Tag: Healthcare reform

Payer News . . . Plus Brief Hiatus in Posting

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Since October 2008, we have published 85 almost weekly blog articles. Holidays and vacations and family illnesses have sometimes interrupted the flow, but I have not purposefully interrupted the postings until now.

Between now and the end of 2010, if I post a blog article, it will be brief and mostly focused on a link to other information that may be of use to you. I will start regular posts again in January 2011 after catching up on some other responsibilities.

For now, if you want to get lots more information about healthcare payers than you or any other provider ever wanted to know, you might consider reading and even subscribing to the FierceHealthPayer newsletter: 

http://links.mkt1985.com/servlet/MailView?ms=MzIzOTIwNgS2&r=MTg5MTY1NDkxMTYS1&j=MTAxMTAwOTA2S0&mt=1&rt=0

This newsletter focuses on the payer aspects of healthcare. If you can stand it, you will find lots of information . . . like how the medical-loss ratio (MLR) rule may or may not affect payers and which states are trying to get a waiver from the rule . . . that may be useful to your organization.

Thanks for reading and commenting. I will look forward to picking up where we left off in January. Please feel free to leave your comments below.

How’s Your Compliance Program Coming Along?

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Last week I attended a webinar sponsored by The National Council: Healthcare Reform Expands Compliance Requirements: Prepare Now.  There is a recording of the presentation at the link above.

I attend lots of webinars to try to stay informed about what is happening in our industry. As indicated by the fact that I often write about those webinars, I am often stimulated by them. I am rarely alarmed, but this presentation by attorney Adam Falk was almost frightening. I found myself thinking that, if I were still in private practice of psychology, I would stop accepting Medicare patients. Since I just turned 60 and will become one of those Medicare patients in only five years, that thought was most distressing.

According to Mr. Falk, the Patient Protection and Affordable Care Act of 2010, as part of the attempt to save money by eliminating fraud, has placed new requirements on providers of service large and small, to demonstrate compliance with the law. It is not enough to comply; one must also be able to prove that compliance, hence the need for a formal Compliance Program.

The regulations have not yet been written to determine what must be included in such a Compliance Program, but Mr. Falk strongly suggests the need to be proactive rather than reactive regarding this matter. While compliance programs are to be ‘scalable’ based on the size of the organization and the amount of service provided as part of the Medicare or Medicaid systems, there are certain aspects that are essential.

The biggest danger to provider organizations is that the Affordable Care Act classifies much irregular activity as making a false claim. The penalties for false claims are significant. Fraud is rampant and HHS is tasked with eliminating as much of it as possible to protect the taxpayer’s dollar. The attempts to prevent this fraudulent activity provide the Secretary of HHS with broad authority.

Additionally, providers are required to identify, report and return overpayment by Medicare or Medicaid within 60 days of the provider’s recognition that an overpayment has been received. That recognition applies to the clerk in your accounts receivable department who mentioned the overpayment to a supervisor or to someone in authority. Training staff and providing formal procedures to follow will be an essential part of any compliance program.

I would suggest that you take an hour and listen to Mr. Falk’s webinar. Then start to research what might be required at your organization’s level to comply with the requirements of the law.

*****

I received an email notification today from the Office of Civil Rights indicating that HHS has scheduled a second public discussion on Confidentiality and Privacy Issues Related to Psychological Testing Data. The meeting will be held in Los Angeles on November 18, 2010.

Please share your comments below. Thanks for reading!

Primary and Behavioral Healthcare Integration

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On Monday the National Council announced that they have won a competitive grant to provide training and technical assistance to move forward the process of integrating primary and behavioral health care services. They will provide support services and assistance to organizations that have received grants to develop integrated care within their organizations, as well as to other organizations seeking to move in this direction.

 One of the pushes in the ARRA stimulus funding and in the health care reform law (Patient Protection and Affordable Care Act) was more efficient and cost effective provision of health services. One possible way to accomplish this for those who experience mental health and addiction problems is to integrate the care they receive for all illnesses, physical and behavioral. The National Council has been at the forefront of this movement. Their snagging of this grant demonstrates their commitment to the cause of integrating primary and behavioral health care for vulnerable populations. The press release indicates the following:

The Center will provide training and technical assistance to 56 organizations that have collectively been awarded more than $26.2 million in grants as well as to community health centers and other primary care and behavioral health organizations. According to HHS Secretary Kathleen Sebelius, these grants are part of an unprecedented push by the Patient Protection and Affordable Care Act to help prevent and reduce chronic disease and promote wellness by treating behavioral health needs on an equal footing with other health conditions.

When I have mentioned this topic in previous blog articles, the response has been disbelief that such integration will occur any time soon. After all, behavioral health private practitioners of our generation are not likely to dramatically change the way in which they practice, and now they mostly practice independently of medical settings.

In fact, it is even the case that many of our community-based behavioral health  organizations have a hard time seeing themselves moving toward providing primary care services for their consumers. At least one of our customers tried establishing a primary care facility as part of their organization a couple of years ago. The service did not take hold and they closed it. Perhaps they were too far ahead of the curve to be successful.

According to the National Council, the motivation to integrate general and behavioral health care among the chronically and seriously mentally ill is the significantly shorter lifespan experienced by those with serious mental illnesses.

According to a 2006 national survey, persons with schizophrenia, bipolar disorder and major depression have lower than average life expectancy and die, on average, at the age of 53 — often from untreated and preventable chronic illnesses like hypertension, diabetes, obesity and cardiovascular disease. Lack of access to primary care and specialty medicine is a critical factor in these tragic outcomes. . . .

The average life expectancy of the population at large in the U.S. in 2006 reached an all time high of 78.1 years. This 25 year difference is unconscionable. It is believed by many in the public health and behavioral health communities that integrating health care services for the seriously mentally ill and chemically dependent populations will encourage treatment regimens that will benefit both physical and mental health.

Most of the organizations active in this integration movement are considered ‘safety net’ providers. Although part of an endangered system,  ‘safety net providers are providers that deliver a significant level of health care to uninsured, Medicaid, and other vulnerable patients.’ They are the health care safety net that is intended to keep vulnerable populations from falling through the cracks in our costly and difficult to navigate health care system.

Are any of our readers among the 56 organizations that have received grant funding to develop integrated physical and behavioral health services? Do you see this as a possible and worthwhile goal for private practitioners to move toward? What changes in training models and practice models would need to occur to integrate primary and behavioral health care?

Let us know your thoughts about these issues. Please enter your comments below.

Resources for Behavioral Health Providers

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I read lots of articles online…or I download the articles and read them in .pdf format. Seth found a free tool that is going to make this whole reading and organizing process easier for me. It is called PDF-XChange Viewer and it can be downloaded for FREE! If you like to highlight and make notes as you go, this is a great tool.

That resource is really just a lead-in. In case you have not already collected some of the following sources from my references to them in other articles, I am going to put them all in one place. These are newsletters and web sites that are chock full of information that can help you stay informed about changes in the health care and regulatory world.

  1. My favorite by far is The National Council (NCCBH). This organization produces regular newsletters on varied topics, but I find their Public Policy Update to be an invaluable source of information on laws and regulations, policy trends and how you can address them. I have also greatly enjoyed their Webinars. Ordinarily, I would have already registered for the program coming up on Friday, May 14, What is an Accountable Care Organization and Why Should I Care? Since I will be out of town, I won’t be able to attend when it is broadcast; instead, I will watch it at a later date from the web site. The best part is that these programs are free and you do not need to be a member to participate in them. They are provided as a service to the behavioral health community.
  2. Every Monday, I receive a free multi-paged newsletter from the Mercom Capital Group, LLC of Austin, TX and Bangalore, India. This newsletter pulls capsules of information from a large variety of sources providing a quick overview of events in the domain of health care technology and health care policy. If you are interested in trying it out, send your email address to Raj at HIT@mercomcapital.com. 
  3. Open Minds is a longstanding and thorough source of industry information and strategy specifically for behavioral health provider organizations. While there are an abundance of workshops, webinars and premium programs, the Open Minds Circle is a free-for-the-registering newsletter from founder Monica Oss and others at Open Minds.
  4. Behavioral Healthcare and Healthcare Informatics (products of the Vendome Group), the U.S. Department of Health and Human Services, and the Office of the National Coordinator for Health Information Technology all have mass quantities of information to offer you, all available online.

The amazing thing to me is that this is just a small list. If you were to add in blogs, the amount of free, high-quality information available to you on the web is overwhelming. Choose wisely…and use that free .pdf markup tool to make it easier!

Please share with the rest of our readers sources of behavioral health industry information upon which you rely. Just enter your comments in the box below.

Health Care Reform and Behavioral Health

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On March 21, 2010, the U.S. House of Representatives passed the Patient Protection and Affordable Care Act. Subsequently, they passed the Reconciliation Act  (H.R. 4872) making changes in the original bill. After some maneuvering, all the necessary legislation was passed by both houses of congress and on Tuesday, March 30, 2010, President Obama signed the Healthcare and Education Affordability Reconciliation Act of 2010 into law.

In the past week or two I have seen many questions about what the effects of this legislation will be. Behavioral health provider organizations are especially concerned about what the effects will be on mental health and addiction service funding.

One of the most useful resources I have come across was forwarded to the Florida Psychological Association member listserv by Dr. Bob Porter. The Bazelon Center for Mental Health Law has done an excellent job of summarizing the law and its impact on coverage for mental health services. While it will take years for all of the provisions of the new law to be implemented, a Congressional document summarizes some of the immediate effects.

In the private insurance sector, generic requirements of the law have particular impact for those with mental illnesses. In the past, such diagnoses have routinely triggered pre-existing condition clauses in policies. Within the first 6 months, the new law prohibits this discrimination.

  1. No discrimination against children with pre-existing conditions.
  2. No rescissions based on developing an illness.
  3. No lifetime limits on coverage.
  4. Tightly regulated annual limits on coverage.

In addition, for those who are currently uninsured, the law mandates:

  1. Immediate help for those with pre-existing conditions (an interim high-risk pool).
  2. Extending coverage for young people up to their 26th birthday through parents’ insurance.

Since so many who have been diagnosed with mental illnesses or with substance abuse issues have been denied coverage or have had coverage revoked or have reached the limits of their benefits, we should see immediate increased access to behavioral health and addiction services. The ability for parents to keep young adults on their insurance plans until they are 26 years old will assist some of the young people who experience late adolescent onset of serious mental illness or substance abuse conditions. This will allow a period during which their parents will be more able to facilitate transition to some other form of insurance coverage.

The National Council for Community Behavioral Healthcare, the trade association of behavioral health community service providers, hosted a webinar on healthcare reform and its impacts, Healthcare Reform: What Happens Next? Additionally, their Public Policy Update for April 1 gives links to resources as well as information about moving forward from here.

I attended the Council’s webinar this week and was struck by a couple of things. Because the Council primarily represents organizations that provide services in the public sector, their information is generally focused in this direction. For me, there were three take-aways from this session, and they were not all for public sector providers:

  1. The Council believes Fee for Service will probably go away in the long run, to be replaced by Case Rates with a Bonus for improvement of the consumer.
  2. Behavioral health providers need to position themselves for the long term. Integrated care is likely to be the way of the future and it is best to start to get positioned for that now.
  3. Private practices can be competitors in the new system; however, those with deep pockets who can manage the whole range of healthcare services will be better positioned to compete.

Community Behavioral Health Organizations (CHBOs) have been working on these steps for the past couple of years and there will be pilot programs using CBHOs together with Federally Qualified Health Programs to start to provide integrated care. Unless private behavioral health practitioners also start to position themselves to play in the Integrated Care setting, they are likely to get left behind.

Even the American Psychological Association’s advocacy efforts focus on the assurance that mental health services will be part of integrated care. This sounds very much like an integration of mental health services into such settings to me.

What do you think about how the new health care reform law will affect behavioral health services? Do you foresee changes in how care is provided? What changes are you willing to make in your organization in order to assure participation in a reformed health care system? Please enter your comment below. If you don’t see the comment box, just click on the title of the article and then enter you comment at the bottom.