozens of education sessions and networking opportunities under the theme of “Transforming the Future of Health Data.” AHIMA members can register at the early-bird rate through July 30. If you are a delegate, you will have an option to register for the HoD Annual Meeting on the form too. Register today.

Be Sure to “Like” Us on Facebook

If you have not already had the opportunity to ‘Like’ the MSHIMA Facebook page, we encourage you to do so. We often post engaging content and links to articles and events that may be of interest to you.

CMS Proposes Extending Certain Medicare Telehealth Provisions through 2023: 5 Details

The Biden administration has proposed expanding telehealth reimbursement for behavioral healthcare services as part of its proposed 2022 Physician Fee Schedule, which CMS unveiled July 13. 

The proposed rule includes payment rates for Medicare next year as well as several other policy proposals that could affect physicians. 

Here are five things to know about the proposed rule's telehealth components: 
  1. CMS wants to pay providers for giving certain mental and behavioral healthcare services to patients via audio-only telehealth calls. However, payment would only be met under certain services including counseling and therapy for opioid treatment. 
  2. The Physician Fee Schedule eliminated geographic restrictions that could be a barrier to telehealth services for mental health. Under the rule, patients also would be able to access telehealth in their own homes. 
  3. If finalized, the rule would cover telehealth used for diagnosis, evaluation and treatment of mental health disorders and also would pay physicians for mental health visits delivered via telehealth to rural and vulnerable patient populations. 
  4. CMS also proposed allowing certain services that have been added to the Medicare telehealth list to remain covered through the end of Dec. 31, 2023, so that "there is a glide path to evaluate whether the services should be permanently added to the telehealth list following the COVID-19 [public health emergency]." 
  5. Stakeholders can comment on the proposed rule through Sept. Click here to view the full version of the rule. 

CMS to Permanently Cover Audio-Only Telemedicine for Mental Health

Editor’s Note: This article is the second of a four-part series discussing specific telemedicine and digital health features in the 2022 Medicare Physician Fee Schedule proposed rule. To read part 1 of this series on the new Remote Therapeutic Monitoring codes, click here.

The Centers for Medicare & Medicaid Services (CMS) has proposed permanent Medicare coverage of audio-only mental health telehealth services. Currently, Medicare covers audio-only telehealth under temporary waivers that will expire when the Public Health Emergency (PHE) ends. The change, contained in the 2022 Physician Fee Schedule proposed rule, is intended to maintain patient access to mental health care post-PHE and reflects CMS’ growing confidence in virtual care technologies.

This article explains the proposed requirements and highlights the questions for which CMS seeks public comment.

Audio-Only Telehealth Coverage for Mental Health Services

CMS’ proposal would reimburse audio-only telehealth services for the diagnosis, evaluation, or treatment of mental health disorders furnished to established patients when the originating site is a patient’s home. It would accomplish this change by amending the definition of “interactive telecommunications system” under Medicare regulations. As is too-often seen with telemedicine regulations, the proposed rule is technical and nuanced; not a simple “green light” for practitioners to easily deliver audio-only services.

Here is a plain summary of the proposed requirements to cover audio-only telehealth:
  1. Services are limited to diagnosis, evaluation, or treatment of mental health disorders;
  2. Available to established patients only;
  3. The distant site practitioner must have furnished the patient with an in-person item or service within the 6-months prior to the audio-only mental health telehealth service;
  4. The patient must be located at his/her home (as the originating site), not another location;
  5. The distant site practitioner must have the technical capability at the time of the service to use interactive audio-video modality with the patient;
  6. The patient is not capable of, does not wish to use, or does not have bandwidth/access to use interactive audio-video modality; and
  7. The distant site practitioner appends to the claim a service-level modifier to identify the service as audio-only and to certify compliance with these requirements.

Why Did CMS Propose Making Audio-Only Mental Health Permanent?

During the PHE, CMS temporarily waived the interactive audio-video requirement for certain mental health and evaluation and management (E/M) services delivered via telehealth. Under the waiver, Medicare covers these telehealth services even when delivered via audio-only technology. Once the PHE concludes, the emergency waiver authority ends, and so does audio-only telehealth.

CMS has historically been reluctant to cover audio-only technology out of concern it could lead to inappropriate overutilization of services and concern that audio-video visualization is necessary to fulfill the full scope of service elements of CPT codes. Yet, given the widespread use of audio-only services during the PHE, CMS reconsidered its position and altered its policy to respond to changing patient needs and evolving clinical practices.

Indeed, preliminary claims data indicates audio-only E/M visits were some of the most commonly performed telehealth services during the PHE, and the majority of these audio-only services were for treatment of mental health conditions. There is a recognized shortage of mental health care professionals. Swaths of the United States have poor broadband access due to geographic, infrastructure, or socioeconomic challenges. Additionally, some areas suffer a devastating combination of both inadequate broadband and physician shortages.

Clinically, mental health services often differ from most other Medicare telehealth services in that mental health care often involves verbal conversation, where visualization between the patient and practitioner may be less critical. Considering the social determinants that affect an individual’s ability to receive mental health care, assessing clinical safety, and recognizing that patients may have come to rely upon the use of audio-only technology to receive mental health care, CMS opined that terminating the audio-only flexibility at the end of the PHE could harm access to care.

What Can Stakeholders Do Now?

Providers, technology companies, and virtual care entrepreneurs interested in Medicare coverage of audio-only telehealth services should consider providing comments to the proposed rule. CMS specifically asked for comments on the following:
  • Should all mental health telehealth service codes be allowed to use audio-only communication?
  • What, if any, additional documentation should be required in the patient’s medical record to support the clinical appropriateness of providing audio-only telehealth services for mental health in the event of an audit or claims denial? (e.g., information about the patient’s level of risk and any other guardrails that are appropriate to demonstrate clinical appropriateness, and minimize program integrity and patient safety concerns.)
  • Should CMS disallow audio-only for certain higher-level services, such as level 4 or 5 E/M visit codes, when furnished alongside add-on codes for psychotherapy, or codes that describe psychotherapy with crisis?
CMS is soliciting comments on the proposed rule until 5:00 p.m. on September 13, 2021. Anyone may submit comments – anonymously or otherwise – via electronic submission at this link. When commenting, refer to file code CMS-1751-P in your submission. Alternatively, commenters may submit comments by mail to:
  • Regular Mail: Centers for Medicare & Medicaid Services, Department of Health and Human Services, Attention: CMS-1751-P, P.O. Box 8016, Baltimore, MD 21244-8016.
  • Express Overnight Mail: Centers for Medicare & Medicaid Services, Department of Health and Human Services, Attention: CMS-1751-P, Mail Stop C4-26-05, 7500 Security Boulevard, Baltimore, MD 21244-1850
If submitting via mail, please be sure to allow adequate mailing time before the date comments are due to CMS.

Telehealth Use Stabilizing at 38 Times Pre-COVID-19 Levels, McKinsey Says

Dive Brief:

  • Telehealth use overall has stabilized at levels 38 times higher than before the COVID-19 pandemic, ranging from 13% to 17% of visits across all specialties, according to new data from McKinsey released roughly a year since the first major spike in COVID-19 cases.
  • Of all the office visits and outpatient care the consultancy originally projected would be done virtually last year, more than two-thirds are actually being conducted virtually.
  • And though usage has dropped slightly since its peak in spring 2020, patient and physician attitudes toward telehealth have improved. About 40% of surveyed consumers said they planned to continue using telehealth moving forward, up from 11% prior to COVID-19.

Dive Insight:

Telehealth surged last year during COVID-19 as consumers sought a way to access care in the safety of their homes, oiled by lax regulations from Washington enabling broader access and reimbursement. In April last year, overall telehealth utilization was a whopping 78 times higher than in February, according to a McKinsey analysis of telehealth claims volumes.

But after that initial spike, utilization levels have dipped and been largely stable since June last year, the consultancy said. McKinsey in 2020 estimated up to $250 billion of the country's annual healthcare spend could be digitized — but that's "not a foregone conclusion," the new report warns, as it necessitates continued consumer demand, clinician usage and sustained adoption of virtual modalities.

McKinsey surveyed consumers over the first half of this year and found ongoing consumer interest in the modality. Between 40% and 60% of patients expressed interest in broader virtual health tools beyond simple telehealth visits, including a "digital front door" to the healthcare system, or a cheaper virtual-first health plan.

But a gap has historically existed between consumers' expressed interest in digital health products and actual utilization, McKinsey pointed out.

"Continuing to focus on creating a seamless consumer interface, breaking down silos in care provision (across virtual and in-person) with improved data integration and insights, and proactive consumer engagement will all be important to sustaining and growing consumer use of virtual health as the pandemic wanes," the consultancy wrote.

On the provider side, 58% of physicians continue to view virtual care more favorably than before the pandemic, though that's down slightly from September, when 64% of physicians were in support. As of April this year, 84% of doctors were offering telehealth, and 57% said they'd prefer to continue offering it.

However, that's largely dependent on reimbursement: 54% of doctors said they wouldn't provide virtual care if it was paid at a 15% discount to physical services.

Providers are closely tracking reimbursement levels. Federal regulators and private payers are still ironing out how much they'll pay for virtual care after the public health emergency expires, expected at the end of this year, but it's unlikely virtual visits will be paid at parity to in-person care.

CMS has already significantly expanded reimbursable telehealth codes, adding 144 telehealth services in 2020 temporarily covered by Medicare and codifying nine permanently in a December payment rule. However, the new additions only apply to patients in rural areas in a medical facility, and any more meaningful changes would require congressional approval.

But those looming regulatory question marks haven't stymied historic levels of investment in the red-hot digital health space. The first half of 2021 has already smashed a previous record for venture capital funding in digital health set just last year, bringing in $14.7 billion compared to 2020's full-year total of $14.6 billion, per data collected by Rock Health.

The unprecedented influx of cash is spurring the creation of new virtual models spanning a range of services and clinical needs, McKinsey said, with particular growth in the traditionally underserved mental health arena. But the sector is still facing acute growing pains, including better data integration and smoother integration of virtual offerings into existing workflows, and greater alignment with value-based models, according to the consultancy.

Virtual Care Becomes a Common Cause in a Divided Congress

Lawmakers are lining up to decide what Medicare will pay for after the pandemic is over, with sponsors of a leading Senate plan confident they have the votes to include it in a must-pass piece of legislation this year.

Congress appears poised to let millions of Medicare recipients continue to video chat with their doctors after the pandemic is over.

A set of telemedicine policies the Trump administration adopted during lockdowns is emerging as an unexpected bipartisan rallying point as lawmakers begin to weigh life after Covid-19. The coverage policies are due to lapse once the health emergency ends, which could limit telehealth payments to rural providers and doctors with existing relationships with patients.

Lawmakers are lining up to decide what Medicare will pay for after the pandemic is over, with sponsors of a leading Senate plan confident they have the votes to include it in a must-pass piece of legislation this year. Telehealth lobbyists so far have failed to get extensions into Covid relief packages, in part due to concern over how they could drive up health spending and potentially invite fraud.

The new momentum is driven by the way Americans quickly embraced remote care during lockdowns, helping cement a permanent role for what had largely been a niche industry. A Senate plan, S. 1512 (117), by Brian Schatz (D-Hawaii) that would permanently enshrine many of the Trump Medicare coverage and payment rules has attracted 59 co-sponsors. Many private insurers have already moved to offer or broaden coverage of virtual visits.

“We've gone from the point where if I talked about telehealth to someone their eyes would start to glaze over,” Schatz said. “Now when I start to talk about telehealth, their head nods vigorously up and down.”

But skeptics warn a rapid expansion of telehealth could trigger a surge of new health spending, The Congressional Budget Office has long balked at plans to increase payment for the technology, warning of the financial burden it could put on payors. The Medicare advisory committee MedPAC has recommended a cautious approach that would temporarily cover some telehealth services for all beneficiaries but revert to lower reimbursement rates post-crisis for virtual appointments compared to in-person. There's also concern a rapid expansion could prompt more fraudulent billings: The HHS Office of Inspector General estimates $4.5 billion of telehealth-related fraud last year.

Government Accountability Office health officials warned the Senate Finance Committee last month of potential fraud and higher spending, adding it’s unclear how extending the policies would affect quality of care. The Congressional Budget Office last year found a plan that would end Medicare geographic restrictions for mental health care via telehealth would add $1.65 billion in spending between 2021 and 2030.

The CBO found last year that a previous bill, H.R. 5201 (116), that would end Medicare geographic restrictions for mental health care via telehealth would add $1.65 billion in spending between 2021 and 2030.

“We're still in an uphill battle with [congressional scorekeepers],” said Tom Leary, senior vice president of government relations for the Healthcare Information and Management Systems Society. “The question of potential overutilization is the biggest issue.”

The Schatz plan would end all location-based restrictions on telehealth for Medicare recipients, allow patients to originate care from home and let rural health clinics and health centers that provide care in underserved areas to use telehealth permanently. Before the pandemic, Medicare only covered telehealth in certain rural areas and required patients to travel to eligible health care facilities to access telehealth services.

It would also allow the Secretary of Health and Human Services to lift telehealth restrictions permanently and mandate a study on telehealth usage during the Covid-19 pandemic. HHS Secretary Xavier Becerra has signaled support for lifting the curbs.

More than half of states have permanently loosened restrictions on telehealth this year, with others considering legislation to expand access. Several other proposals on telehealth have been introduced in Congress as well.

Advocates have said the legislation would be a win for patient access and medical care and point to support from numerous provider groups such as the American Medical Association.

“It avoids what we call the telehealth cliff,” said Kyle Zebley, director of public policy at the American Telemedicine Association. “If Congress doesn't act and the public health emergency is declared over sometime in the not-too-distant future, then all of these regulatory flexibilities that have made telehealth accessible to all Medicare beneficiaries will go away.”

Backers of the legislation are confident they'll write at least an extension of telehealth flexibilities into law this year, to avoid a potential rollback in access. HHS has said in a letter to governors that the public health emergency declaration lifting telehealth restrictions will likely remain through the end of 2021.

Schatz is looking to attach the legislation to a must-pass bill, which could include a year-end spending deal. If that falls through, lawmakers could opt for a temporary extension that buys time to collect more data on virtual care coming out of the pandemic. This would track with MedPAC's recommendations, which call for a one- or two-year extension after the public health emergency ends.

Among the influential lawmakers who haven't signed on are Senate Finance Chair Ron Wyden (D-Ore.) and House Ways and Means health subcommittee chair Lloyd Doggett (D-Texas), whose tax-writing panels have jurisdiction over Medicare. Doggett — who's expressed concerns over a permanent telehealth scale up before there's more study— has said he would introduce legislation to extend waivers for telehealth to gather more data.

But some telehealth advocates say there’s already enough data showing fewer no-shows for appointments and certain virtual services being just as efficient as in-person care.

“Congress will always ask for more data,” said Sarah-Lloyd Stevenson of Faegre Drinker. “My fear is even if we do a two-year extension, they're going to keep asking for more data.”

Major Medical Groups Call for Mandatory Vaccinations of Health-Care Workers

Leading groups for doctors, nurses and other health care professionals are calling for COVID-19 vaccines to be mandated for health care workers as vaccinations lag amid the spread of the delta variant.

"Due to the recent COVID-19 surge and the availability of safe and effective vaccines, our health care organizations and societies advocate that all health care and long-term care employers require their workers to receive the COVID-19 vaccine," the American Medical Association, American Nurses Association and more than 50 other health care groups said in a statement on Monday. "This is the logical fulfillment of the ethical commitment of all health care workers to put patients as well as residents of long-term care facilities first and take all steps necessary to ensure their health and well-being."

Despite working with vulnerable people, many staff at long-term care facilities are not vaccinated. ProPublica reported last week that only 59 percent of workers at nursing homes and other long-term care facilities had at least one shot, citing government data.

The new call comes as the delta variant fuels an increase in cases in the U.S., primarily among the unvaccinated.

As the vaccination rate lags, many experts say mandates from employers could play a bigger role in boosting the number of people getting the shots, as the role of incentives and persuasion could be fading in usefulness.

"Unfortunately, many health care and long-term care personnel remain unvaccinated," the groups said in Monday's statement, which was first reported by The Washington Post. "As we move towards full FDA [Food and Drug Administration] approval of the currently available vaccines, all health care workers should get vaccinated for their own health, and to protect their colleagues, families, residents of long-term care facilities and patients."

Full FDA approval is also seen as a key step in encouraging more people to get the vaccine.

The health care groups also said they hope all employers will require vaccines for their workers.

"As the health care community leads the way in requiring vaccines for our employees, we hope all other employers across the country will follow our lead and implement effective policies to encourage vaccination," they said. "The health and safety of U.S. workers, families, communities, and the nation depends on it."

MSHIMA Job Board

The MSHIMA website contains a job board available for those seeking employment and those looking to hire qualified HIM professionals in Mississippi. The job board is free to use for all MSHIMA members. Click here to access this great membership tool.

MSHIMA Legal Manual

Don't forget that the MSHIMA Legal Manual is available for purchase and download. This manual includes state and federal guidelines and policies for health information management. Stay up-to-date on the latest updates on policy and download your copy today!
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