Having worked with a lot of practices that have very large patient balances we are routinely asked the best way to manage patient AR. In a nutshell, these balances typically exist because patients with balances have not been asked for a payment prior to coming in for an appoitment and/or a payment plan has not been implemented for those who are unable to pay their bill at time of service. The problem is often compounded by not having any mechanism in place to administer these plans if a one has been developed.
Absent a sound financial policy, the practice will end up spending resources post service on collection efforts or ultimately end up having these accounts written off as bad debt because no-one ever explained payment options to the patients.
So what's the answer? One solution is to develop protocols for patient payment plans that include acceptable payment thresholds that are clearly communicated to patients before services are provided. An example might be for charges in the $400 - $500 range that 50% is paid in the first month, with 25% in the second and the remaining 25% in the third. The goal should be to collect all patient balances due in six months or less.
Once payment plan agreements have been created, staff should be given the autonomy to implement and administer the program. The physician should not have to approve each payment plan that is negotiated; instead, a formal structure and policy should be implemented. For example pre-approve a sliding scale i.e. for amounts up to $300, payments made in $100 increments and paid within three months, for amounts of $900 paid in $150 increments over six months etc.
Patients who are set up on a payment plan should be asked to sign the payment plan agreement indicating their understanding of the terms of payment. Should the patient miss a payment the practice should immediately make follow up calls.
We don't carry balances on anything else without at least making regular monthly payments so why should it be any different with medical services that have been provided to us? Following through with this and determining which patients should be on payments plans, ideally before service is rendered, gives practices far greater control over accounts receivables and smooths cash flow.
Friday, July 1, 2011
Thursday, March 10, 2011
8 Ways to Sabotage Your Own Funding Efforts
I've been through the dog & pony show of raising money, the post below is spot on:
Posted by Marty Zwilling, on March 10th, 2011
A while back I received a discouraging note from an entrepreneur with a patent and a medical software application who couldn’t find a dime of investment, and was grousing that seed funding just wasn’t available anymore. After exchanging a couple of notes, I concluded that she was more likely a victim of item #1 on my reject list, rather than a drought on seed funding.
Too many people still believe the urban myth that you can sketch your idea on a napkin, and people will throw money at you. Fundraising is indeed brutally tough at all stages, and the seed funding is the hardest to find. The simple answer is that if you need funding, do your homework early and completely.
I seem to see common threads in the stories from people who don’t get money, so I checked my list against ones from Brian Emerson, president of Starlight Investments, as quoted in a recent book by Barry H. Cohen and Michael Rybarski, titled “Start-Up Smarts.” We agree on issues we see sabotaging most funding efforts, in decreasing priority sequence:
1. Lack of a compelling story. That story has to begin with a painful problem shared by a large collection of viable customers, with your competitive solution. Additionally, you need to be able to communicate the essence that story and value to investors in a couple of sentences – your elevator pitch.
2. Lack of clear objectives/goals. Often, the number one question that entrepreneurs fail to address is: “How much money do you need, and what valuation do you place on your company?” Then you have to have evidence to support your request. I’ve asked this question many times of presenters in angel meetings, and often get a blank look.
3. Failure to prepare for due diligence. Any serious investor will perform a thorough review of your business and personal background before signing the check. They don’t like surprises, so you should explain any possible issues first, in the best possible light, before being asked.
4. Lack of understanding of the fund process/rules. The key here is to create a win-win situation for your investors. Discussion of risks and rewards in an open fashion, without sleight-of-hand or shortcuts, will convince investors that they can count on you, and will avoid shareholder lawsuits later.
5. Reliance on inappropriate business professionals. Using well-respected professionals to bolster your endeavor is key. If you can attract well-known advisors, attorneys, and accountants, it will give potential investors comfort that you have been able to get implied endorsement of your concept, as well as your integrity.
6. Poor choice of funding sources. It is not helpful to you for funders to love an idea that does not fit the criteria for their investing capability. Don’t waste time talking to VCs for requests less than $1M, or very early stage, and don’t expect professional investors to jump in if you have no “skin in the game.”
7. Not doing due diligence on the funding source. You need to complete due diligence on your prospective funders as they complete due diligence on you. Find out what they have invested in recently, what stage, and what is their track record of expectations and follow-through. You don’t need surprises or disappointments either.
8. Being unprepared for the next steps. After a good elevator pitch or initial presentation, investors will ask for your formal business plan and financial projections. Don’t derail their enthusiasm or risk your professional image by not having these materials immediately available. The same thing goes for incorporating your company, having key hires lined up, and facilities arranged as required.
There are many others opportunities for funding to be derailed. Rather than play the victim, you can be proactive on all these items, and stay one step ahead of your “competitors” in professionalism, timing, and preparation. The resources are out there to help you, like the book mentioned, this site, and many more. Use them and win.
Martin Zwilling is the founder and chief executive officer of Startup Professionals, a company that provides products and services to start-up founders and small business owners.
Posted by Marty Zwilling, on March 10th, 2011
A while back I received a discouraging note from an entrepreneur with a patent and a medical software application who couldn’t find a dime of investment, and was grousing that seed funding just wasn’t available anymore. After exchanging a couple of notes, I concluded that she was more likely a victim of item #1 on my reject list, rather than a drought on seed funding.
Too many people still believe the urban myth that you can sketch your idea on a napkin, and people will throw money at you. Fundraising is indeed brutally tough at all stages, and the seed funding is the hardest to find. The simple answer is that if you need funding, do your homework early and completely.
I seem to see common threads in the stories from people who don’t get money, so I checked my list against ones from Brian Emerson, president of Starlight Investments, as quoted in a recent book by Barry H. Cohen and Michael Rybarski, titled “Start-Up Smarts.” We agree on issues we see sabotaging most funding efforts, in decreasing priority sequence:
1. Lack of a compelling story. That story has to begin with a painful problem shared by a large collection of viable customers, with your competitive solution. Additionally, you need to be able to communicate the essence that story and value to investors in a couple of sentences – your elevator pitch.
2. Lack of clear objectives/goals. Often, the number one question that entrepreneurs fail to address is: “How much money do you need, and what valuation do you place on your company?” Then you have to have evidence to support your request. I’ve asked this question many times of presenters in angel meetings, and often get a blank look.
3. Failure to prepare for due diligence. Any serious investor will perform a thorough review of your business and personal background before signing the check. They don’t like surprises, so you should explain any possible issues first, in the best possible light, before being asked.
4. Lack of understanding of the fund process/rules. The key here is to create a win-win situation for your investors. Discussion of risks and rewards in an open fashion, without sleight-of-hand or shortcuts, will convince investors that they can count on you, and will avoid shareholder lawsuits later.
5. Reliance on inappropriate business professionals. Using well-respected professionals to bolster your endeavor is key. If you can attract well-known advisors, attorneys, and accountants, it will give potential investors comfort that you have been able to get implied endorsement of your concept, as well as your integrity.
6. Poor choice of funding sources. It is not helpful to you for funders to love an idea that does not fit the criteria for their investing capability. Don’t waste time talking to VCs for requests less than $1M, or very early stage, and don’t expect professional investors to jump in if you have no “skin in the game.”
7. Not doing due diligence on the funding source. You need to complete due diligence on your prospective funders as they complete due diligence on you. Find out what they have invested in recently, what stage, and what is their track record of expectations and follow-through. You don’t need surprises or disappointments either.
8. Being unprepared for the next steps. After a good elevator pitch or initial presentation, investors will ask for your formal business plan and financial projections. Don’t derail their enthusiasm or risk your professional image by not having these materials immediately available. The same thing goes for incorporating your company, having key hires lined up, and facilities arranged as required.
There are many others opportunities for funding to be derailed. Rather than play the victim, you can be proactive on all these items, and stay one step ahead of your “competitors” in professionalism, timing, and preparation. The resources are out there to help you, like the book mentioned, this site, and many more. Use them and win.
Martin Zwilling is the founder and chief executive officer of Startup Professionals, a company that provides products and services to start-up founders and small business owners.
Wednesday, December 1, 2010
Database lists drug firms' payments to 17,000 doctors
Here's some interesting information about the close relationship between physicians and drug companies. Make your own decision regarding how unbiased your physician is when it comes the prescription he/she writes for you...
BY CYNTHIA BILLHARTZ GREGORIAN
Three drug companies paid a Washington University anesthesiologist $255,737 over 18 months to speak to other doctors about some of their products, including pain killers and muscle relaxants.
An analysis of data from seven major drug companies found that Dr. Anthony Guarino, an assistant professor of anesthesiology, was one of the doctors nationwide who received the most money from the drug companies between January 2009 and June 2010. The analysis was done by ProPublica, an independent, nonprofit news organization in New York.
The data show that seven companies - Eli Lilly and Company, Pfizer Inc., Merck & Company Inc., Cephalon, GlaxoSmithKline, AstraZeneca Pharmaceuticals and Johnson & Johnson - together paid more than $282 million to more than 17,000 doctors nationwide.
Critics of such relationships maintain they pose a conflict of interest - that they can color the way doctors educate their peers at company-sponsored events, as well as how they prescribe medications in their offices.
But Guarino, who treats patients at the pain management center at Barnes-Jewish West County Hospital, said he mostly prescribes generic drugs.
"There are situations where I recognize that brand medications would be superior, and in that instance I will prescribe them," Guarino said. "But I do let the patient know that I speak for the company, and if they feel there's a conflict of interest I will not write a prescription for that medicine."
Several of the seven companies in the "Dollars for Docs" database were required to post names and compensation online as the result of legal settlements. ProPublica acknowledges that the data is limited, so far.
New disclosure rules in the federal health care reform law require more than 70 other pharmaceutical companies operating in the United States to start reporting payments to doctors in March 2013.
The data from the seven reporting companies show payments to individual doctors ranged from less than $100 to more than $303,000. More than 230 doctors on the Missouri side of the St. Louis area and 14 in the Metro East area accepted payments.
Charles Ornstein, senior reporter for ProPublica, stresses that it's legal for pharmaceutical companies to pay doctors, and that the database is designed to start conversations between doctors and patients.
"Doctors should feel comfortable talking about this," he said. "If they're uncomfortable answering questions about their relationship with pharmaceutical companies, patients need to ask why."
Educating doctors
Dr. David L. Weinstein, an obstetrician-gynecologist with Consultants in Women's Healthcare in west St. Louis County, made $164,295 over 18 months speaking to other physicians about two osteoporosis drugs, according to the database. He is among the 13 doctors in the metro area who were paid the most by the seven drug companies.
Weinstein says educating other doctors on behalf of pharmaceutical companies has made him a better physician.
"I participate in more conferences on advances in my field, and find myself taking a more holistic approach to patient care, which means writing fewer prescriptions and letting physician audiences know this and why," he said.
Dr. Anthony J. Margherita, a physical medicine and rehabilitation doctor at West County Spine & Sports Medicine, said he and other speakers draw on their own clinical experience in their specialties when speaking to other doctors, most of whom are general practitioners.
"The key is making sure they prescribe and treat correctly," he said. Margherita said he has encountered doctors "who were inappropriately or dangerously prescribing the medicine I was speaking about."
For instance, he said, Cymbalta is not indicated for use by people with severe kidney disease. "I had one doctor who'd been prescribing it to a patient with kidney disease come up after an event and said, ‘Oh, my god, I'm stopping it right now.'"
Eli Lilly paid Margherita $122,274 to speak about Cymbalta.
Dr. Jerold J. Kreisman, a psychiatrist with Allied Behavioral Consultants Inc. in St. Louis, sees benefits in specialists who can talk about specific diseases and conditions reaching out to educate doctors in remote areas. He doesn't oppose the idea of the database.
"Full disclosure is important as long as people understand it in its full context," Kreisman said. "If there's a feeling that it's being done just for money and as a main source of income, for the vast majority of doctors that's really not the case. It's reimbursement for (time away from) their offices, working and seeing patients."
Best in the field?
Some doctors, such as Guarino, say they're chosen by the pharmaceutical companies and reimbursed at such high rates because they're among the best in their fields.
But ProPublica also identified 292 doctors in the database who have been sanctioned or warned by regulators.
Among them are six doctors from Missouri - three from the St. Louis area - who were disciplined for infractions, including inappropriate sexual relationships with patients, failing to get proper informed consent from those participating in clinical studies and not keeping proper records and inventories of controlled substances.
In addition to ethical issues, some experts wonder whether the pharmaceutical companies' programs are necessary.
The FDA-approved labeling and package inserts that come with pharmaceutical products should give doctors all of the information they need for prescribing them, says Dr. Murray Kopelow, president of the Accreditation Council for Continuing Medical Education in Chicago. There's also a wide array of non-commercial sources for doctors to get medical information.
"We have about 2,200 accredited medical education providers and more than 10 million individual registrants in that education each year," he said. "We believe it's unbiased education, without a proprietary interest."
Doctors who speak for certain drugs often don't have all the information about those drugs, said John Abramson, a lecturer on health policy at Harvard University and author of "Overdosed America."
"It's proprietary information, and (pharmaceutical companies) very rarely make it available for outside research or analysis," Abramson said.
For profits or patients?
When information comes from a commercial source, he added, the purpose typically is to maximize profits for shareholders and not to improve patient health.
The ProPublica database provides transparency, but determining to what extent a conflict of interest is at play is nearly impossible, Abramson said.
He said Harvard clamped down this year by instituting a policy that prevents its faculty members from giving promotional talks for drug companies. It also requires doctors to publicly disclose fees exceeding $5,000 a year for consulting or serving as board members.
Locally, the St. Louis University Medical Center encourages collaborations between its faculty and private industry, with the idea that it advances the discovery of better treatments.
Nancy Solomon, communications director for St. Louis University Medical Center, said in an e-mail that the school continually reviews its policies "to ensure faculty members engage with industry effectively, ethically and with the highest degree of professionalism so that research, education and medical decision-making always are driven by what ultimately is best for patients."
Washington University School of Medicine requires its doctors to disclose how much money they receive from pharmaceutical companies each year. If it's more than $10,000, the faculty member must post it on his or her university Web page. A university panel regularly reviews the relationship between that physician and the pharmaceutical company.
For instance, the panel calculates the hourly rate the physicians are earning from the companies, said Dr. James P. Crane, executive vice chancellor for clinical affairs and CEO of the faculty practice plan at Washington University.
"One benchmark we use is how much a physician typically earns in clinical practice, and that varies by specialty," said Crane. "Our upper limit is $500 an hour."
Crane said the university also monitors patterns using its electronic prescribing system to ensure that a doctor isn't prescribing a drug he or she speaks about more than others.
Abramson isn't convinced such measures are good enough because those faculty members also have influence over medical students.
He recalls a student doing a fellowship in rehabilitation and pain medicine at Harvard telling him how he would try to talk to patients about lifestyle changes, only to have physicians come in and prescribe medications instead.
That's the commercial influence on health care, he said.
Dr. H. Gilbert Welch, professor of medicine at the Dartmouth Institute for Health Policy and Clinical Practice says public disclosure such as the ProPublica database is healthy, even if it doesn't always reflect well on his profession.
"Patients need to know it doesn't affect all doctors," he said, "but it certainly highlights the fact that money matters in medicine."
BY CYNTHIA BILLHARTZ GREGORIAN
Three drug companies paid a Washington University anesthesiologist $255,737 over 18 months to speak to other doctors about some of their products, including pain killers and muscle relaxants.
An analysis of data from seven major drug companies found that Dr. Anthony Guarino, an assistant professor of anesthesiology, was one of the doctors nationwide who received the most money from the drug companies between January 2009 and June 2010. The analysis was done by ProPublica, an independent, nonprofit news organization in New York.
The data show that seven companies - Eli Lilly and Company, Pfizer Inc., Merck & Company Inc., Cephalon, GlaxoSmithKline, AstraZeneca Pharmaceuticals and Johnson & Johnson - together paid more than $282 million to more than 17,000 doctors nationwide.
Critics of such relationships maintain they pose a conflict of interest - that they can color the way doctors educate their peers at company-sponsored events, as well as how they prescribe medications in their offices.
But Guarino, who treats patients at the pain management center at Barnes-Jewish West County Hospital, said he mostly prescribes generic drugs.
"There are situations where I recognize that brand medications would be superior, and in that instance I will prescribe them," Guarino said. "But I do let the patient know that I speak for the company, and if they feel there's a conflict of interest I will not write a prescription for that medicine."
Several of the seven companies in the "Dollars for Docs" database were required to post names and compensation online as the result of legal settlements. ProPublica acknowledges that the data is limited, so far.
New disclosure rules in the federal health care reform law require more than 70 other pharmaceutical companies operating in the United States to start reporting payments to doctors in March 2013.
The data from the seven reporting companies show payments to individual doctors ranged from less than $100 to more than $303,000. More than 230 doctors on the Missouri side of the St. Louis area and 14 in the Metro East area accepted payments.
Charles Ornstein, senior reporter for ProPublica, stresses that it's legal for pharmaceutical companies to pay doctors, and that the database is designed to start conversations between doctors and patients.
"Doctors should feel comfortable talking about this," he said. "If they're uncomfortable answering questions about their relationship with pharmaceutical companies, patients need to ask why."
Educating doctors
Dr. David L. Weinstein, an obstetrician-gynecologist with Consultants in Women's Healthcare in west St. Louis County, made $164,295 over 18 months speaking to other physicians about two osteoporosis drugs, according to the database. He is among the 13 doctors in the metro area who were paid the most by the seven drug companies.
Weinstein says educating other doctors on behalf of pharmaceutical companies has made him a better physician.
"I participate in more conferences on advances in my field, and find myself taking a more holistic approach to patient care, which means writing fewer prescriptions and letting physician audiences know this and why," he said.
Dr. Anthony J. Margherita, a physical medicine and rehabilitation doctor at West County Spine & Sports Medicine, said he and other speakers draw on their own clinical experience in their specialties when speaking to other doctors, most of whom are general practitioners.
"The key is making sure they prescribe and treat correctly," he said. Margherita said he has encountered doctors "who were inappropriately or dangerously prescribing the medicine I was speaking about."
For instance, he said, Cymbalta is not indicated for use by people with severe kidney disease. "I had one doctor who'd been prescribing it to a patient with kidney disease come up after an event and said, ‘Oh, my god, I'm stopping it right now.'"
Eli Lilly paid Margherita $122,274 to speak about Cymbalta.
Dr. Jerold J. Kreisman, a psychiatrist with Allied Behavioral Consultants Inc. in St. Louis, sees benefits in specialists who can talk about specific diseases and conditions reaching out to educate doctors in remote areas. He doesn't oppose the idea of the database.
"Full disclosure is important as long as people understand it in its full context," Kreisman said. "If there's a feeling that it's being done just for money and as a main source of income, for the vast majority of doctors that's really not the case. It's reimbursement for (time away from) their offices, working and seeing patients."
Best in the field?
Some doctors, such as Guarino, say they're chosen by the pharmaceutical companies and reimbursed at such high rates because they're among the best in their fields.
But ProPublica also identified 292 doctors in the database who have been sanctioned or warned by regulators.
Among them are six doctors from Missouri - three from the St. Louis area - who were disciplined for infractions, including inappropriate sexual relationships with patients, failing to get proper informed consent from those participating in clinical studies and not keeping proper records and inventories of controlled substances.
In addition to ethical issues, some experts wonder whether the pharmaceutical companies' programs are necessary.
The FDA-approved labeling and package inserts that come with pharmaceutical products should give doctors all of the information they need for prescribing them, says Dr. Murray Kopelow, president of the Accreditation Council for Continuing Medical Education in Chicago. There's also a wide array of non-commercial sources for doctors to get medical information.
"We have about 2,200 accredited medical education providers and more than 10 million individual registrants in that education each year," he said. "We believe it's unbiased education, without a proprietary interest."
Doctors who speak for certain drugs often don't have all the information about those drugs, said John Abramson, a lecturer on health policy at Harvard University and author of "Overdosed America."
"It's proprietary information, and (pharmaceutical companies) very rarely make it available for outside research or analysis," Abramson said.
For profits or patients?
When information comes from a commercial source, he added, the purpose typically is to maximize profits for shareholders and not to improve patient health.
The ProPublica database provides transparency, but determining to what extent a conflict of interest is at play is nearly impossible, Abramson said.
He said Harvard clamped down this year by instituting a policy that prevents its faculty members from giving promotional talks for drug companies. It also requires doctors to publicly disclose fees exceeding $5,000 a year for consulting or serving as board members.
Locally, the St. Louis University Medical Center encourages collaborations between its faculty and private industry, with the idea that it advances the discovery of better treatments.
Nancy Solomon, communications director for St. Louis University Medical Center, said in an e-mail that the school continually reviews its policies "to ensure faculty members engage with industry effectively, ethically and with the highest degree of professionalism so that research, education and medical decision-making always are driven by what ultimately is best for patients."
Washington University School of Medicine requires its doctors to disclose how much money they receive from pharmaceutical companies each year. If it's more than $10,000, the faculty member must post it on his or her university Web page. A university panel regularly reviews the relationship between that physician and the pharmaceutical company.
For instance, the panel calculates the hourly rate the physicians are earning from the companies, said Dr. James P. Crane, executive vice chancellor for clinical affairs and CEO of the faculty practice plan at Washington University.
"One benchmark we use is how much a physician typically earns in clinical practice, and that varies by specialty," said Crane. "Our upper limit is $500 an hour."
Crane said the university also monitors patterns using its electronic prescribing system to ensure that a doctor isn't prescribing a drug he or she speaks about more than others.
Abramson isn't convinced such measures are good enough because those faculty members also have influence over medical students.
He recalls a student doing a fellowship in rehabilitation and pain medicine at Harvard telling him how he would try to talk to patients about lifestyle changes, only to have physicians come in and prescribe medications instead.
That's the commercial influence on health care, he said.
Dr. H. Gilbert Welch, professor of medicine at the Dartmouth Institute for Health Policy and Clinical Practice says public disclosure such as the ProPublica database is healthy, even if it doesn't always reflect well on his profession.
"Patients need to know it doesn't affect all doctors," he said, "but it certainly highlights the fact that money matters in medicine."
Wednesday, November 3, 2010
The current meaningful use criteria for EHR
The Centers for Medicare and Medicaid Services (CMS) published the final rule regarding EHR technology and qualifications for meaningful use. Measures have been outlined for the initial phase, while more stringent requirements will be detailed through future rulemaking, resulting in a total of 3 stages with expectations that Stage 2 and Stage 3 will be released in 2011 and 2013, respectively.
At the current time, the Stage 1 criteria consists of a total of 25 meaningful use objectives within two categories; a core set of 15 objectives and a menu set of 10 objectives, each with associated measures to determine if the EMR was used in the appropriate number of opportunities. In order to qualify for meaningful use, the eligible provider (EP), eligible hospital (EH) or critical access hospital (CAH) must meet each objective within the core set, as well as five of the objectives from the menu set, which allows for further flexibility while ensuring minimum standards are met. The core set of objectives includes:
•Use computerized physician order entry (CPOE) for all drug orders
•Implement drug to drug and drug allergy interaction checks
•E-Prescribing (EP only)
•Record demographics
•Maintain an up-to-date problem list
•Maintain active medication list
•Maintain active medication allergy list
•Record and chart changes in vital signs
•Record smoking status
•Implement one clinical decision support rule
•Report clinical quality measures (CQM)
•Electronically exchange key clinical information
•Provide patients with an electronic copy of their health information
•Provide patients with an electronic copy of their discharge instructions (EH/CAH Only)
•Provide clinical summaries for patients for each office visit (EP Only)
•Protect electronic health information created or maintained by certified EHR
In addition to these core set of measurements, the menu set of objectives require a total of 5 be completed within 2011-2012, which allows for the deferment of the remaining 5 to later phases of the incentive program. The menu set of objectives includes:
•Implement drug formulary checks
•Incorporate clinical lab test results into certified EHR technology as structured data
•Generate patient lists by condition
•Identify patient-specific education resources and provide to patient as appropriate
•Perform medication reconciliation between care settings
•Provide summary of care record for referred or transitioned patients
•Submit electronic immunization data to registries
•Submit electronic syndromic surveillance data to public health agencies
•Send care reminders to patients per patient preference (EP only)
•Provide timely patient electronic access to health information (EP only)
•Record advance directives for patients 65 years and older (EH/CAH only)
•Submit electronic data on reportable laboratory results to public health agencies (EH/CAH only)
The CMS final rule including the requirements and measures for these objectives, as well as payment rates and necessities for the EHR incentive program can be found on the CMS website at: http://www.cms.gov/ehrincentiveprograms/
At the current time, the Stage 1 criteria consists of a total of 25 meaningful use objectives within two categories; a core set of 15 objectives and a menu set of 10 objectives, each with associated measures to determine if the EMR was used in the appropriate number of opportunities. In order to qualify for meaningful use, the eligible provider (EP), eligible hospital (EH) or critical access hospital (CAH) must meet each objective within the core set, as well as five of the objectives from the menu set, which allows for further flexibility while ensuring minimum standards are met. The core set of objectives includes:
•Use computerized physician order entry (CPOE) for all drug orders
•Implement drug to drug and drug allergy interaction checks
•E-Prescribing (EP only)
•Record demographics
•Maintain an up-to-date problem list
•Maintain active medication list
•Maintain active medication allergy list
•Record and chart changes in vital signs
•Record smoking status
•Implement one clinical decision support rule
•Report clinical quality measures (CQM)
•Electronically exchange key clinical information
•Provide patients with an electronic copy of their health information
•Provide patients with an electronic copy of their discharge instructions (EH/CAH Only)
•Provide clinical summaries for patients for each office visit (EP Only)
•Protect electronic health information created or maintained by certified EHR
In addition to these core set of measurements, the menu set of objectives require a total of 5 be completed within 2011-2012, which allows for the deferment of the remaining 5 to later phases of the incentive program. The menu set of objectives includes:
•Implement drug formulary checks
•Incorporate clinical lab test results into certified EHR technology as structured data
•Generate patient lists by condition
•Identify patient-specific education resources and provide to patient as appropriate
•Perform medication reconciliation between care settings
•Provide summary of care record for referred or transitioned patients
•Submit electronic immunization data to registries
•Submit electronic syndromic surveillance data to public health agencies
•Send care reminders to patients per patient preference (EP only)
•Provide timely patient electronic access to health information (EP only)
•Record advance directives for patients 65 years and older (EH/CAH only)
•Submit electronic data on reportable laboratory results to public health agencies (EH/CAH only)
The CMS final rule including the requirements and measures for these objectives, as well as payment rates and necessities for the EHR incentive program can be found on the CMS website at: http://www.cms.gov/ehrincentiveprograms/
Tuesday, September 28, 2010
Business before safety?
Scans are very big business for medical practices so stories like this make you wonder...
Feds reopen probe into medical scanner approvals. Scientists say they were pressured to approve harmful medical scanners
By MATTHEW PERRONE
WASHINGTON — Federal inspectors have reopened an investigation into complaints by Food and Drug Administration scientists who say they were pressured by their managers to approve high-tech medical scanners that could pose harm to patients.
The lead inspector overseeing the matter told The Associated Press on Tuesday that the inquiry into the allegations, which were dismissed in February, is being revisited to look at manager misconduct.
"The original intent of the investigation was to look at criminal matters and our agents did that," said Gerald Roy, deputy inspector general for investigations in the Department of Health and Human Services. "But I point toward broader issues that really compelled me to take a second look at this and reopen it from an administrative perspective."
The HHS office of inspector general, which oversees the FDA, closed the case in February after finding there was "no violation of law."
But the whistleblowers have repeatedly stressed that their grievances involve mismanagement and violations of regulations — which don't fall under criminal law.
Nine FDA medical device reviewers alleged in 2008 that agency management overruled their opinions without supporting evidence and tried to intimidate them when they went public with their concerns.
At issue are CT scanners, MRI machines and other medical devices that use radiation to detect or treat diseases. Many of the devices allow lifelike pictures of the human anatomy, but carry a higher risk from radiation than older scans such as X-rays
Hundreds of cases of radiation overdoses
In recent years, hundreds of radiation overdoses have been reported with imaging devices used by hospitals across the country. The whistleblowers say these problems underscore the concerns they raised about such devices.
The new probe comes after prodding from lawmakers and nonprofit watchdog groups, including the Project for Government Oversight. In a letter to the inspector general Tuesday, the group calls the previous investigation a "sham."
"If these allegations are true, the FDA is failing in its primary mission of keeping people safe," said Danielle Brian, the group's executive director.
An agency spokeswoman said she could not immediately provide comment Tuesday.
Since the FDA whistleblowers went public with their concerns — in letters to Congress and the Obama administration in 2008 and 2009 — at least two scientists have been let go and another has quit after alleged intimidation.
Interviews with the staffers and internal e-mails obtained by The Associated Press provide new details of alleged mismanagement in the FDA's device division.
Central to the scientists' complaints is an FDA pathway to approval that allows speedy clearance if a device appears comparable to others already on the market.
Former FDA reviewer Dr. Gamal Akbani repeatedly recommended against clearing radiation-emitting devices used to treat cancer under the accelerated system, saying the devices needed to undergo actual testing to prove their safety and effectiveness. Between 2007 and 2008, Akbani said he was frequently pressured by supervisors to change his opinion, he said in an interview with The Associated Press.
In the final incident, Akbani's manager asked about the health of his wife, who has cancer, and his son, who was born severely handicapped. According to Akbani, the manager suggested his job — and health insurance for his family — would be safe as long as he cooperated with his supervisors.
"It shook me to the core because I realized that he was coercing me," said Akbani, who resigned from the FDA and currently teaches nuclear physics at Texas A&M University.
Whistleblowers say managers lack expertise
Akbani and other whistleblowers say a key problem at the agency is that managers — who have often spent decades in government — have far less expertise and up-to-date training than the medical reviewers they oversee. Akbani was recruited to the FDA after a decade in the radiology department at Duke University Medical Center.
The whistleblowers also point out that FDA managers are evaluated, in part, on their ability to get speedy reviews of devices, causing them to pressure and sometimes overrule scientists who slow down the process.
In another case of alleged retaliation, an Oxford-trained medical specialist's contract was not renewed after he repeatedly opposed approving a CT scanner for routine colon cancer screening. Dr. Julian Nicholas said that he objected to exposing otherwise healthy patients to the cancer risks of radiation. He says he was ridiculed by agency managers for "raising the bugaboo of radiation."
"They conspired against me because I refused to change my expert medical opinion to conform with their desired regulatory outcome," Nicholas wrote in an e-mail to FDA Commissioner Margaret Hamburg after his termination late last year.
Both Akbani and Nicholas say they were never contacted by the office of inspector general, which they say makes the inspectors' original report flawed and incomplete.
The inspector general's office issued a memo to FDA leadership in February when it concluded there had been no criminal violations.
The whistleblowers complain that FDA officials have used the four-page memo to try to dissuade members of Congress from looking into their allegations.
Robert Smith, a former radiology division reviewer who left the agency in July, said FDA leadership assured the whistleblowers that the investigation would be comprehensive.
"It was the FDA's responsibility to make sure the investigation they requested was properly conducted and reported," Smith said, "And it was the responsibility of the inspector general to conduct a legitimate investigation — which they know they did not."
Feds reopen probe into medical scanner approvals. Scientists say they were pressured to approve harmful medical scanners
By MATTHEW PERRONE
WASHINGTON — Federal inspectors have reopened an investigation into complaints by Food and Drug Administration scientists who say they were pressured by their managers to approve high-tech medical scanners that could pose harm to patients.
The lead inspector overseeing the matter told The Associated Press on Tuesday that the inquiry into the allegations, which were dismissed in February, is being revisited to look at manager misconduct.
"The original intent of the investigation was to look at criminal matters and our agents did that," said Gerald Roy, deputy inspector general for investigations in the Department of Health and Human Services. "But I point toward broader issues that really compelled me to take a second look at this and reopen it from an administrative perspective."
The HHS office of inspector general, which oversees the FDA, closed the case in February after finding there was "no violation of law."
But the whistleblowers have repeatedly stressed that their grievances involve mismanagement and violations of regulations — which don't fall under criminal law.
Nine FDA medical device reviewers alleged in 2008 that agency management overruled their opinions without supporting evidence and tried to intimidate them when they went public with their concerns.
At issue are CT scanners, MRI machines and other medical devices that use radiation to detect or treat diseases. Many of the devices allow lifelike pictures of the human anatomy, but carry a higher risk from radiation than older scans such as X-rays
Hundreds of cases of radiation overdoses
In recent years, hundreds of radiation overdoses have been reported with imaging devices used by hospitals across the country. The whistleblowers say these problems underscore the concerns they raised about such devices.
The new probe comes after prodding from lawmakers and nonprofit watchdog groups, including the Project for Government Oversight. In a letter to the inspector general Tuesday, the group calls the previous investigation a "sham."
"If these allegations are true, the FDA is failing in its primary mission of keeping people safe," said Danielle Brian, the group's executive director.
An agency spokeswoman said she could not immediately provide comment Tuesday.
Since the FDA whistleblowers went public with their concerns — in letters to Congress and the Obama administration in 2008 and 2009 — at least two scientists have been let go and another has quit after alleged intimidation.
Interviews with the staffers and internal e-mails obtained by The Associated Press provide new details of alleged mismanagement in the FDA's device division.
Central to the scientists' complaints is an FDA pathway to approval that allows speedy clearance if a device appears comparable to others already on the market.
Former FDA reviewer Dr. Gamal Akbani repeatedly recommended against clearing radiation-emitting devices used to treat cancer under the accelerated system, saying the devices needed to undergo actual testing to prove their safety and effectiveness. Between 2007 and 2008, Akbani said he was frequently pressured by supervisors to change his opinion, he said in an interview with The Associated Press.
In the final incident, Akbani's manager asked about the health of his wife, who has cancer, and his son, who was born severely handicapped. According to Akbani, the manager suggested his job — and health insurance for his family — would be safe as long as he cooperated with his supervisors.
"It shook me to the core because I realized that he was coercing me," said Akbani, who resigned from the FDA and currently teaches nuclear physics at Texas A&M University.
Whistleblowers say managers lack expertise
Akbani and other whistleblowers say a key problem at the agency is that managers — who have often spent decades in government — have far less expertise and up-to-date training than the medical reviewers they oversee. Akbani was recruited to the FDA after a decade in the radiology department at Duke University Medical Center.
The whistleblowers also point out that FDA managers are evaluated, in part, on their ability to get speedy reviews of devices, causing them to pressure and sometimes overrule scientists who slow down the process.
In another case of alleged retaliation, an Oxford-trained medical specialist's contract was not renewed after he repeatedly opposed approving a CT scanner for routine colon cancer screening. Dr. Julian Nicholas said that he objected to exposing otherwise healthy patients to the cancer risks of radiation. He says he was ridiculed by agency managers for "raising the bugaboo of radiation."
"They conspired against me because I refused to change my expert medical opinion to conform with their desired regulatory outcome," Nicholas wrote in an e-mail to FDA Commissioner Margaret Hamburg after his termination late last year.
Both Akbani and Nicholas say they were never contacted by the office of inspector general, which they say makes the inspectors' original report flawed and incomplete.
The inspector general's office issued a memo to FDA leadership in February when it concluded there had been no criminal violations.
The whistleblowers complain that FDA officials have used the four-page memo to try to dissuade members of Congress from looking into their allegations.
Robert Smith, a former radiology division reviewer who left the agency in July, said FDA leadership assured the whistleblowers that the investigation would be comprehensive.
"It was the FDA's responsibility to make sure the investigation they requested was properly conducted and reported," Smith said, "And it was the responsibility of the inspector general to conduct a legitimate investigation — which they know they did not."
Saturday, August 28, 2010
Where is the annual $2.3 trillion in healthcare spending going?
According to recent data from the Centers for Medicare & Medicaid Services (CMS) the breakdown of who receives the $2.3 trillion of the healthcare spending in the US. looks something like this:
Hospitals $718 billion
Physician & Clinical services $496 billion
Prescription drugs $234 billion
Administrative costs $159 billion
Nursing homes $138 billion
Structure & equipment $113 billion
Dental $101 billion
Government public health $69 billion
Other personal health $68 billion
Other professional $65 billion
Home health $64 billion
Research $43 billion
OTC's and related products $39 billion
Durable medical equipment $26 billion
Hospitals $718 billion
Physician & Clinical services $496 billion
Prescription drugs $234 billion
Administrative costs $159 billion
Nursing homes $138 billion
Structure & equipment $113 billion
Dental $101 billion
Government public health $69 billion
Other personal health $68 billion
Other professional $65 billion
Home health $64 billion
Research $43 billion
OTC's and related products $39 billion
Durable medical equipment $26 billion
Saturday, August 21, 2010
Physicians starting a new practice; what needs to be done?
I get a lot of calls from physicians about to enter their own private practice and unsure of all the items that need to be attended to. Here's an article I wrote with a shortlist of the major items, while not comprehensive it at least gives a good starting point.
Establishing a new practice is a lot of work and many details must be dealt with in order for things to go as smoothly as possible – even then, you must allow for “hiccups” in the process. As you begin this endeavor, identify those resources and individuals who can help steer you through all the pitfalls involved in a practice start-up. Key professionals to include are your attorney, accountant, banker and a practice management consultant. You may also need to hire an administrative assistant as early as possible to help you with the blizzard of paperwork involved in setting up a practice - unless you are working with a top notch practice management company, in which case they will typically take care of much of the paperwork on your behalf.
The main things to focus on are:
• Finding a location
• Determining what kind of a legal entity you want your practice to be
• Developing a banking relationship
• Determining which managed care panels are a priority
• Collecting your paperwork in order to begin the credentialing process
• Developing and implementing your billing/collection mechanism
I've found you can just as easily use on-line resources such as nolo.com or legalzoom.com to set up your corporation, however, many physicians prefer using professionals to assist. If you prefer, your attorney and accountant can help complete all the required legal and tax-related paperwork necessary to set up your business, including obtaining an employer identification number (EIN) as its a bad idea to have everything tied to your SSN.
Establishing a line of credit with your banker is a good idea, even if you believe you have enough start-up capital; remember it can be 60 – 90 days, and often longer, after the initial patient visit before insurance checks or electronic payments start coming in, assuming you begin submitting claims right from the start.
As early as possible you must determine which managed care panels you want to apply for and begin the application process, begin with Medicare and continue with the rest. On average, it takes three to four months to go through the credentialing process. It doesn’t matter if you are already credentialed with these plans as you still have to go through the entire process again using your new employer identification number. It’s also a good idea to confirm your admitting privileges at any area hospitals to ensure that they will continue once you start your own practice, especially as you may need this information for credentialing with provider plans.
Once these steps have been dealt with, you have to decide what equipment and furniture you need, you’ll also have to obtain a telephone long distance carrier, pager, cell phone service and or answering service. If you intend accepting credit card payments, you will have to find the appropriate vendors.
The next order of business is to determine how you will bill insurance companies and patients. Your options are to either use your own staff or to use an outside billing service. In-house billing would require purchasing, or leasing, a computer system and practice management software as well as hiring experienced, competent billing and collection staff who also understand CPT coding. Using an outside billing company can cut down some of the in-house headaches of the billing/collection process, especially if it all new to you.
Your decision here is critical to the financial well being of your practice and should be based on several considerations, including the availability of cash to purchase or lease the necessary hardware and software, staff expertise and office space etc. Regardless of your decision, your primary goal is to have a system in place when you see your first patient.
Next, establish accounting and payroll systems, your accountant can help here. You will also need to purchase appropriate professional and office insurance, set up a medical records system, obtain office and medical supplies, develop an office manual and establish OSHA standards.
Staffing is next on the list, first identify the functions that must be accomplished in your practice and develop written job descriptions. Next, determine the qualifications and experience of the people who would be performing the jobs. There is a wealth of information regarding staffing ratios and salary ranges etc available on the internet and via local and national organizations.
Now that you have completed all these steps you have to publicize the opening of your new practice. At a minimum, letters and announcements should be sent to your colleagues, referral sources, patients, family and friends. Other activities should include advertising the practice’s opening in local and internet media as well as developing a web site. These are just some initial ways to get word out about your practice, marketing is an on-going activity and will be dependant on your budget.
Starting a new practice is an exciting albeit cumbersome task. You should allow yourself at least six to nine months to make sure everything gets attended to. The professionals you select to work with you have the resources available to help remove many of the headaches from the process. Good luck!
Establishing a new practice is a lot of work and many details must be dealt with in order for things to go as smoothly as possible – even then, you must allow for “hiccups” in the process. As you begin this endeavor, identify those resources and individuals who can help steer you through all the pitfalls involved in a practice start-up. Key professionals to include are your attorney, accountant, banker and a practice management consultant. You may also need to hire an administrative assistant as early as possible to help you with the blizzard of paperwork involved in setting up a practice - unless you are working with a top notch practice management company, in which case they will typically take care of much of the paperwork on your behalf.
The main things to focus on are:
• Finding a location
• Determining what kind of a legal entity you want your practice to be
• Developing a banking relationship
• Determining which managed care panels are a priority
• Collecting your paperwork in order to begin the credentialing process
• Developing and implementing your billing/collection mechanism
I've found you can just as easily use on-line resources such as nolo.com or legalzoom.com to set up your corporation, however, many physicians prefer using professionals to assist. If you prefer, your attorney and accountant can help complete all the required legal and tax-related paperwork necessary to set up your business, including obtaining an employer identification number (EIN) as its a bad idea to have everything tied to your SSN.
Establishing a line of credit with your banker is a good idea, even if you believe you have enough start-up capital; remember it can be 60 – 90 days, and often longer, after the initial patient visit before insurance checks or electronic payments start coming in, assuming you begin submitting claims right from the start.
As early as possible you must determine which managed care panels you want to apply for and begin the application process, begin with Medicare and continue with the rest. On average, it takes three to four months to go through the credentialing process. It doesn’t matter if you are already credentialed with these plans as you still have to go through the entire process again using your new employer identification number. It’s also a good idea to confirm your admitting privileges at any area hospitals to ensure that they will continue once you start your own practice, especially as you may need this information for credentialing with provider plans.
Once these steps have been dealt with, you have to decide what equipment and furniture you need, you’ll also have to obtain a telephone long distance carrier, pager, cell phone service and or answering service. If you intend accepting credit card payments, you will have to find the appropriate vendors.
The next order of business is to determine how you will bill insurance companies and patients. Your options are to either use your own staff or to use an outside billing service. In-house billing would require purchasing, or leasing, a computer system and practice management software as well as hiring experienced, competent billing and collection staff who also understand CPT coding. Using an outside billing company can cut down some of the in-house headaches of the billing/collection process, especially if it all new to you.
Your decision here is critical to the financial well being of your practice and should be based on several considerations, including the availability of cash to purchase or lease the necessary hardware and software, staff expertise and office space etc. Regardless of your decision, your primary goal is to have a system in place when you see your first patient.
Next, establish accounting and payroll systems, your accountant can help here. You will also need to purchase appropriate professional and office insurance, set up a medical records system, obtain office and medical supplies, develop an office manual and establish OSHA standards.
Staffing is next on the list, first identify the functions that must be accomplished in your practice and develop written job descriptions. Next, determine the qualifications and experience of the people who would be performing the jobs. There is a wealth of information regarding staffing ratios and salary ranges etc available on the internet and via local and national organizations.
Now that you have completed all these steps you have to publicize the opening of your new practice. At a minimum, letters and announcements should be sent to your colleagues, referral sources, patients, family and friends. Other activities should include advertising the practice’s opening in local and internet media as well as developing a web site. These are just some initial ways to get word out about your practice, marketing is an on-going activity and will be dependant on your budget.
Starting a new practice is an exciting albeit cumbersome task. You should allow yourself at least six to nine months to make sure everything gets attended to. The professionals you select to work with you have the resources available to help remove many of the headaches from the process. Good luck!
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