Episode Transcript
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Hello, folks, and happy Tuesday
to you. My name is Lawrence peppler
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and I'm the senior client success manager
over here at Karac touge, practice management
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software and integrated practice illutions, and
we are just overjoyed to bring you a
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really interesting and informative topic. Today
we're going to be talking about billion coding
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and hints and tips. This issue
of their series is going to focus on
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the no surprises act, in effect, this month. Are you in compliance?
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Once again, we're fortunate enough to
be partnering with Cathy Widner, who
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is the de facto, absolute most
astute professional when it comes to coding and
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compliance in our industry. Here,
the superlatives that I could throw towards Cathy
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are never ending. Cathy, how
are you doing this morning? Well,
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I am Jim Dandy and I'm always
embarrassed by all of those superlatives love.
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Thank you for loving me. I
appreciate that. So, Hey, folks,
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if you're not using the services over
at KMC University, you ought to
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be, because there is no better
service to help you with your billing and
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coding needs, and especially when it
comes to getting in the weeds on coding
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and things of that nature. And
and new changes that are coming. Cathy
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helps us keep abreast of what's on
the forefront, what's coming down the pipe,
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things that we need to be aware
of before they even happen. So
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what are we going to cover today? Well, this overview is going to
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cover these important aspects of this re
wired law that affects providers. How the
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transparency peace applies to all providers,
making them responsible for clearly communicating the cost
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of care to both ensured and uninsured
patients, and this includes chiropractors. What's
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the definition of good faith estimate and
how some are expected to be no more
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than four hundred dollars off when estimating
the cost of care? And then we're
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going to talk about some tips for
building a process to provide this information in
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the most streamlined way, with templates
offered for your use. So, with
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that being said, Cathy's going to
take just a little time get your mind
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going, get you thinking about this
topic and present some really good information to
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you. So I'm going to pass
it over to you now, Cathy.
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Awesome, and I want to be
clear. The government has certainly provided templates,
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which we are happy to share as
files that can be posted where Lawrence
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and the team will post this recording. So we're happy to provide those.
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Obviously we've kind of dug into it
more and we have some additional things and
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we'll talk a little bit more about
how those are available. So I'm giving
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you a very targeted version of something
that in our world is a five module
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course. It is so complicated.
So don't expect that you're here to learn
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every detail of this. That is
certainly not what we either intend or what
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is even reasonably possible. So I
want to just share kind of right up
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front. I'm going to go quickly. So why did the government want to
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cramp our style like this? Well, the challenge is that this is about
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consumer protection and you don't have to
go very far to find out about these
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challenges that have happened. Two big
giant offenders have been ambulance services, particularly
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air ambulance services, and these kind
of pop up emergency rooms that are all
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around. I can throw a rock
either east or west from my home and
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hit two of them because they're simply
everywhere. Sometimes they're in Ergent care,
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sometimes they're an emergency room and the
problem is their facilities that perhaps out of
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network. Doctors work in but you
don't know that when you're you've cut your
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hand and you need something quick,
and then later you get a tenzero dollar
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bill, and I'm not exaggerating.
So this is where all this came from.
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We, as providers, got caught
up in the mix. I will
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tell you that even as of today, which is whatever the heck. Today
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is, January the twenty five,
they're still unanswered questions. So nobody has
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the right answers and anyone that tells
you they do as blow and smoke.
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So I'm going to tell you what
we know. I'm going to tell you
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what you should do, what you
can do and, as usual, our
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job is to be as practical as
we can for you about what's going on.
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So we've had a really big kind
of year, starting in two thousand
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and twenty one with the twenty one
century cures act, with the new hippo,
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changes to information blocking, Hippo rite
of access, changed the hip a
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privacy rule and the proposed changes happened, and then, boom, the no
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surprises act happened as well. So
what we know? Their issues are are
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hidden charges, the excessive balance billing
that's happening and the idea that the number
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one reason for bankruptcy in the United
States is medical debt. Now, I
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don't think our little world of chiropractors
particularly are the problem here, but,
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as I said, we've gotten kind
of caught up in the process and there
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may be practices that you do in
your office that are now going to be
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contrary to what they want you to
do with this new law which, by
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the way, everything I'm telling you, went into effect at the beginning of
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this month. So if you've done
nothing on it or are like nine out
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of ten doctors who we speak to
who call in and say what it's what,
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what happened, it's not okay.
Like you have to stay on top
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of things and I'm so grateful that
Chire touch asked me to come and just
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share a little bit of information with
you here. So surprised. Billing in
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and of itself is essentially I wasn't
expecting this to happen. I had an
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interesting thing happened myself recently where I
visited an eant and I was still meeting
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my large deductible and I noticed that
I had a charge for four hundred and
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eighty five dollars that pass through because
it was applied to deductible for this endoscopic
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bloody blah blah, which was an
endoscopic but it was a literally a camera
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that they put up on each side
of my nostrils. I remember this distinctly
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and if this doctor spent four seconds, that's an exaggeration. She put this
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thing on her head, she went
bloop bloop in each side and I got
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a four hundred and eighty five dollar
bill, which I freaked the frick out
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about, and I you don't want
to. You know us as billards and
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coders right where the worst people to
send a send a balance bill to,
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and I fought it all the way
to the Ombudsman because it was it was
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not fair what she did. So
a surprise bill is when you get something
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you're not expecting and it often comes
down to a non participating provider or facility.
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And remember the facilities are what caused
this problem in the first place.
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Now the difference is balance billing.
Balance Billing is when you're supposed to be
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writing something off that the patient ends
up getting charged for in general terminology.
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That's what it means. So you
are absolutely okay with charging the patient for
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their portions, but again with no
surprises. We do have to let them
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know what's what. So remember this
is a consumer protection law, which means
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it affects your patients. So again, hidden charges, excessive balance billing and
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the medical debt issue. Now one
of the first things that we're going to
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talk about is understanding who you are
in your practice and how you deal with
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things. And I say this with
all the love in my heart because we
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talked to so many doctors. There
are some of you out there who don't
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know if you're in er out of
network, with a plan, and if
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you're out of network, you're billing
anyway and maybe mishandling what the patient should
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be paying. So all of that
has to be first. You've got to
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bring yourself up to speed with what
you should know. It's at Na,
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it's at Nahmo, I'm in network. Fine, it's blue cross PPO plan,
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I'm not in network, and you
have to know what these things are
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because, depending on those levels of
participation, even if you call yourself and
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all cash based practice, you have
to know these things because if I walk
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into your practice and I have whatever
insurance, and yes, you're a cash
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based practice, but I have blue
cross Blue Shield that has out of network
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benefits, if I see you.
You are affected by this act and you
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need to be aware of that.
So there's two parts to this thing.
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The whole idea of when part one
started, which was in July of last
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year, was to try to increase
stakeholders transparency, to create competition, to
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have doctors, half a hospitals particularly
have to list their fee schedules and things
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of that nature, because it would
give us consumer pricing information allow them to
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sort of shop a little bit.
And what the ultimate goal was to increase
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competition. Now part two, where
the final rule came out in September,
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is the one that we have to
pay the closest attention to. Number One,
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they established a resolution process. That
was their big deal. If a
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person doesn't like what they got for
a bill, there's a formal federal process
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they can go through. You know
what the problem is? They first hired
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the person in December to go create
the process. That was supposed to be
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an effect January first. So Gospel
according to Cathy. I'm going to be
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aware of it, but I'm not
worried about that right now. Second thing,
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which you're going to talk about a
lot today, is the good faith
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estimate. This one hundred percent applies
to us. The third thing is what's
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called an advanced eob that has to
come from the payer, because this rule
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not only affected doctors, that affected
payers. Payers have to be in a
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position to be able to say,
in a way, think about verification,
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here's what we expect the out of
pocket cost on this to be. Now
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I will tell you my own health
plan. I belong to Kaiser Permanente here
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in Colorado, and they are ready
do this because everything that they've been doing
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it for a few years, everything
that I would have done if I chose
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to. I could request and as
deiment and they would say, based on
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what we believe the coverage to be
on the diagnosis and the process that's going
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to happen, we expect your portion
to be x. now, this is
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impossible right now. Can't be done
for everybody, so we don't even worry
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about this today. Patient Provider Dispute
Resolution. That's kind of this thing.
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It's possible, but unlikely. And
then, obviously there's an expansion of the
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rights to external review. This is
the piece, along with what we're going
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to call billing protections, that we're
going to focus on today because in my
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estimation, to not blow your minds. I'm going to focus in on the
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things you need to know about those
two pieces. Number one, the world
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requires providers to furnish a good faith
estimate of expected charges upon request or scheduling.
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Now we'll get into what that means. And providers are expected to inquire
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about insurance status at the time of
scheduling the appointment. Now you may already
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do this. If you don't,
you're going to have to get it added
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into your process because, particularly those
of you who maybe don't take well,
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you're enough to do it either way, because you could have people with no
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insurance or they have like Hmo that
you're not a part of, etc.
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Healthcare providers and healthcare facilities are required
under this to furnish a notification of good
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faith estimate of expected charges to anyone
who is going to pay cash. Now,
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who are these people? Anybody with
insurance but you're out of network with
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their insurance, anybody who is exercising
their hippo omnibus rights and they have insurance
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but they're telling you not to bill
it, and anyone there to pay cash.
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These are all people that this applies
to, and so what we're going
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to show you definitely applies to those
people, here's the big challenge, and
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to an individual who has not yet
scheduled but requests so anybody can request this.
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So what you need to do is
have a process in place now.
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In fairness, I want you to
know this has been such a moving target.
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Even for our own clients. We
have about eighty five percent of the
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material that we would have available in
the forms and all the things. We're
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eighty five percent of the way there
because we have two questions that we want
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the final answer to out to both
C ms and a set of healthcare attorneys
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before we finalize our material. We
expect that this week our materials incomplete.
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Those you that are members, you'll
find it in the library here by next
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week. Is Our goal, by
the way, also the lunch of our
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brand new website next week. So
I want you to know we don't even
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have all the final stuff now.
Most of what the government provided is so
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heavily worded toward a facility that it
sucks. It's not good stuff for us.
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There have been a few other consultants
to put something together and frankly,
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they did nothing more than take the
government one and slap it on their letter
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head. We have created something for
chiropractors and the way chiropractors practice because,
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guess what, people calling you might
get them in the same day as a
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new patient. Now what do you
do? You have these rules to follow.
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So that's kind of where we're moving
in that direction, but I'm trying
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to be as transparent as I can. We don't even have all the answers,
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but we will have by next week
and that will be the final answer
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here, or at least the answers
we need today. So this is the
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issue that's been a big issue for
people like us, because you have to
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be, according to this rule,
able to supply your good faith estimate three
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business days before the day the service
is rendered. Now, is there a
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way around that? Yes, and
I'm going to show you what that is.
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But you still have to make the
patient aware. It's a little bit
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like the wink wink that could happen
around in a BN. Well, if
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you want to get your papers at
home and see all the stuff in the
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papers, in the papers, in
the papers, you check option one and
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we'll go ahead and bill it.
If you don't want any of that,
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you do number two. Same Story. We absolutely are required to be able
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to provide all of these estimates three
days ahead. I'm more than happy to
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get you in today if you wish
to waive that, or I can schedule
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you out far enough so that we
could at least give you an estimate of
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these first days charges. So most
people are going to go whatever. There
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you know. What do you mean? What's The ball park? The provider
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is responsible for the list of services. Theoretically, this is the piece that
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I talked about. is almost impossible
now, but I want to let you
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know this is coming down the road. I don't know how far out.
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I hope it's way the heck far
out, but you need to know.
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This is that connection between the provider
and the payer. So our suggestion for
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you as a to do right now
is make sure that you're enrolled in your
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pay or portals so that when this
comes to fruition, you're already at least
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set up to be where you need
to be. The practices that are smaller
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practices, maybe you're not so involved
with insurance, it's going to be less
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onerous. But if you're involved with
insurances and you're not a part of that,
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you want to get busy on that. Obviously it's not possible by January.
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It's also was not possible even today. So the good faith estimate,
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as I said, is for those
people self paying, those who are ensured
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using their Omnibus Hippo Rites and those
who are insured but don't have benefits for
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your coverage or item. We like
to call that the election to self pay.
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So I want laser, but laser
is experimental according to my insurance company.
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Even if you're in network with a
payer and we think oh no,
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surprises, doesn't affect us here.
It may be that if you're asking the
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patient to pay for their laser treatment, the good faith estimate has to come
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in place. Now, are most
of you good doctors and offices doing something
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anyway like this? I'm going to
bet that you are. If you're our
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member, of course you already know
how to do the election for the excluded
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services formed that we have because we've
been asking doctors to do this for years.
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Is it's just a good business practice
to put something in writing and say
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hey, this is not going to
be covered. If you want it,
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sign here, and it's quasi similar
to, you know, an excluded services
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a bien or special notice for Medicare
now you may be wondering why I haven't
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said Medicare in any of this.
This does not apply so much to Medicare
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patients because billing protections are already built
into the Medicare law. They're already there.
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So somebody who, even if you're
non participating with Medicare, think about
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that. You don't have to tell
them surprise billing because you already know you
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can't charge more than the limiting fee. Now, when they've become a cash
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paying patient for maintenance care, at
that point maybe that's the time to do
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so. But if you're continuing to
charge the Medicare allowed fee or limiting fee,
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you don't even have to worry about
that. So here's what's required for
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good faith. Estimate our GFEE,
as we're going to call it, when
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the person calls for their appointment.
If you don't do it now, you've
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got to work on a process to
get this done. For those of you
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who are members, this will all
be part of the checklist that's in that
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course, but it's important to know
you need to ask them a series of
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questions. Are they ensured? Do
they plan to use their insurance, etc?
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Now it would be very simple.
I assume for most of you are
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going to be doing a new patient
evaluation and management service on visit one.
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Now, let's not even talk about
our new conditions and returning patients. Let's
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just talk about new patients for now. It would not be hard for you,
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and this is certainly what we're advising
our members to do, to go
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pull a two thousand and twenty one
coding audit to be able to go.
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I want to see all of my
em services for new patients, nine and
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nine two oh something, and I
want to see what the ratio is of
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how many times I build each one. Right. That's just a straight up
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coding audit. And let's pretend for
a minute that stupid numbers. Twenty five
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percent of the time it was a
no to. Fifty percent of the time
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it was a nous three. Twenty
five percent of the time it was a
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no for, and for demonstration's sake, only my nine two hundred two is
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a hundred dollars, my two hundred
and three is a hundred and fifty and
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my o for is two hundred.
It would be very, very simple for
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me, because all you know right
now, I don't care what you think,
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you know all you know right now
is that that person is going to
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get an em service, because that's
really all you can guarantee. They come
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in, they have that evaluation.
Do I take extrays or not? Do
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I treat or not? Those are
decisions that happen after the patients there,
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even if you work off of a
protocol. So if I know that between
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one hundred and two hundred dollars is
what I can verbally estimate on the phone
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because that's what I know, and
the majority of those people are one hundred
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and fifty, that's a very easy
thing. You could say simply by doing
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a little audit review of your information. If the patient wants to get in
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the same day, you do need
to tell them. I'm required to give
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you a written estimate of this.
I can provide that when you get here
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later today, or I can send
it to you if you're willing to schedule
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at least three days out. So
that's a bunch of bollocks if you ask
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me, but it's just the rule
of what you have to do. So
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start with, what's your Em Service? On visit one? Now they can
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ask and you have to send it. I'm going to show you kind of
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what the government has for a form
for that, but if it's not yet
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scheduled, they can ask for that
estimate in writing. And it's a pain
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in the fanny, but they can
do it and you have to comply.
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So we encourage you to really build
a solid intake process. Those that use
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our new patient telephone form. That's
a great way to use that process because
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it lays out what the patient has
or doesn't have in network out of network,
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and then it allows you to verify
and to know where you're out with
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them. In Roll with your pay
air porters for now. Get that done.
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Get Medical Review Policies and eimbursement guidelines. You hear me say this all
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the time from the payers that you
deal with, so you know what is
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and isn't covered. Start a solid
verification process that's in place before the patient
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comes in, if you can,
and not just eligibility verification of what actually
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is or isn't covered, and then
really build your compliant financial policy. figure
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out your coding averages, how many
different you know of each one you did
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and maybe you can figure out what
you want to provide as verbal estimates on
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the phone. Provide that written estimate
at visit one. Something that you could
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put together. My guess is it
would be very easy to have a standard
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template, have what you normally do
and then fill in that information, then
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provide a more detailed one at your
report of findings, are financial report of
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findings, and most certainly keep it
in between that ballpark of four hundred dollars.
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So if you're already doing some type
of a good faith estimate, awesome.
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The little gory details are going to
still reveal themselves, I think over
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the next thirty, two, sixty
days. Make sure that, if it's
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an out of network person that you
deal with specifically that extra billing protections form
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that we talked about now. In
my mind, and certainly the way we're
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advising our members, is I still
think it's a good idea to use a
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patient election to sell pay form,
to double indemnify, so to speak,
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the fact that the patient says no, no, I don't want to use
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my insurance. I want to do
this. The other thing that you can
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do if you're worried about this initial
visit situation, I know I've talked about
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it in these trainings before, and
certainly we have this in our library as
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well, is what we call the
pre acceptance interview, that the pace,
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the way you manage new patients is
that the patient comes in, they have
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a discussion with the doctor, that
anybody can have a conversation, because we
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don't want to call it a free
consultation, but they can come meet the
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doctor, talk about their issue,
determine whether they're a good fit and because
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they're in now, you could give
that more specific estimate of how much that
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first visit would be. I love
all of those ideas. I think at
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this point it's about process, you
know, and even those that work with
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us one on one, every different
coach is working differently with every single person
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because we don't want to upset your
apple cart of your practice that much.
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We want to make it so you
do what you need to do, but
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it's not overboard. Catherine, thank
you so much for joining us today.
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We appreciate your folks. Have a
great day.