Business Associates Agreement Now Required

Back in September of 2013 it became a requirement that any provider using an outside medical billing service must have a Business Associates Agreement on file.  This is the responsibility of the provider, not the billing service, but only 2 out of over 40 of our providers even contacted us to see if they have one.  That amazes me.  I’m not sure why.  I know providers main task is to treat patients, but they must make themselves aware of the other responsibilities that they have as well.  If they don’t then they need to make sure that they have someone else looking out for them.

For example, have an office manager, or their spouse making sure that they are keeping up with all these changes.  I can only wonder how many are ready for ICD 10.


We recently sat down with a husband and wife, both MDs, who had no idea about the BSA.  We don’t do their billing but we do other work for them.  When we mentioned it they had no idea what we were talking about.  And their billing service didn’t mention it to them either (no surprise there though).


If you are a billing service, or if your office uses a billing service, make sure that the BSAs are on file.  If you are a service, do your providers a favor and do it for them.  Tell them it is their responsibility but you have one all ready for them.  They will appreciate that and knowing that you are looking out for them.  They will also be reassured that you are up on what’s happening.

New Marketing Opportunity

In the last two months we have signed up more new accounts than we generally sign up in a year.  When we talk to others we find that this is very common right now.  This is a great time for medical billing services to be out marketing.  Providers are looking for solutions to the problems that are arising with all the changes happening in the field of medical billing.  The change to ICD10s seems to be freaking out a  lot of providers.  Some just do not wish to update their software to become compliant with the changes.  Some just want some of this work taken from their offices.

We have also heard and seen ourselves that some billing services have recently gone out of business.   We were recently contacted by a marketing service we previously used.  Our representative told us that they have had really good results lately particularly with medical offices that have been billing in house.  They feel with all the changes in the field this year that it is too much to handle the billing in house any longer.  The rep also told us that several medical billing services have gone out of business leaving their accounts to find new billing services.

With the costs involved in updating practice management systems for the new CMS 1500 forms and ICD10 codes, many struggling businesses decided to call it quits.  We personally are seeing the results of a local billing service that wasn’t doing a very good job fall apart.  This is a great opportunity for the billing service that wants to offer great customer service to their clients to advance.  It’s a great time to be marketing!

Lots of Changes for 2014

It seems that this  year in particular there are so many changes in the field of medical billing that it is cause for concern in many medical offices.  With the implementation of the Affordable Care Act, (more commonly known as Obamacare)  (and what’s affordable about it??) the implementation of ICD10 diagnosis codes, the threat of being penalized for not satisfying the PQRS requirements and the newly revised CMS 1500 forms there is almost panic in many medical offices.

Everyone is asking how the Affordable Care Act is going to affect them and who really knows.  It’s going to cause more people to be covered with health insurance so there will be more doctor’s visits and more insurance billing to be done.  Other than that we don’t know what will happen.

The requirement to file claims on the newly revised CMS 1500 form requires new software.  This can be an expensive upgrade for many.  Some offices do not want to go through this and are looking for alternatives.

The implementation of ICD10 codes is going to be a challenge for many offices.  As we haven’t seen a change like this in many years it is difficult to predict how it will affect us.

Understanding PQRS

PQRS (Physician Quality Reporting System) is an extremely complicated system of reporting quality care for Medicare patients.  Originally it started as PQRI (Physician Quality Reporting Initiative), an initiative which paid an incentive to providers for using the reporting system.  It is now going to penalize providers who do not use the system by applying payment adjustments to physicians who do not satisfactorily report the quality measures.  PQRS applies to most providers who bill services for Medicare patients.
CMS states that the first step is to determine if the provider is eligible to participate in PQRS.  A list of PQRS eligible providers can be found at:

Click to access PQRS_List-of-EligibleProfessionals_022813.pdf

Next determine which reporting method best fits their practice.  There are four methods:

    Claims based
    Registry Reporting
    EHR Based Reporting
    Group Practice Reporting Option (GPRO)

Claims based reporting is the traditional reporting option.  It involves submitting CPT-II or G Codes on the Medicare claims for the patients being reported.  In order to qualify using the claims based option, an eligible provider must satisfactorily report on at least 50 percent of eligible instances.  (We are going to cover the claims based reporting option and the G codes in depth in our next newsletter.)

Registry Reporting is done through qualified registries.   Qualified registries are vendors that submit quality measure data to CMS using a source other than an EHR.  Providers would manually input or upload the patient data into the qualified registry.  The qualified registry then calculates the PQRS and submits those calculations to CMS.

EHR Based Reporting is done through an Electronic Health Record system.  Providers may submit PQRS measures through a qualified EHR system.  The qualified EHR system vendor would forward that data on to CMS.

Group Practice Reporting Option is done when a group of providers opts to participate in PQRS as a group practice.  The members of a group who opts into the Group Practice Reporting Option (GPRO) relinquish their right to participate in PQRS as an individual provider.  The PQRS incentive is then calculated based on the group’s total estimated Medicare Part B charges for the year.

Once the method is determined it is important to set up an office workflow to make sure the reporting is completed.  If using the traditional reporting option, or claims based reporting, then the codes used to report PQRS could be added to the encounter form.  If a paper encounter form is used then that would be fairly easy.  The provider can simply check off the appropriate reporting codes and the biller would simply add them to the claim when it is billed.  If the provider uses an electronic system then the codes need to be added to that system so that they can be reported on the claims.  The important thing is to establish a system to ensure that the PQRS reporting is done.

Providers do not need to notify CMS or their Medicare regional carrier prior to beginning reporting.  Simply add the codes to the claims and submit.  Many providers and billers are avoiding figuring out what PQRS is because it seems too complicated.   But avoiding it will end up costing the provider money.  How much money is lost will depend on how many Medicare patients the provider sees.

(Next newsletter will cover the claims based reporting method including the codes used in greater detail.)