by Tahlia Brody, CHP, VP of Customer Service TLD Systems
December 16, 2020
in order to be HIPAA Compliant, you must maintain a "Culture of Compliance" at your office. This can include keeping your software up-to-date, regular required training and addressing risks that pose to your office. This month we address dedicating a privacy officer, testing your backups and proper disposal of patient records.
“This past summer, one of my patients who was suffering from a diabetic foot ulcer was admitted to a skilled nursing facility (SNF) following a hospital discharge. During her admission to the SNF, I continued to care for her in my office, including ulcer debridement and radiographs. Medicare is denying payment for her ulcer debridements (CPT 97597) as well as the technical component of her radiographs (CPT 73630-TC) on the grounds that “all SNF Part A inpatient services are paid under a prospective payment system (PPS)” and that “services that are considered within the scope or capability of SNFs are considered paid in the PPS rate.” In other words, Medicare considers the care that I rendered to be bundled with the payment to the SNF for admission, and therefore the SNF should have been doing it themselves, and that if I want payment I need to bill the SNF since they–in Medicare’s view–outsourced the ulcer care to me. While I fully expect the SNF to balk at any requests for payment from me, and I believe it might still be worth my time to appeal to an Administrative Law Judge, I would like to know if anyone has experienced this? In the future, if I am going to care for the ulcers of my patients when they are admitted to SNFs, is there anything I can arrange with the SNF or with the patient to ensure I am compensated for their care?”
“Can someone please clarify the postoperative global period for a percutaneous flexor tenotomy for flexible hammertoes? I thought the postop global for CPT 28010 was ten days. I discovered that it is 90 days! Is it really the same as a bunion correction? I performed an in office flexor tenotomy successfully on one foot and now the patient requests correction for the other foot. I understand how a longer global period would discourage so called “serial surgeries” for higher reimbursements for multiple procedures on one foot. But on the opposite foot as well?”
All HIPAA breaches are investigated by the US Department of Health and Human Services – Office for Civil Rights (OCR). The OCR maintains a web site that lists breaches under investigation as well as those that have been resolved. Reviewing this site can provide us with insight into what has gone wrong for other medical providers. It can help us to understand the steps we can take to avoid similar breaches in our practices.