Happy Qualiween!

Protect your agency from Medicaid take-backs

In these lean times when budgets are stretched thin and belts are being tightened, agencies with inadequate compliance processes are being caught in charges of Medicaid waste, fraud and abuse.

A high-profile civil fraud lawsuit was filed and settled against the Westchester County Health Care Corporation’s Behavioral Health Center in Valhalla, New York, this week. The BHC provides outpatient behavioral health services to children, adolescents and adults who are mentally ill or suffer from psychiatric or emotional conditions. According to the press release:

Medicaid, which reimburses providers for the cost of care for its recipients, paid millions of dollars in reimbursement for claims submitted by WMC for these mental health services. As such, it must comply with Medicaid regulations. Those regulations expressly require that mental health outpatient clinics maintain certain documents, including progress notes and treatment plans, to ensure that billed services are actually provided, and that the providers are in compliance with the regulations. From August 2001 through June 2010, WMC repeatedly billed Medicaid for outpatient mental health services without having the core documentation required by the Medicaid regulations in order to bill for those services.

Community behavioral health providers literally cannot afford to submit error-filled claims that are subject to costly take-backs. What is the answer to this dilemma?

A comprehensive, fully-integrated electronic health record will naturally verify and validate that an agency meets each clinical and billing requirement to meet the funding source’s reimbursement rules. If there is inaccurate data or missing information, the system won’t release the claim, thereby eliminating risk for the provider.

An EHR like CareLogic Enterprise accommodates these processes with ease:

• Claims are automatically generated when a service is kept, and all client information and documentation automatically flow into the billing engine without any manual intervention once the clinician completes the service.
• Claims are automatically generated and run through a series of 50 checks including service authorization, correct client demographics and required clinical information.
• Built-in alerts notify the billing office, the clinician and the supervisor of inaccurate data or missing information.
• Standard 837 P-I and 835 files for electronic claims submission and payment.
• All major billing formats and specialized formats for hundreds of payers are supported.

Jeni Woods, former compliance officer with Albertina Kerr Centers in Portland, OR, and now corporate training manager at Qualifacts explains why this example of a behavioral healthcare provider being required to refund large amounts of money for missing clinical documentation is a perfect illustration of the critical importance of implementing an effective EHR:

As a compliance officer you strive to reduce the risk in your agency, and billing and clinical documentation is one of the highest areas of risk. An EHR that effectively reduces that risk gives an agency one less thing to worry about, and more time to spend providing quality care. CareLogic does a lot of the compliance work for you because the compliance configurations in CareLogic require that the necessary completed documentation is associated with every service that is provided before a claim is sent out the door. This is a compliance officer’s dream!

Do you have your individual Medicaid provider ID number?

Even though most state Medicaid Offices do not require that a rendering provider have their own individual Medicaid ID number in order to provide services at your agency, the final 2011 rules from CMS require that all Eligible Professionals who want to participate in any of the EHR Incentive Programs must have an active individual Medicaid Provider ID number.

If any/all of your Eligible Providers are without this number, there’s still time to get started:

• Ask each EP or call your state Medicaid contact and ask how many of your providers have their own individual Medicaid ID number. You will need their NPI number in order to do this.
• Once you have established that each EP has an individual Medicaid Provider ID number, you will need to make sure that the individual Medicaid numbers are linked to your group Medicaid provider numbers. This is critical for Medicaid to be able to reconcile the Medicaid patient volume numbers each EP submits.
• If an EP does not have an individual Medicaid Provider ID number, they must get one. In most states, the process for getting an individual Medicaid Provider ID number is the same for providers that want to get one in order to be able to provide services to Medicaid members. A few states have set up a special process for providers who only want a Medicaid Provider ID number in order to participate in the MU programs:
  • Georgia
  • New Jersey
  • Pennsylvania

If you don’t know how to get your EP an individual number, contact me for specific instructions.

It’s Mental Illness Awareness Week

For Mental Illness Awareness Week, Oct 7-13, the National Council has created some special treats for us all to share. Here are a few of the adorable images they have created–reminding us that ghouls have feelings too!  Find all 5 on their website!

Qualifacts at the Table: ONC releases Behavioral Health IT Roundtable report

David Klements, CEO Qualifacts

Last week, the Office of the National Coordinator for Health Information Technology (ONC) released a report on the health information technology needs of behavioral health providers. The report reflects behavioral health stakeholder comments and recommendations from a day-long meeting held on July 24, 2012.

I was invited to represent Qualifacts at that meeting, one of only four EHR vendors invited to attend, and I wanted to share my experience. In total, there were 25 participants from HIEs, federal partners, certifying bodies, standards experts, foundations, EHR vendors, innovators and consumers.

The goal of the meeting was to help the ONC identify priority action items to ensure the needs of behavioral health stakeholders were incorporated into policy planning, specifically around Meaningful Use.  It’s clear that the arcane federal privacy and consent regulations (specifically 42 CFR), combined with current limitations in HIE software, present the biggest barrier facing behavioral health providers’ integration into the broader healthcare IT landscape. The key discussion topics were:

• What HIT capabilities do behavioral health and primary care providers need to better support integration across care settings?
• What HIT capabilities do behavioral health care providers need in order to support current care practices? To support person-centered approaches to care?
• How do the proposed Stage 2 Meaningful Use criteria, certification criteria, and related standards align with the range of behavioral health and primary care providers’ needs?

Overall, there were a lot of passionate people (no surprise there) who made some interesting points about (a) meaningful use needing to be more focused on increasing consumer engagement, (b) ensuring EHRs provide real-time and relevant clinical information, and (c) the need for better coordination on reporting requirements (eliminate unnecessary redundancies).

It was a lively discussion and I left knowing Qualifacts would continue to take the lead on informing the behavioral health community on the initiatives supporting the move to a national health information network.  The first of these initiatives will be Meaningful Use Stage 2 and how these requirements can fit seamlessly into clinical workflows.

In case you hadn’t heard, the CareLogic user community has received more meaningful use incentives than any other behavioral health EHR customer base – more than $5 million to-date. I believe our collective success with stage 1 highlights the value of a single platform, Software-as-a-Service business model.   At the end of the day, one of primary reasons Qualifacts’ customers have garnered more than $5 million in meaningful use incentives is because everyone is on the same platform – there are no versions of CareLogic to complicate things.

I truly believe that as behavioral health integrates with physical health and as major system changes including stage 2, coordinated care, DSM-5 and ICD-10 come to pass, our single platform approach will enable Qualifacts to quickly and accurately deploy these new requirements and capabilities, thereby helping our customers to continue to lead in their communities, improve quality care and serve more people.

I encourage you to take a look at the ONC report, and let us know what you think.

David Klements, CEO
Qualifacts

Welcome Aboard

Qualifacts’ CareLogic Enterprise continues to be the fastest growing cloud-based electronic health record for behavioral health. We would like to extend a big Qualifacts welcome to the new customers who signed with us in September:

ILLINOIS
Wellspring Resources | Alton, IL

MARYLAND
Baltimore Community Resource Center | Baltimore, MD

NEW JERSEY
The unique Qualifacts collaborative implementation model continues to be a hit in New Jersey with two collaboratives live on the CareLogic EHR and these agencies coming together to form a new one:

Comprehensive Behavioral Healthcare, Inc. | Lyndhurst, NJ

North Jersey Friendship House | Hackensack, NJ

The Occupational Center of Union County | Roselle, NJ

Two Illinois Customers Receive Grants for Integrated Care

We were thrilled to learn that two of our customers in Illinois – DuPage County Health Department and Lutheran Social Services of Illinois – received demonstration project grants under the Illinois Behavioral Health Integration Project (BHIP).

According to Laura Zaremba, director, Office of Health Information Technology, “The award of these grants will accelerate Illinois’ progress toward using health information exchange to achieve better health care and support care coordination.”

DuPage, a licensed Illinois behavioral health provider, received a grant of $39,600 for their project with VNA Health Care, a community-based medical provider, to integrate behavioral health and medical services to support severely mentally ill individuals in the community. DuPage and VNA plan to use ILHIE to share pertinent behavioral health and medical information about individuals who receive care from both agencies.

LSSI received $45,000 for the electronic exchange of data from inpatient to outpatient services for youth with harm to self/harm to others conditions and the SASS population.

Joe Dickason, product manager for Qualifacts, explained that existing functionality in the CareLogic Enterprise electronic health record that both organizations are using will help facilitate these projects. The continuity of care document’s create/download and PDF reports for service documents will be used. The documents will be downloaded locally, then be sent as attachments to partners using the IL-HIE e-mail system via Direct protocol.

Read the full press release here.