According to the Congressional Research Service (CRS) Report, Medicare Provisions in the Patient Protection and Affordable Care Act (PPACA), the CMI would work in conjunction with the Patient-Centered Outcomes Research Institute (PCORI), also created under the Patient Protection and Affordable Care Act (PPACA), "to generate new information about how alternative treatments affect patient outcomes as well as evidence to support how different payment methods might alter the incentives for providers and the outcomes for patients."

Also according to the CRS report, "successful models could be expanded nationally. The CBO (Congressional Budget Office) estimates that this provision will lead to an additional savings of $1.3 billion over 10 years." The report concludes that "in the long run, these provisions combined have the potential to be the most substantial of the PPACA and the Reconciliation Act modifications affecting physicians and related providers." AAOMS will continue to monitor these issues to keep the membership informed.

The Interim Final Rule also includes requirements about keeping, for a time period of seven years, written documentation of orders and referrals made and/or received. The documentation must include the NPI of the ordering or referring provider and must be made available to Medicare when requested to avoid penalties including a one-year suspension of Medicare billing privileges. In addition, the IFR requires that providers include the NPI on any enrollment applications to Medicare and Medicaid, as well as on any payment claims. For more information on the recent PECOS rule, possible earlier deadline and record keeping requirements visit the Medicare Enrollment news on the AAOMS web site.

Level II compliance, required by December 31, 2011, means that a "covered entity has completed end-to-end testing with each of its trading partners, and is able to operate in production mode with the new versions of the standards." CMS states that the transition period when both versions would be allowed in production mode for Medicare will be from January 1, 2011 - December 31, 2011. The 835v4010A1 and the current Standard Paper Remittance (SPR) should not be sent on or after January 1, 2012, irrespective of the date of receipt or date of service reported on the electronic or paper claim. For more information visit the Transaction and Code Set Standards page of the CMS web site. OMSs should share this information with their software vendors to ensure compliance and prevent payment lapses.

On October 1, 2013, medical coding in U.S. health care settings will change from ICD-9 to ICD-10. The transition will require business and systems changes throughout the health care industry. Everyone who is covered by the Health Insurance Portability and Accountability Act (HIPAA) must make the transition, not just those who submit Medicare or Medicaid claims.

The first ICD-10-related compliance date is less than 2 years away. On January 1, 2012, standards for electronic health transactions change from Version 4010/4010A1 to Version 5010. Unlike Version 4010, Version 5010 accommodates the ICD-10 code structure. This change occurs before the ICD-10 implementation date to allow adequate testing and implementation time.

The compliance dates are firm and not subject to change. If you are not ready, your claims will not be paid. Preparing now can help you avoid potential reimbursement issues.

Basic Steps to Prepare for Version 5010/ICD-10

Begin preparing now for the ICD-10 transition to make sure you are ready by the October 1, 2013, compliance deadline. The following quick checklist will assist you with preliminary planning steps.

• Identify your current systems and work processes that use ICD-9 codes. This could include clinical documentation, encounter forms/superbills, practice management system, electronic health record system, contracts, and public health and quality reporting protocols. It is likely that wherever ICD-9 codes now appear, ICD-10 codes will take their place.

• Talk with your practice management system vendor about accommodations for both Version 5010 and ICD-10 codes. Contact your vendor and ask what updates they are planning to your practice management system for both Version 5010 and ICD-10, and when they expect to have it ready to install. Check your contract to see if upgrades are included as part of your agreement. If you are in the process of making a practice management or related system purchase, ask if it is Version 5010 and ICD-10 ready.

• Discuss implementation plans with all your clearinghouses, billing services, and payers to ensure a smooth transition. Be proactive, don't wait. Contact your payers, clearinghouse, billing service with whom you conduct business, ask about their plans for the Version 5010 and ICD-10 compliance, and when they will be ready to test their systems for both transitions.

• Talk with your payers about how ICD-10 implementation might affect your contracts. Because ICD-10 codes are much more specific than ICD-9 codes, payers may modify terms of contracts, payment schedules, or reimbursement.

• Identify potential changes to work flow and business processes. Consider changes to existing processes including clinical documentation, encounter forms, and quality and public health reporting.

• Assess staff training needs. Identify the staff in your office who code, or have a need to know the new codes. There are a wide variety of training opportunities and materials available through professional associations, online courses, webinars, and onsite training. If you have a small practice, think about teaming up with other local providers. You might be able, for example, to provide training for a staff person from one practice, who can in turn train staff members in other practices. Coding professionals recommend that training take place approximately 6 months prior to the October 1, 2013 compliance date.

• Budget for time and costs related to ICD-10 implementation, including expenses for system changes, resource materials, and training. Assess the costs of any necessary software updates, reprinting of superbills, training and related expenses.

• Conduct test transactions using Version 5010/ICD-10 codes with your payers and clearinghouses. Testing is critical. Allow yourself enough time to first test that your Version 5010 transactions, and subsequently, claims containing ICD-10 codes are being successfully transmitted and received by your payers, clearinghouses, etc. Check to see when they will begin testing, and the test days they have scheduled. See the "Compliance Timelines" link below for important interim deadline information.

OSHA is interested in strategies that are being used in such healthcare and other healthcare-related work settings to ease the risk of occupationally-acquired infectious diseases. OSHA would like to collect information and data on the facilities and the tasks potentially exposing workers to this risk; successful employee infection control programs; control methodologies being utilized (including engineering, work practice, and administrative controls and personal protective equipment); medical surveillance programs; and training. OSHA will use the information received to determine what action, if any, the Agency may take to further limit the spread of occupationally-acquired infectious diseases in these types of settings. Comments must be submitted by August 4, 2010. For more information, please visit www.osha.gov.

Acceptable methods include the following:

1. Provide a legible full signature (a readable first name and last name).
2. Provide a legible first initial and last name.
3. Write an illegible signature over a typed or printed name.
4. Write an illegible signature on letterhead with information indicating the identity of the signer. Example: There's an illegible signature appearing on a prescription. The letterhead of the prescription lists three physician names, one of which is circled - thus indicating the identity of the signer.
5. Use an illegible signature accompanied by a signature log or attestation statement.
6. Write initials over a typed or printed name.
7. Write initials not over a typed or printed name, but accompanied by a signature log or attestation.
8. Neglect to sign a portion of a handwritten note, but other entries on the same page in the same handwriting are signed.

Unacceptable methods are below:

1. Use an illegible signature not over a typed name or on a letterhead, without a signature log or attestation statement.
2. Write initials, but leave out a typed name without a signature log or attestation statement.
3. Forget to sign a typed note that includes the provider's typed name.
4. Neglect to sign a typed note that does not include the provider's typed or printed name.
5. Neglect to sign a handwritten note with no other entries on the page.
6. Use the words "signature on file" in lieu of a signature.
7. Use a signature stamp.

More information including some exceptions to the rule may be found in the transmittal.

• Dentists - While the guidance acknowledges that most dentists do not enroll in Medicare, it states dentists are of a specialty that is eligible to order and refer items or services for Medicare beneficiaries (e.g., to send specimens to a laboratory for testing) and to do so a dentist must be enrolled in Medicare. A dentist may enroll by filling out the paper CMS-855I or online via the Internet-based Provider Enrollment, Chain and Ownership System (PECOS) and must include a covering note with the paper application or with the paper Certification Statement that is generated when submitting a web-based application that states that they are enrolling in Medicare only to order and refer. They will not be submitting claims to Medicare for services they furnish to Medicare beneficiaries. This is good information for OMSs to share with their referring dentists.

• Opted Out Providers - OMSs that have opted out of Medicare may still order items or services for Medicare beneficiaries. Their opt-out information must be current (an affidavit must be completed every 2 years, and the NPI is required on the affidavit). Opt-out practitioners whose affidavits are current should have enrollment records in PECOS that contain their NPIs.

• ABN - Billing Providers should be aware that claims that are rejected because they failed the Ordering/Referring Provider edits are not denials of payment by Medicare that would expose the Medicare beneficiary to liability. Therefore, an Advance Beneficiary Notice is not appropriate.

• Due Diligence by Billing Providers - CMS is instructing billing providers to use due diligence to ensure that the physicians and non-physician practitioners from whom orders and referrals are accepted have current Medicare enrollment records (i.e., they have enrollment records in PECOS that contain their NPIs) and are of a type/specialty that is eligible to order or refer in the Medicare program. CMS has made available a downloadable PDF file of National Provider Identifiers (NPIs) and names (last name, first name) of all physicians and non-physician practitioners meeting these criteria. OMSs are encouraged to check this list to see if those from whom referrals for services are received, are in fact listed.

The final phase of the rule goes into effect January 3, 2011, postponed from the original effective date of January 1, 2010 and later postponed until April 5, 2010. For more information see CMS Change Requests (CR) 6417 and Internet-based PECOS system, regardless as to when enrolled in Medicare.