September 2013
Welcome to Synergistic Update. This
newsletter is our vehicle to provide information about SOS Software,
events in the healthcare industry, links to important regulatory
information, and notes about recent blog posts. Please let us know what
issues you would like to hear about. And remember, your feedback is
welcome at any time!
In
this issue:
Move to ICD-10 is on the way: SOS's ICD-10 Plans
New CMS-1500
Forms Required Soon: Do you use a special HCFA form?
Microsoft
discontinues support for Windows XP in April 2014
NOTE:
Emailing PHI is not HIPAA Compliant
HIPAA-secure
online Backup...with a BAA
Filing
Secondary Claims Electronically through Emdeon: New document
available
SOS
Staff Profile: Noe Gamez, Technical Support Representative
Customer Spotlight:
Laura S. Morrison, Ph.D.
Recent blog
articles available:
Brain 2013, January 10, 2013
Violence in our Lives: What to do?,
January
17, 2013
P.S. on Gun Violence in our Lives,
January 22, 2013
HIPAA Final Rule Finally Released,
January 31, 2013
Caregiving Revisited, February
12, 2013
PQRS Intro, April
16, 2013
Thoughts on the Quality of Death and Dying:
A personal reflection, June 18, 2013
ICD-10 Implementation, June
27, 2013
New Blog Strategy: Short, targeted
posts....States prep for health information exchange in emergency,
July 18, 2013
PHI Leaks: The Insider Threat, July
24, 2013
'Single Payer Healthcare Would Save US
$Billions' Study Shows, August 1, 2013
Now Open for Enrollment: Health Insurance
Marketplace, August 8, 2013
HIPAA Breach Fines Grow, August
19, 2013
Contractor vs. Employee: How does your
organization decide?, August 29, 2013
HIPAA Omnibus Rule: How much time have you
spent?, September 6, 2013
New CMS-1500 Forms Required Soon, September
13, 2013
HHS Releases Model Notice of Privacy
Practices, September 20, 2013
Move to ICD-10 is on the way: SOS's
ICD-10 Plans
On
October 1, 2014, all health care providers will be required to utilize
ICD-10 codes on claims in order to receive payment. The following is
a detailed Q & A by Seth Krieger, President of
Synergistic
Office Solutions, to address the software issues involved in
accomplishing this goal. Please do read it carefully.
The
Questions and Answers below often make reference to an SOS update that
includes ICD-10 features. In this discussion, that update is a set of
enhancements to the current generation of SOS software, not our
next-generation SOS product known as "Silver". Silver will, of course,
include the same range of features, but the release date of that
product is still uncertain, so we have decided to make all those
features available in the current generation of software as well.
Again, the discussion below refers to an update of the current
generation SOS software.
The
transition from ICD-9 to ICD-10 is a very big deal:
- The
new codes are much more specific than the old ones,
so there are many
more of them (approximately nine times as many) from which to choose,
and most often there is not a one-to-one correspondence between the
codes in the old and new systems.
- The
coding system itself is different. For example, the first character of
every ICD-10 diagnosis code is a letter instead of a number, and the
code itself could be as many as seven characters compared to ICD-9's
maximum length of 5. The only really familiar thing is that there is
still a period/decimal point after the third character.
- The
change in codes means that insurance payers have to either re-program
their payment systems based on the new codes, or, at least in the short
run, use software mapping to translate the new codes back to an old
code that the payment system will recognize for proper claim
processing. The needed changes on the payer end are very extensive. As
a result, most industry insiders expect the transition to be extremely
disruptive for all concerned. Smart
providers will be setting aside funds, or negotiating lines of credit,
so that business operations can continue normally in spite of expected
insurance payment delays next fall.
In
the coming months your claim processors and perhaps even your insurance
payers may ask you details about your readiness to start submitting the
new codes on your claims when the transition date of October 1, 2014
arrives. Your readiness depends in part on the readiness of your
software. Here are some of the questions you might want to ask SOS and
our responses:
Q. I use DSM codes instead of
ICD-9. Does any of this pertain to me?
A. Actually, ALL
of it pertains to you. Except, perhaps, for some small, niche
managed-care administrators, the health insurance industry is
standardized on ICD coding. In fact, ICD-9 diagnostic codes are one of
the required standardized code sets required by the HIPAA legislation
since at least 2004. Happily for those of you who are using DSM
documentation to determine your patients' diagnoses, the DSM codes
overlap with ICD-9 codes almost completely. As a result, when your
DSM-coded claim reaches the payer, it has been processed in accordance
with adjudication rules that are actually based on ICD-9 codes. Please download American Psychiatric
Association's document on DSMV, ICD-9 and ICD-10 if this matter
concerns you.
The
transition to ICD-10 codes, however, removes the overlap completely.
DSM-IV code books do not match up with ICD-10 codes, so you will have
to change from the codes you are currently using to the appropriate
ICD-10 codes starting on October 1, 2014 in order to receive insurance
payment. The recently released DSM-5 code books sold by American
Psychiatric Association include appropriate ICD-10 codes, in
parentheses, next to each diagnosis description, so purchase of those
resources may be of some assistance to you in selecting the correct
codes to put on your claims starting in October, 2014. That said, your
best resources for ICD-10 diagnosis coding to assure rapid insurance
payment will be ICD-10 code books, not DSM-5 books.
Q. Will SOS automatically map or
somehow convert the current codes in my SOS claim setups to ICD-10-CM
codes?
A.
There is no way for software to accurately convert every ICD-9-CM code
to an equivalent ICD-10-CM code. In many cases the old ICD-9 code has
been replaced by a multitude of new ICD-10-CM codes. SOS has no way to
know which of the new codes would be the right one for a particular
patient. That said, SOS will be releasing a software update in late
September, 2013, that includes what we are calling the "SOS ICD-10 Prep
Utility". The utility will be available on the Tools menu in SOS Office
Manager and will allow you to gradually work your way
through your
patients' current diagnoses to set appropriate ICD-10 diagnoses to be
used starting next October (a year from now).
As it happens,
many mental/behavioral health ICD-9 codes have only one ICD-10 match in
the CMS General Equivalency Mapping (GEM) table. When you open a
patient in the Prep utility, it will automatically insert the
appropriate ICD-10 codes wherever there is an unambiguous match
of this sort. When there is not an obvious match, clicking a button on
screen will show you all the likely matches for the current codes,
based on CMS's GEM table, so you can select the best match for this
patient without having to sift through all 90,000 ICD-10
codes.
We
are providing this utility now so that you have a full year to prepare
your patient data, rather than putting you in the position of waiting
nervously for SOS to release new software that accepts the new codes.
The ICD-10 selections you make using the Prep Utility will, of course,
be saved in your database. When SOS's ICD-10 compatible software is
released in 2014, your chosen ICD-10 codes will automatically be
imported and will appear in SOS, ready for insertion into your claims
when you need them. Your current ICD-9 codes will appear in the new
software as well, and will be used on your claims until the changeover
date you specify for your payers.
Q: What is your timeline for system
modifications and what do those modifications include?
A:
The ICD-10 Prep Utility will be available by October 1, 2013. No later
than June 1, 2014, SOS will release a version of the SOS software that
accepts both ICD-9 and ICD-10 diagnoses. A new System Option will
provide a field for you to specify the default date for SOS to start
using ICD-10 Dx codes in place of the old ICD-9 codes. This date will
be preset to October 1, 2014, but, in the unlikely event that CMS
delays implementation, you will be able to change that date. In
addition, each insurance payer configuration will have a new field
where you can specify a payer-specific ICD-10 changeover date, if
different than the system default date. The SOS update will also
include new ICD-10 compatible paper claim formats, and the necessary
adjustments to the 5010 electronic claim generation.
Q: Is there a cost for SOS users to
update to the ICD-10 compatible software?
A: This ICD-10
update of the current generation of SOS will be available to all SOS
customers with current
support contracts at no additional cost. Those who do not have a current
support contract will have to renew their contracts to obtain the
update.
Q: Will you continue to support the
old software, or are you discontinuing some products in the wake of the
ICD-10 transition?
A:
SOS will continue to provide support to all customers with a current
support contract. For example, if a customer's use of the software does
not require ICD-10 capability, that customer will continue to receive
support for their older version of SOS after the ICD-10 update is
released if the customer has a current support contract.
Q: Are there any new hardware
requirements associated with ICD-10-related software changes?
A:
The SOS software discussed above is an update of the current generation
of SOS products that first appeared in 2007. If you are currently using
a version between SOS 2007 and SOS 2013, no hardware changes will be
required to run the ICD-10 update.
Q: Will training be provided for
any new ICD-10-related functionality, and is there a charge?
A:
Articles detailing the use of the new features will be provided at no
charge on the SOS web site for both the ICD-10 Prep Utility and the
ICD-10 capable update to the software. The software changes should not
require any special training beyond that. Providers
and billers should, however, take advantage of any available training
on ICD-10 coding itself, particularly in their own specialty areas.
Neither your SOS software nor SOS Support Techs will teach you
to
correctly code your claims. Correct coding is your responsibility.
Q: Is
the update you describe the same as the "Silver" or "next generation"
software that I have seen mentioned on the SOS User Group?
A:
No. Silver does contain the full range of ICD-10 features, but its
release date is still uncertain. For this reason, SOS has decided to
provide an update to the current generation of software in the
meantime.
New
CMS-1500 Forms Required Soon: Do you use a special HCFA form?
CMS
has announced deadline dates for use of the new HCFA form that will be
ICD-10 compatible. CMS will begin accepting the new paper form (for
those who have a special exemption to send paper Medicare claims) on
January 6, 2014. Starting April 1, 2014, Medicare will accept only the
new form. The information and links below are from an email
notification we received on September 5, 2013.
"CMS-1500 Claim Form Updates: Medicare to Accept Revised Form Starting
January 2014
The
CMS-1500 Claim Form has been recently revised with changes including
those to more adequately support the use of the ICD-10 diagnosis code
set. The revised CMS-1500 form (version
02/12) will replace version
08/05.
The revised form will give providers the ability to indicate whether
they are using ICD-9 or ICD-10 diagnosis codes, which is important as
the October 1, 2014, transition approaches. ICD-9 codes must be used
for services provided before October 1, 2014, while ICD-10 codes should
be used for services provided on or after October 1, 2014. The revised
form also allows for additional diagnosis codes, expanding from 4
possible codes to 12.
Only providers who qualify for exemptions
from electronic submission may
submit the CMS-1500 Claim Form to Medicare. For those providers who use
service vendors, CMS encourages them to check with their service
vendors to determine when they will switch to the new form.
Medicare
will begin accepting the revised form on January 6, 2014. Starting
April 1, 2014, Medicare will accept only the revised version of the
form."
As you
know,
private insurers will follow CMS' lead on use of the new form. SOS
users with current support agreements
will be able to obtain an update containing the new format before the
Medicare deadline.
| If
you use a special or custom HCFA form (such as NY Medicaid), please
contact SOS. Updating any such forms will require custom
programming
and will not be done as RUSH orders. Please contact SOS NOW if you use
such a claim form. |
Microsoft
discontinues support for Windows XP in April 2014
Microsoft
has announced
that it will discontinue all support and updates for
Windows XP on April 8, 2014. This has implications
for
you if you are still using Windows XP on any of your computers.
When
Microsoft discontinues support for a product, they will no longer
provide updates for that
product. This makes your
operating system susceptible
to attack by
criminals wanting to hack into your computer. You see, as long as you
have been doing automatic updates of Windows XP, each time someone
finds one of the many vulnerabilities in this operating system,
Microsoft creates a fix for that weakness that is
automatically
installed on your computer. This automatically keeps your system from
being hacked by way of these vulnerabilities.
With
no more fixes comes exposure to every virus and trojan horse that
thieves and hackers can come up with. Your credit card information,
your
patient's Protected Health Information, anything you thought was secure
on your Internet-connected computer is no longer so. Such vulnerability
means that your computer system is not compliant with the requirements
of HIPAA....your PHI is at risk. If you keep customer information (like
credit card info) on the machine, that also is at risk putting you out
of compliance with your credit card vendor.
If
you have not already moved all of your computers from Windows XP to one
of the newer versions of Windows,
please begin your transition right away.
Important
Note to our Customers: Emailing PHI is not HIPAA compliant
SOS
would like to remind you
that email is not secure. Unless you use encrypted email, or
you can document that the patient has approved it, you
should never include Protected Health Information (PHI) of any
kind in the subject or body of an email message. Any
attached documents should be cleansed of PHI before being sent, or the
document should be zipped with 256 bit AES encryption or better, prior
to being
attached to the email message. The password to open the document should
be conveyed to the receiver by phone or fax.
If
your email is going to SOS, you can fax the encryption password
to SOS at 888-609-5514 or you can forward it to us by
telephone at 352-242-9100, option 1. Never include the password in an
email.
We take the protection of your PHI very seriously.
Anytime we receive an email from you that contains PHI, we notify you
of the potential breach of information and we enter it into our own
Breach Log, as required by our HIPAA policies. Please carefully review
anything you send to us by email before it is sent.
|
HIPAA-secure
Online Backup...with a BAA
As
you may be aware, we have recommended online backup through products
like Mozy and Carbonite for quite some time as a supplement to local,
first line backup strategies. We emphatically do NOT recommend any
single backup strategy as your ONLY
backup, but online backup is very
slow relative to the other methods, which is why its best place in the
system is as a supplemental, off-site backup and part of your
HIPAA-mandated Business Continuity and Disaster Plans.
A
couple of things about using online backup for your SOS data and other
protected health information (PHI):
- Like
the rest of your backups, your
online backups must be encrypted before they leave your computer. By
default, the online backup vendors stress how easy it is to use their
services. Although many of these companies offer "client-side"
encryption (arguably, the only kind of encryption that would be
HIPAA-compliant), it will be an option,
and is unlikely to be
the default.
- A
new wrinkle is that healthcare lawyers, interpreting the latest
revision of the HIPAA rules, insist that online backup vendors are
among the vendors from whom you must get a signed Business Associate
Agreement (BAA) if you plan to continue to use them. As custodians of
your
data, theoretically they could be the reason for a data breach that
could
compromise the security of your patient records. If that were to
happen, you would certainly want to be able to force them to accept
their liability for the breach and get their assistance in responding
to it. That is what a current BAA with your backup service would do for
you. While they have not previously been willing to do so, we have
reason to believe that at least two of the popular
services, Mozy and Carbonite, may be willing to sign a BAA with you if
you push for it. Do not be surprised, however, to learn that their
agreements REQUIRE that you use their client-side encryption option.
The reason is simple: even if their facilities were completely
compromised, if your data is encrypted before it even leaves your
system, then, by HIPAA definition, a breach is not possible. You (and
they) would be in the safe harbor HIPAA allows for encrypted PHI. If
there
is no breach, then there is no way they will ever have to clean it
up.
Here are the takeaways:
- You
must do local backups under any circumstances, but
supplementing with online backups is strongly recommended for disaster
recovery and as a backup to your local backups.
- All
backups, whether local or online, must be encrypted by turning on
the encryption options in your backup software. If you are doing file
copies as your backup, you must use something like WinZip or 7Zip to
encrypt the files during the copy process.
- If
you are using an online backup service, and you want to be sure that
you are HIPAA compliant, then be sure to get a BAA from your backup
vendor. If your backup vendor won't sign one, then switch to a vendor
who will. Encrypt the backup before you send it to the online service.
Once you have a backup saved on the new system, delete all
your backups on the old system and uninstall the old vendor's software
to avoid accidental use.
This
past month, two more SOS customers experienced serious data loss
because they did not have a working backup system. SOS
guidance on
what you should be doing for backup is readily available. Please use it!
Filing
Secondary Claims Electronically through Emdeon: New document
available
Manon recently noticed that many
of our Emdeon customers were getting rejections for secondary claims.
She updated our document on electronic filing of
secondary insurance claims for your edification. Please let us know if
it is helpful to you.
SOS Staff
Profile
Noe
Gamez,Technical Support Representative
We
decided that it
might be fun for you, our customers, to know a bit more about those of
us
who
work here at SOS. After all, you talk to us often, but many of you have
never
met any of us. Noe Gamez is someone most of you have spoken to. As one
of our Technical Support Representatives, he spends most of his time on
the telephone solving technical support problems for you or answering
your questions about how to accomplish certain tasks. Here are Noe’s
answers to our standard questions.
How
long have you worked at SOS?
I have been
with SOS since January 2000.
How
would you describe your role at SOS?
I
would describe my role as someone who makes sure things are working
properly for our customers.
How
do you prefer to spend your time when you are not
working?
It
varies on the mood that I'm in. There are days when I would just curl
up and read a book from beginning to end. Then there are other days
when I like to go hiking or doing any activities that involve the
outdoors.
What
else would you like our customers to know about
you?
Two
things:
Yes,
my real name is Noe, and
I'm really a nice guy in person!
SOS Customer
Spotlight 
Laura
S. Morrison, Ph.D.
Morrisons Psychotherapy
Graeagle, California
Dr. Laura
S. Morrison has used SOS software since May 1991. Below are our
questions and her answers.
For how long have you been
providing services to your community?
28
years in Plumas County (which includes Graeagle); we were initially in
Quincy. I've been in Graeagle 8 years.
How
many staff members are involved in your organization? What are their
credentials?
At
this point there is just me. My husband and I were in practice together
from 1990 to 2011; he was an LCSW. However, he passed away two years
ago. At this point, our county is extremely short on private-practice
psychotherapists and mental health services in general.
What
areas of specialization do you provide to your community?
There
are areas I especially like, but I see a real variety of clients since
I'm the only psychologist and virtually the only licensed therapist in
private practice in the county. I do a fair amount of psychological
testing, for courts and county agencies for two different counties. I
mostly see clients individually--no groups; it's much too small a
community for anonymity. I work with a lot of clients with PTSD,
anxiety disorders, and all the kinds of things that usually come up.
Since
I work in a retirement community (and I'm getting closer to that age
myself), I see quite a few retirees. That has turned out to be far more
interesting and satisfying than I would have thought possible.
Retirees, and older people in general, are working on some very tough
issues. I also do a fair amount of marriage counseling with
retirees--very interesting, since long-term married people and older
people have much more motivation to stay together.
I have also
become very interested in working with clients suffering from major
depression. This, too, is not an area most therapists are interested
in--it takes a lot of patience, and a much more directive approach than
one would use working with other kinds of clients.
I
consult with several other agencies in town, including ones working
with abused children. However, I don't see children much anymore; I
started out my career doing a lot of work with children, but I guess
I'm beginning to feel a little too old to get down on the floor and do
play therapy. I still very much enjoy testing children. I guess, in
doing testing with both children and adults, I've never lost that
fascination, wondering how the tests are going to come out, what I'm
going to see that I didn't expect. In doing evaluations, I also enjoy
pulling a great deal of information together from all the sources I can
contact and trying to integrate that information into something that is
really going to help the client/family/agency.
What is your
mission statement? How do you want your community to see you?
In
a very small town like this, everyone talks about their experiences
with their therapist with everyone else. And I think I'm respected, the
"go to" person for mental health information and advice that others
might not have. I've done quite a bit of clinical supervision with
therapists (and have seen quite a number of them in therapy); I've
consulted with agencies, attorneys, and nonprofits; sometimes people
call me, just asking me what kinds of services they need, and I can
help them figure that out (although our services are limited). I guess
I'm saying that there is something satisfying about being older and
more experienced in our profession; we don't "age out" as quickly as
some professions do. It sounds silly, but I think I'm enjoying being
seen as wise. If I lived in a tribal culture, I would enjoy being a
wise woman. After spending all these years accumulating information, it
feels good to be able to give back.
What
would you like to share with the SOS community of professionals who use
our software? Please include any unique things about your organization,
any interesting ways you use our software, what your special place
within your community is, how you are like/different from other
practices/organizations, or anything else you would like to share.
We've
been using SOS software since 1991, and I've seen so many changes and
improvements in what you have to offer. I remember when the first
Windows version came out (I'm dating myself), and thinking, "This is
really complicated." But I've used almost every one of those features
over the years. I guess what I use the most is the insurance tracking.
Being able to immediately look at any client, see which sessions
insurance has and has not paid, and how much, how long it took, and how
many authorizations are left, and what's happening with the second
insurance--that kind of information has been invaluable.
Because
I live in a rather poor county, I have to accept insurance. I know a
lot of therapists are cash-only these days, and the insurance companies
are so nasty that I don't blame them. If I weren't using SOS, I
wouldn't even attempt the insurance billing, but SOS makes the
impossible possible. Insurance companies count on the fact that
therapists are so overworked and not very good at billing that they
probably won't follow up on a payment if the insurance company denies
it. But with SOS, I'm usually on top of it, and I have a pretty good
collection percentage. One of my therapist friends uses a billing
service, but she still has to do all this work (by hand!) to get the
paperwork ready for the billing service! Entering clients and
transactions in OM is so easy that I can't imaging doing it any other
way.
And when Medicare started expecting us to use all these
exotic codes to document our compliance with their "good practice"
standards, I could just incorporate those in as simple transactions
(with a $0.01 charge). Frankly, Medicare is really very easy with
OM...and with ECM.
But the electronic billing is astonishing; it
has changed my life. When I was still struggling to get everything set
up and working, one of my therapist friends in Reno said, "It's so
easy." That gave me hope and kept me going. So I want to tell your
readers this: It is really so easy, and it is SO worth it. The toughest
snag I had during setup was that the program didn't seem to like the
information I entered for referral sources (doctors), no matter what I
did. But Manon helped with a workaround for that. The only problem that
I've had recently is that the process is so easy (takes about 5
minutes, once I've entered everything and closed the daysheet) that I
don't pay enough attention to insurance company denials. I recently
discovered (with the help of Emdeon) that one particular insurance
company was denying a lot of claims for really obscure and trivial
reasons. So I will also say: Check your Emdeon claims information every
month or after you send a billing batch. Emdeon also lets you print out
documentation that you billed that session months ago, for those nasty
insurance companies who deny claims and then won't pay for a claim more
than three months old.
SOS is really incredibly useful, even
(maybe especially) for small practices. So whether you're old or young,
and whether or not you're comfortable with a computer, it's worth
learning the program and using it. It makes it possible to do rather
complex insurance billing, to bill agencies for multiple clients, and
all without a secretary. In other words, the way our profession is
going, you just about have to have something like this to survive.
"CMS-1500 Claim Form Updates: Medicare to Accept Revised Form Starting
January 2014