NJ Department of Health Guidance to Providers on Ebola

New Clinical Guidelines for Initial Evaluation of Suspect Cases of Ebola  

[T]he NJDOH requests that all health care providers consider  Ebola Virus Disease (EVD) in the differential diagnosis of febrile illness in persons with recent travel (within 21 days) to the affected countries in West Africa, currently including Guinea, Liberia, Sierra Leone and Nigeria. All persons with compatible symptoms and travel history should be isolated until clinical evaluation and/or diagnostic testing is completed. At this time, there have been NO reports of EVD in the U.S.

Reporting Reminder for Health Care Providers:

Confirmed or suspect cases of any viral hemorrhagic fever, including EVD, should be reported immediately to the local health department where the patient resides. [Memo dated August 13 to Local Health Departments, Health Care Providers, and Hospitals from Shereen Semple, MS, Epdiemiologist, NJ DOH]

Read the NJ DOH Memo, CDC Update, CDC Key Messages and Clinical Guidelines for Initial Evaluation of Suspect Cases of Ebola. Other important Ebola information can be found on the NJ DOH website.

Open Payment System Maintenance; Time to Dispute Extended to September 10

The Open Payments system will be shut down during a series of scheduled maintenance upgrades. Due to these shut downs, the deadline to file a dispute has been extended to September 10. Please plan accordingly:

Saturday, August 30, 2014
1:00am to 11:00am
and
Saturday, September 5, 2014
Time not specified.

MSNJ along with more than 100 medical societies signed on to a letter to CMS asking for a six month delay in the public release of the Open Payments data. When the data is released next month, one-third of the records will be withheld due to data inconsistencies. In an email written to Propublica, CMS spokesman Aaron Albright stated, “CMS is returning about one-third of submitted records to the manufacturers and [group purchasing organizations] because of intermingled data, and will include these records in the next reporting cycle.” These records will be posted in June 2015. September 30 will still be the first public release date, despite the temporary shutdown of the website, and will include payments made from August 1, 2013 to December 31, 2013. Read more.

Having trouble registering? Check out MSNJ’s archived webinars with speaker Jennifer Searfoss, Esq of Searfoss Consulting Group, LLC. Listen as Jen walks you through the process step-by-step.
• Part 1 covers Step 1 of the registration process. The Sunshine Act is Here: Open Payments Web Portal Registration
• Part 2 covers Step 2 of the registration process as well as the dispute mechanism. Sunshine Act: Financial Interest Data Disclosure: Refuting Open Payments Data

Prescription Blank Deadline Extended

MSNJ asked the Division of Consumer Affairs (DCA) for leniency for practices unable to obtain the new prescription blanks by the August 18 deadline, due to vendor back-orders. In response to our request and that of several other groups, the DCA decided to extend the deadline to September 19, 2014 and allow physicians to use the old and/or new prescription blanks from August 19 through September 19. Only the new prescription blanks may be used effective September 20. Physicians, who have not placed orders for the new blanks, are urged to contact an approved vendor and order immediately. Also, please be sure to notify the NJ Drug Control Unit that you have destroyed your old prescription blanks by completing a certification of destruction.

IHCAP Notice Requirement for Physician Offices

The New Jersey Department of Banking and Insurance (DOBI) recently adopted regulations requiring physician offices to post notice regarding patient rights under the Independent Health Care Appeals Program (IHCAP). MSNJ provided comments to DOBI on the proposed regulations requesting that the notice include language that clarifies that IHCAP may not apply to all patient plans. We thank DOBI for honoring our request. Note that IHCAP does not apply to most government-sponsored coverage, such as Medicare, the Federal Employee Health Benefits Program, the New Jersey State Health Benefits Program and self-funded plans according to DOBI. The notice language may be downloaded from DOBI’s website. The notice must be posted by August 3, 2014, include the specific content from DOBI’s website, and be printed on at least 8 ½” by 11″ paper with 12-point type or larger. Physicians may choose to print it on larger paper, in order to incorporate all the information on one sheet; in this case the text must also be at least 12-point type. MSNJ created a one page sample notice, for member use. Please feel free to download, print, and post this legal sized (8 ½” by 14″) poster in your office.

We also recommend that practice’s also have available, the plans that DOBI has excluded from the IHCAP appeal process. This information can be found on the DOBI website FAQ number 25 or downloaded here.

Sunshine Act Update: Open Payments Registration and Review/Dispute Process Began July 14

Registering in the Open Payments system is voluntary, however, it is a mandatory process if physicians want to review and dispute the data submitted by manufacturers and group purchasing organizations (the Industry) before the data is posted to the public on September 30, 2014. Any data disputes must be filed on or before August 27, 2014, in order to be reviewed and possibly corrected by the Industry which before going public, will be able to submit dispute corrections beginning August 28 through September 11. Please Note: Registration is a two-step process. Physicians must first register for the Enterprise Portal before registering for the Open Payments System. View MSNJ’s archived webinar regarding the complicated Enterprise Portal registration process. Read more on how to prepare for the review and dispute process. View AMA’s Sunshine Act resources.

CMS’ MLN Connects™ will host a National Provider Call on July 22 on this topic. Listen to a brief introductory presentation about Open Payments and an overview of the registration and review and dispute process. Register.

Register for MSNJ’s upcoming webinar that will provide an in depth look into: The Sunshine Act – Financial Interest Data Disclosure: Refuting Open Payments Data
Wednesday, July 30, 2014 from 12:00pm-1:00pm
Register online.

Key Provisions of Proposed Medicare Physician Fee Schedule for 2015

CMS published its proposed rule on Medicare’s payment schedule and policies on July 11. Comments on the proposal are due on September 2. Key changes in the proposal include:
• Doubling the value-based modifier (VBM) penalties to 4% and subjecting all physicians to 2017 VBM adjustments based on performance in 2015;
• Extending the VBM to ACOs and other alternate payment models;
• Eliminating global surgical services by 2018;
• Reducing the opportunity for comment, review time, and implementation for changes in local coverage determinations (LCDs) for clinical laboratory tests;
• Expanding reimbursement for telehealth services under certain circumstances to include psychotherapy services, prolonged services, and annual wellness visits in 2016;
• Reimbursing for chronic care management services on a per patient per month basis when certain conditions are met; among other things, beneficiaries must have two or more serious chronic conditions;
• Expanding public reporting of group-level measures in Physician Compare in 2016 and, if feasible, expanding measures for individuals making all 2015 PQRS individual measure collected via registries, EHR, or claims available on Physician compare in late 2016;
• Increasing the requirements for successful PQRS reporting and imposing a 2% penalty in 2017 for those eligible professionals who do not report satisfactorily in 2015. Read more details in AMA’s Summary of Key Provisions.

Note that CMS supports legislation to permanently address the SGR, but rates are only protected from payment cuts through March 2015 at which time payments will be reduced by over 20% if Congress does not act.

Important EHR Incentive Program Deadlines

This is the last year (2014) that Eligible Professionals (EPs) can start participating in the Medicare EHR Incentive Program to receive incentive payments. EPs who begin participation in the Medicare EHR Incentive Program after 2014, will not be able to earn an incentive payment for that year or any subsequent year of participation. If you choose to participate in the program for the first time in 2014, you should begin your 90-day reporting period no later than July 1, 2014 and submit attestation by October 1, 2014 to avoid the payment adjustment in 2015. Read more.

If you were unable to successfully demonstrate meaningful use for 2013 due to circumstances beyond your control, CMS is accepting applications for hardship exceptions to avoid the penalty for the 2013 reporting year. Applications for individual eligible professionals and eligible professionals submitting multiple NPIs are available. CMS will review the application to determine whether or not you are granted a hardship exception. Applications for the 2015 penalty are due July 1, 2014. If approved, the exception is valid for one year. Use CMS’ new interactive tool for eligible professionals to help determine if you will avoid the penalty by demonstrating meaningful use. Tipsheets are available on the CMS website. Use this timeline  to determine which year you will demonstrate Stage 1, Stage 2 and Stage 3 of meaningful use.

CMS and the ONC released a Notice of Proposed Rulemaking (NPRM) allowing providers participating in the EHR Incentive Programs to use the 2011 Edition of certified electronic health record technology (CEHRT) for calendar and fiscal year 2014 and extending Stage 2. Read more.

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