What we need is for people to submit a comment, and to spread the word that hyperbaric oxygen therapy is in a crisis.
Blog Posts by Caroline Fife, MD
Your EHR will need to be modified to meet the DME documentation requirement burden (and if you think the list below is ridiculous – it is, but it’s still required).
A recent Ebola outbreak in Dallas was blamed on a “flaw” in the hospital’s electronic health record (EHR). Yes, you heard me correctly.
Observations About the 2024 PFS Pertaining to Cellular and/or Tissue-Based Products in the Doctor’s Office Setting
On July 13, 2023, CMS issued proposed rules for the 2024 Physician Fee Schedule (PFS) and the Hospital Outpatient Prospective Payment System (OPPS).
Attorney Knicole Emanuel has posted a chilling blog on her site about hidden RAC (Recovery Audit Contractor) audits.
On your drive home, check out this podcast with Helen Gelly MD, FUHM, FACCWS, UHM/ABPM, “How to Get Your Wound Clinic Through an Audit.”
We need individuals at all training levels to comment on the proposed changes that CMS is proposing in the Medicare Physician Fee Schedule (MPFS) for the technical payment of HBOT.
Three Medicare Administrative Contractors (MACs) issued their final Local Coverage Determinations (LCDs) for Cellular and/or tissue-based products (CTPs).
You should read the documents yourself, but here are some highlights of the 2024 OPPS proposed rule (in no particular order).
PRESS RELEASE: New Study in Journal of Medical Economics Shows Decrease in Chronic Wound Medicare Costs Amid Increase in Chronic Wound Prevalence
Over 2014-2019, the number of Medicare beneficiaries with chronic wounds increased 13% to 10.5 million amid a surprising 20% reduction in chronic wound expenditures. Researchers seek to explain why, and what the policy implications may be.
I am highly suspicious that this is being driven by the manufacturers of CTPs, and is yet another indication that the CTP industry is out of control.
Here’s a doctor who knows his days are numbered, and he’s making the most of every one because he has a purpose.
HIPAA Does NOT Require That Healthcare Providers Obtain Patient Authorization to Disclose Protected Health Information (PHI) to Other Clinicians for Treatment Purposes
HIPAA does NOT require that health care providers obtain patient authorization to disclose protected health information (PHI) to other clinicians for treatment purposes.
In Knicole Emanuel’s latest blog, she discusses the new Medicare rules stating that no extrapolation may be run if the error rate is under 50%.
The Big Picture of Physician Payment Within CMS The big picture is still playing out for physician...
The LTA will improve insurance coverage for the medically necessary, doctor-prescribed compression supplies that are the cornerstone of lymphedema treatment.
Medicare Posts Final Rule for 2024 Policy Changes to Medicare Advantage Plans – Review of Medical Necessity Requirements
Undersea and Hyperbaric Medicine IS a recognized medical subspecialty so that might help patients obtain necessary HBOT treatments.
The rule goes into effect Jan 1, 2024. Whether this will make MA less of a Medicare DIS-advantage is yet to be seen.
CMS Published 2023 Medicare/caid Health Care Providers’ Audit Process – Read Attorney Knicole Emanuel’s Offer to Clinicians Being Audited
Nearly every wound care and hyperbaric medicine practitioner is undergoing some sort of Medicare audit.
Wound Care Services and the Jimmo Settlement – Why it Matters to Patients Who Are in Palliative Wound Care
Unfortunately, some Medicare auditors are not following the law as it pertains to the presence or absence of a beneficiary’s potential for improvement.
There are no federal regulatory prohibitions on the use of verbal orders, although CMS frowns upon verbal orders in the context of medications.
A self-audit is a miserable “gift” to give yourself, but a real audit is a gift that just keeps on giving when you are not prepared.
In its effort to debunk regulatory myths, the American Medical Association (AMA) has produced this useful fact sheet, “Who can document components of E/M services?”
The AMA reminds physicians that that there is no requirement to document the total time spent if the physician is not using time to calculate the level of service.
The American Medical Association (AMA) has been debunking several myths in a project called “Debunking Regulatory Myths.”
The Centers for Medicare & Medicaid Services (CMS) has opened the data submission period for Merit-based Incentive Payment System (MIPS) eligible clinicians who participated in the 2022 performance year of the Quality Payment Program (QPP).
A new post by attorney Knicole Emanual is vitally important for anyone under a Medicare audit.
Check out this article by Kathleen Schaum in Today’s Wound Clinic: Are You Prepared to Implement the 2023 CTP Final Rules?
On January 30, 2023, the Biden-Harris Administration announced its intent to end the national emergency and public health emergency (PHE) declarations related to the COVID-19 pandemic on May 11, 2023.
Are you feeling frustrated and helpless in the face of overwhelming regulatory burdens, capricious...
The way these audits work, it’s assumed you are guilty and you have to prove you are not – in a one way conversation.
Not only do you need to document the goals of therapy, but you need to document whether your treatments are achieving them.
Healing does not have to be the goal, but if not, we had better state goals like, “getting the wound to a state in which the patient and family can care for it with only periodic physician assessment,” or “preventing progression and hospitalization.”
I am going to discuss the wound care policy that’s been in effect since 07/23/2020 for the Novitas jurisdiction.
The full attention of every aspect of CMS is now focused on the use of CTPs. Why do you think that is?
Sweeping changes are proposed for cellular and/or tissue-based products (CTPs) when applied in the physician’s office.
If you want to know what topics the Centers for Medicare and Medicaid Services (CMS) are auditing,...
Kathleen Schaum provided the first of 4 free sessions on "Keeping your Payment after an Audit."...
In case you think you are safe because you live in another MAC jurisdiction, it’s the same as the First Coast policy and it won’t surprise me to see all the MACs adopt the same (flawed) policies.
This is Part 4 of the list of what you need to document (per the proposed rule) if you want to use a skin substitute (CTP) for a DFU or VLU.
Novitas is going to limit clinicians to 2 applications of a “specific skin substitute” over the 12-week period defined by the date of the first application.
I am not even halfway through the details of the proposed policy, so stay tuned for more.
If you want to present comments on any of the proposed policies in the Novitas LCD, sign up to attend the Open Meeting.
The Department of Justice and the Drug Enforcement Agency Announce New Searchable Portals for “Guidance Documents”
This portal contains a single, searchable, indexed database that contains links to all DEA guidance documents.
I will be the first to admit that I did a bad job recognizing and treating nutritional deficits in...
As wound care begins to shift into the private doctor’s office – doctors are not going to be able to just may paybacks without a fight.
“Maybe it’s time to switch our telescopic lens from auditing providers to auditing MCOs and MAs. Let’s get these RAC, ZPIC, and TPE auditors focused on the stewards of our tax dollars, the prepaid entities.”
Wound care terminology & diagnosis codes haven’t changed since 1991, but wound care technology definitely has.
Dr. David Charash has just put out an article in Today’s Wound Clinic describing his experience with a TPE (Targeted Prove and Educate) audit. Check it out!
Targeted Probe and Educate (TPE) audits were briefly suspended for COVID-19, but now they are back.
Great opportunities to advance wound care knowledge, this week in Philadelphia!
In this game, you may find out the rules only when someone gets a penalty.
CMS Releases the Final Rules of the Medicare Physician Fee Schedule and the Hospital Outpatient Payment System
CMS has released the final rules of the Medicare Physician Fee Schedule (MPFS) and the Hospital Outpatient Payment System (HOPPS).
Free Access to a Review Article on the Development & Treatment of Lymphatic Dysfunction in Cancer Patients
Check out this Open Access review article on the development and treatment of lymphatic dysfunction in cancer patients.
Benchmarking allows you to visualize whether you might raise a red flag with an auditor, since we know they have been auditing debridement services.
The MACs have been auditing wound debridements. I thought it might be useful to understand the history of debridement audits.
Severe pressure injuries continue to occur at a predictable rate, particularly among critical care patients. There’s a reason.
These proposed “rules” are hundreds of pages and filled with jargon. However, the details will control how physicians get paid in 2022.
Let’s take a look at the ways in which proper nutrition can be an invaluable part of the wound healing process.
It’s finally possible to have the tools you need for outpatient wound management seamlessly integrated into the hospital EHR.
Proper documentation for surgical debridement is going to take a lot of engagement with your EHR vendor.