Hospitals are required to document physician time in numerous categories, ranging from physician Medicare Part A administrative time to, for some academic institutions, physician teaching time and pre- and post-transplant time. It’s an exacting and time-consuming administrative and financial responsibility that entails navigating a complex patchwork of regulations [42 Code of Federal Regulations §415.60(b)(1 through 3)], including the program instructions of the CMS Provider Reimbursement Manual [CMS Pub 15-1 §2313.2 E].
Limitations of Current Methods
Many providers continue to employ paper-based methods or electronic spreadsheets to complete this challenging work. However, these traditional methods tend to discourage participation by physicians and often create frustration and confusion for both physicians and hospital staff, potentially resulting in significant losses of reimbursement dollars. These outdated approaches no longer make sense in the current “do more with less” healthcare environment.
Hospitals must rely to a large extent on physicians to accurately report their time. Unfortunately, many physicians see the process as an administrative burden that interferes with their ability to practice medicine and care for patients.
Navigating the Regulatory Maze
Even small discrepancies in reported time can result in substantial reimbursement losses. Effective software solutions can help providers catch these discrepancies before they translate into losses. One significant area of vulnerability is reimbursements for acute care hospitals paid under the prospective payment system. Reimbursements are affected by wage index data reported for physician Part A time (administration and teaching) on Worksheet S-3, Part II of the Medicare cost report. The importance of capturing, documenting, and reporting physician Part A administration cannot be overstated. However, many hospitals lack an efficient and effective way to report physicians’ higher average hourly wages in a manner that fully complies with regulations and program instructions.
Another consideration is the Office of Inspector General (OIG) of the U.S. Department of Health and Human Services “Work Plan” for fiscal year 2015, which calls for an analysis of salaries included in hospital cost reports and reimbursed by Medicare as well as a review of hospital controls over the reporting of wage data used to calculate wage indexes for Medicare payments. Salaries and wage index data have received the OIG’s attention. As a result, even hospitals that consider their existing processes solid would do well to re-evaluate those processes and consider opportunities for automation.
Other areas of Medicare reimbursement that demand close attention include pre- and post-transplant time for hospitals with organ transplant programs, time related to emergency department physician availability services for both acute and critical access hospitals, and time supporting home office allocations and Medicare Worksheet B-1 statistical allocations.
In addition, hospitals in states participating in Medicaid Section 1115 research and demonstration projects should consider the time study documentation needed to secure reimbursement. For example, hospitals in Texas now must consider the new requirements under the Texas Healthcare Transformation and Quality Improvement Program Section 1115 waiver. To secure the maximum amount of payment from the uncompensated care pool, hospitals must distinguish and document physician and midlevel practitioner time spent on direct patient care, hospital administrative and teaching activities, and other nonbillable activities, such as research.
The Stark Law and More
To qualify for the academic medical center exception available under the Stark law, academic medical centers must account properly for faculty time spent on clinical teaching and academic services. The law, which prohibits a physician from referring Medicare/Medicaid patients to a facility in which the physician has a financial interest, has two exceptions:
- When a physician spends at least 20 percent of his or her professional time providing academic or clinical teaching services
- When a signed written agreement, the indirect compensation agreement, exists providing compensation not in excess of fair market value
Adding to the complex mix are further requirements to adhere to a variety of reporting protocols, such as the ability to provide adequate and auditable time studies on request.
How Automated Time Studies Can Help: Crowe® Physician Links
Automated systems to capture, document, and report physician time can meet many of a hospital’s demands and deliver efficiencies and capabilities far beyond anything achievable with traditional methods.
One such solution is Crowe Physician Links software, a patent-pending application that can help healthcare providers more effectively and efficiently handle the entire time study process in a way that adheres to regulatory requirements and improves reimbursement.
Crowe Physician Links integrates physician, finance, and compliance activities to enable organizations to identify hidden reimbursement opportunities that might otherwise be missed; confirm regulatory compliance and mitigate risks with respect to Medicare, Medicaid, and Tricare; improve margins; and identify and establish best practices that can be used to achieve further efficiencies and maximize reimbursements.
Crowe Physician Links offers:
- A system that runs on smartphones, tablets, laptops, and personal computers, allowing physicians to enter their time no matter where they are and helping them make time documentation a natural part of their daily routine
- Customizable views relevant to individual physician activities to minimize the risk of errors by allowing input of information pertaining only to the individual physician’s activities
- Administrative support and automatic email reminders to promote physician acceptance and increase participation
- A single repository for all supporting documentation needed at the time of an audit
- Proactive oversight in real time through such tools as exception reports and drill-down capabilities
- Reporting capabilities relevant to allocation agreements, administrative time, teaching time, emergency department availability, transplant time, research grants, and other areas
The Crowe® Physician Links software solution was invented by Andrew Jay Sutton and others of Crowe. A patent is pending for the Crowe Physician Links solution.