Department of Health and Human Services (HHS) Secretary Kathleen Sebelius today announced a proposed rule that would establish a unique health plan identifier under the Health Insurance Portability and Accountability Act of 1996 (HIPAA). The proposed rule would implement several administrative simplification provisions of the Affordable Care Act.

The proposed changes would save health care providers and health plans up to $4.6 billion over the next ten years, according to estimates released by the HHS today. The estimates were included in a proposed rule that cuts red tape and simplifies administrative processes for doctors, hospitals and health insurance plans.

“The new health care law is cutting red tape, making our health care system more efficient and saving money,” Secretary Sebelius said. “These important simplifications will mean doctors can spend less time filling out forms and more time seeing patients.”

Currently, when health plans and entities like third party administrators bill providers, they are identified using a wide range of different identifiers that do not have a standard length or format. As a result, health care providers run into a number of time-consuming problems, such as misrouting of transactions, rejection of transactions due to insurance identification errors, and difficulty determining patient eligibility.

The rule simplifies the administrative process for providers by proposing that health plans have a unique identifier of a standard length and format to facilitate routine use in computer systems. This will allow provider offices to automate and simplify their processes, particularly when processing bills and other transactions.

The proposed rule also delays required compliance by one year– from Oct. 1, 2013, to Oct. 1, 2014– for new codes used to classify diseases and health problems. These codes, known as the International Classification of Diseases, 10th Edition diagnosis and procedure codes, or ICD-10, will include new procedures and diagnoses and improve the quality of information available for quality improvement and payment purposes.

Many provider groups have expressed serious concerns about their ability to meet the Oct. 1, 2013, compliance date. The proposed change in the compliance date for ICD-10 would give providers and other covered entities more time to prepare and fully test their systems to ensure a smooth and coordinated transition to these new code sets.

The proposed rule announced today is the third in a series of administrative simplification rules in the new health care law. HHS released the first in July of 2011 and the second in January of 2012, and plans to announce more in the coming months.

The proposed rule may be viewed at www.ofr.gov/inspection.aspx. Comments are due 30 days after publication in the Federal Register.

DBNC Education Center is located on the lower level of the Decatur Back and Neck Center and is where many of Dr. Fucinari’s courses are held.

Decatur Back and Neck Center and DBNC Education Center are located just off of Rte. 51 North (Water St.) at 3350 N. Water St. in Decatur, IL between Target and Brettwood Village Shopping Center.

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“Thank you to all who voted. I am honored and very appreciative.” — Mario Fucinari, DC

Once the covered entities have been selected, they will be notified as to their selection. Within 30 to 90 days, the on-site inspection of the covered entities will occur. Depending on the size of the entity, the government stated that the audits may take up to three days and will examine procedures and policies within the office. After reviewing the findings of the initial 20 audits, the audit process will be analyzed for procedural changes. Afterward, the audits will continue until the remaining 130 audits are completed by December 2012. Data from the entire 150 audits will be used to guide compliance audits in the future.

During site visits, auditors will interview key personnel and observe processes and operations to help determine compliance. According to an OCR press release, “ We expect covered entities to provide the auditors their full cooperation and support and remind them of their cooperation obligations under the HIPAA Enforcement Rule.” Every covered entity and business associate is eligible for an audit.

Following the on-site visit, auditors will develop and share with the provider a draft report, which will generally describe how the audit was conducted, what the findings were and what actions the covered entity is taking in response to those findings. The covered entity will have 10 business days to review it, and will be invited to provide written comments back to the auditor. The auditor will complete a final audit report within 30 business days after the covered entity’s response and submit it to OCR. Should an audit report indicate a serious compliance issue, OCR may initiate a compliance review to address the problem. The final report submitted to OCR will incorporate the deficiencies found by the auditors, the steps the entity has taken to resolve any compliance issues and also describe any best practices discovered at the entity. Although the audit results will be “broadly shared”, OCR will not post a listing of audited entities or the findings of an individual audit which clearly identifies the audited entity.

This course is open to all qualified doctors and staff. Must have knowledge in coding and claim form completion.

For the last three years, this class has consistently sold out.  Seating is limited!

Register now for the Fall 2012 MCS-P Course in Decatur, IL

A MCS-P Certification Class has been scheduled for fall 2012 in Decatur, IL. The dates for the class are October 20-21 for Part 1 and November 3-4 for Part 2. The exam will be on Monday, November 5, 2012. You may register for this fall class today – see below for registration & payment instructions.

The course will be held at the DBNC Education Center in Decatur, IL at 3350 N. Water St.

A block of rooms has been reserved at a special rate of $85 for the suite. The rooms are being held at the special rate under “Medical Compliance Training” or with “Dr. Mario Fucinari” Rooms are limited and should be reserved as soon as possible. The suites available are at

Country Inn & Suites By Carlson Decatur
5150 Hickory Point Frontage Road, Decatur IL 62526
Reservations: 1-800-596-2375 US/Canada Toll-free
Telephone: (217) 872-2402

The course is a 48-hour course approved for 48 hours Category One CME in Illinois. The certification exam will be held on Monday, November 5, 2012. The following degrees will be obtained upon completion of this course:

• Certified Medical Compliance Specialist-Physician (MCS-P)
• Certificate of Chiropractic Proficiency

Cost of the course is $2,895. Get the early bird discount price of $2,745 through October 5, 2012!
This includes the course fee and certification exam fee of $500. Price also includes course fee, books, binders, supplies and the $500 exam fee.

Sign up now! Class size is limited and will sell out!

How to Register

1. Download the Registration Form (pdf).
2. Print and fill out the form.
3. Choose a payment type.
   • Visa or MasterCard
     - fill out information on registration form.
   • Check – send in by mail. Make checks payable to Dr. Mario Fucinari.
   • Paypal™ – pay directly on our website. See the  PayPal™ button at the bottom of  this page.
4. Submit in one of the following three ways:
   • By e-mail attachment to doc@askmario.com.
   • By fax to 217-422-4266
   • By mail to:
     Mario Fucinari DC, MSC-P
     Compliance Training
     3350 N. Water St., Ste. A
     Decatur, IL 62526

Pay for the Extended MCS-P Course with PayPal™

The Centers for Medicare and Medicaid Services (CMS) has added a new contractor in its army of health care auditors.  The Zone Program Integrity Contractor (ZPIC) is the latest approach by CMS to audit and enforce its program guidelines.  Prior to the formation of the ZPICS, there were different entities such as the Program Safeguard Contractors (PSC), Medicare drug integrity contractors (MEDICs) and the Recovery Audit Contractors (RAC).  There was no uniformity in jurisdiction for each of these entities, therefore one entity may be overseeing a portion of Part A providers (hospitals) and another may be overseeing another portion of Part B (physician’s offices) in the same state.

To make the system more efficient, CMS has given jurisdiction to the ZPICs to oversee all Medicare claims for their appointed zones of the state.  Eventually, ZPICs will be entrusted in ensuring the integrity of all portions of Medicare.  This will include Part A, Part B, Part C and Part D Medicare.

In respect to the Comparative Billing Report, this report was sent to the top 5,000 utilizers and providers to the Medicare program.  As such, if you received a CBR, you are one of the top 5,000 chiropractors seeing Medicare patients.  Good for your practice, but not so good for looming audits.  ZPIC has used information from the CMS computer profiles to not only see who are the top providers, but also where you are skewed compared to your colleagues.

It is to your benefit to study your profile and compare yourself to others nationally, but especially in your state.  If you are too high in one area, then you may be singled out for a future audit.  When I recently called the ZPICs, I was informed that they are not using this information for audits “at this time.”  The person on the telephone was emphatic about the “this time.”  One can extrapolate that a statistically significant deviation in the numbers of 98940, 98941 and 98942 claims may be an indication of improper usage.  As such, the question of medical necessity will be a trigger for a possible audit.

Keep in mind that the CBR is for educational purposes.  I wonder if you have been educated that there is a statistical difference between you and your peers and you continue to practice in the same manner, might this indicate an intentional over utilization.  This in itself may be indicative or at least construed as fraud.

For those providers that have not received a CBR, you may still be vulnerable in your practice for an audit.  As such, it is recommended that you request a Physician Profile on yourself through the Freedom of information act.

As a Compliance consultant, I have personally seen a rise in the number of Medicare and Blue Cross audits in the last year.  Whether you are a participating provider or non-participating provider does not alter the chances of being audited.  Medicare clearly stated that the fact that you are par or non-par does not alter the likelihood of an audit.

To prevent an unforeseen audit and eventual reimbursement of funds to Medicare or another carrier, it is recommended that you become proactive in your approach to documentation, coding and compliance.  This can be accomplished through internal audits and education.

The most accurate way to assess your entire practice is for an audit or review at your office.  The Office of Inspector general has stated that a proper compliance audit and manual will not only uncover deficiencies in your practice, but will also is used as a mitigating factor in the case of fines and/or jail time.  Another alternative is to have a competent certified compliance specialist audit your charts for documentation, billing and coding checked for accuracy and compliance.

Many are frustrated by the level of audits conducted by carriers, but accountability, accuracy and efficiency are key to a practice with decreased stress.  Having a cash practice will not preclude you from audits.  Don’t forget that your documentation is also important to thwart any type of malpractice or negligence litigation.

Many opportunities are being offered to our profession by the Illinois Chiropractic Society.  For a listing of upcoming Medicare, coding and compliance classes, see our website at www.ILChiro.org

Dr. Fucinari is a Certified Medical Compliance Specialist and a Certified Insurance Consultant.  For further information on compliance audits or record reviews, please contact Dr. Fucinari at Doc@Askmario.com  Classes are now forming to become a Certified Compliance Specialist (MCS-P).  See www.AskMario.com for details.

Dr. Mario Fucinari is a full-time practitioner in Decatur, Illinois. He is a Certified Insurance Consultant, Certified Medical Compliance Specialist and a Certified Medical Compliance Instructor. Dr. Fucinari also is on Logan College of Chiropractic Faculty and Post-Graduate Faculty. For further information about compliance or audits, you may contact Dr. Fucinari at doc@askmario.com

To listen to this audio interview, download the mp3 or visit www.chiroviewpresents.org/chirochat_audio.cfm.

About Sig Miller, D.C. and ChiroChat

Chiropractic Gateway, a free online information service, assists chiropractors, chiropractic assistants, and students to successfully prepare for and to deal with challenges of every day practice, and to tap into the wellness marketplace valued in the trillions of dollars.

Chiropractic Gateway and many of our profession’s brightest minds are positioned to serve-up their most extraordinary ideas. Contributors include industry experts, leading companies and their representatives, national associations and organizations, and colleges who are provided full access all media.

Chiropractic Gateway is designed to assist chiropractors with 1) improving diagnostic acumen and patient management outcomes, 2) attracting and retaining new and established patients, 3) implementing effective practice development and management strategies, and 4) introducing effective ways to deliver the chiropractic message to the general public.

Chiropractic Gateway, using advanced technologies, includes streaming audio and video, live and recorded ChiroChat™ teleclasses, clinical case-of-the-week, research updates, surveys, forums, classified, clinical forms for download, seminar updates directing registrants for sign-up, and more. ChiroView Presents weekly e-broadcasts, received by more than 42,000 DC’s, CA’s and students, include the latest media and content.

Text above from: www.chiropracticgateway.com

Dr. Mario Fucinari has been presenting Medicare Classes for over six years and is a nationwide speaker on Medicare, Clinical Documentation and HIPAA. Dr. Fucinari also serves as the Illinois Chiropractic Society’s Medicare Committee chairman and as alternate Chiropractic representative to the Illinois Medicare Carrier Advisory Committee (CAC). In his back-to-the-basics approach, Mario whittles a difficult subject to an understandable, and interesting, comprehension of the Medicare requirements.

As an optional section in the demonstration project regions, Dr. Fucinari will add in materials pertaining to the requirements to participate in the Medicare demonstration project. The demonstration project has expanded coverage for the services that chiropractors provide for the care of neuromusculoskeletal conditions, including diagnostic and other services such as the provision of x-rays and therapy services. The demonstration project includes the entire states of Maine and New Mexico, in the Chicago Metropolitan Statistical Area (MSA) and 17 central counties in Virginia.

“After joining you for the most recent Medicare seminar, I am once again amazed at the wealth of information that I took away from it.  Going to your seminars on a regular basis has not only made my practice more lucrative, but also has helped me to hone my clinical skills. Thanks Mario!” – R. B., DC, Chicago, IL

• Participating vs. Non-Participating Provider
• Steps to a Medicare Audit
• The Medicare Appeals Process
• “Unprocessable Claims”
• Initial Visit Documentation
• Subsequent Visit Documentation Requirements
• Coding Requirements for Medicare
• OIG Gifts and Inducements
• CMS-1500 Claim Form Requirements For Medicare
• How to Use the Coding Modifiers Properly
• What is Medicare Medical Necessity?
• Limiting Charge Guidelines
• What the new Medicare Prescription Drug Modernization and Improvement Act of 2003 means to YOU!
• Proper Use of the ABN Form