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Medical Mutual Practice Managers Educational Workshop Attracts Record Crowd
Nearly 150 practice administrators attended the annual Educational Workshop presented by Medical Mutual Insurance Company of Maine last Tuesday, June 29th. Medical Mutual is the largest professional liability carrier in the state and also writes policies for physicians and hospitals in New Hampshire and Vermont. The workshop, which gets more popular each year, was presented at the Marriott Sable Oaks in South Portland.
Presenters on the topics of test tracking and appointment management system and liability and the electronic medical record included Karen Waycott, CPC, Quality Manager for Physician Services for SMMC PrimeCare, Louise Beaulieu, FNP, Clinical Quality Coordinator, SMMC PrimeCare, and the following staff from Medical Mutual.
Terrance J. Sheehan, M.D., President/CEO
Cheryl Peaslee, Asst. VP, Risk Management
Sue Boisvert, Sr. Risk Manager
Nancy Brandow, Sr. Risk Manager
Mary-Elizabeth Knox, Asst. VP, Claims
Jim Bilodeau, Sr. Claims Rep.
Ted Westerfield, Sr., Claims Rep
Of particular interest was the last presentation of the afternoon by Ms. Knox regarding the relatively new Medicare requirements regarding the reporting of write-offs. These requirements come from Section 111 of the Medicare, Medicaid and SCHIP Extension Act of 2007 (42 U.S.C. 1395Y(B)(2)(A). For purposes of Section 111, risk management write-offs or payments (i.e., actions taken because of an adverse medical incident), are considered liability self-insurance.
WRITE-OFFS BEFORE BILLING MEDICARE
When a provider knows they want to reduce a charge or write-off some portion of a charge BEFORE sending the bill to Medicare, they must submit a claim to Medicare reflecting the unreduced, permissible charges and showing the amount of the reduction or write-off as a payment. In this situation, the provider does not need to report the reduction or write-off to CMS. However, if there is any evidence, or a reasonable expectation , that the patient has sought or may seek additional medical treatment from any other healthcare provider as a consequence of the underlying incident, the provider shall report the write-off, payment, reimbursement or property of value (one example would be a gift card), as a TPOC (Total Payment Obligation to the Claimant) from self-insurance. However, if the value of the write-off or payment is less than the following TPOC reporting threshold, it does not need to be reported:
- 10/01/2010 through 01/01/2012 $5,000
- 01/01/2012 through 12/31/12 $2,000
- 01/01/13 through 12/31/13 $600
- After 12/31/13 zero threshold
This obligation to report begins with any write-off or payment made to a Medicare beneficiary on or after Oct. 1, 2010. Non-compliance with Section 111 reporting will result in a penalty of $1000 for each day of noncompliance with respect to each Medicare beneficiary.
WHAT DO YOU DO?
If a practice has any expectation that it may be in the position of deciding to write-off bills, reimburse money or even provide property of value (such as a gift certificate) to a Medicare beneficiary as a consequence of an adverse medical incident, the practice should:
- Educate itself by reviewing the provisions set forth at www.cms.hhs.gov/MandatoryInsRep
- Consider consulting your corporate counsel
- Register as a reporting entity with CMS
- Become familiar with the Direct Data Entry (DDE) option for small reporters
Practices insured by Medical Mutual are always free to call the company and discuss the situation with staff in the claims department.
MMA thanks Medical Mutual and Mary Elizabeth Knox for permission to reprint materials on this topic.
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