IBHIS GO-LIVE - Claims & Revenue Risk Mitigation Topics

Now that there is an updated LACDMH IBHIS GO-LIVE roll-out schedule and there have been a couple of update calls, I have been getting a lot of questions around the topic of claiming, reimbursement timing, revenue risks, etc.

 I have been assisting my customers lately with IBHIS Risk Mitigation planning .... Here are some topics to consider for your GO-LIVE plans.


·    Cash flow advances – Agencies going live between July – September will receive 3 months’ cash flow advances; others will receive the standard cash flow advance stated in their DMH contract (I understand that this is being modified in the FY16-17 contract to allow for additional cash flow advances should there be any IBHIS claiming issues.)


·    Timeline Example – If your GO-LIVE date were January 2017, mid-fiscal year, then DMH assumes you will stop sending claims to the IS by the end November 2016 and hold all further claims until the end of December and no later than the claims cut-off on January 6^th. All claims ready for submission after your IS cut-off date of Nov 31^st, will be submitted to IBHIS as soon as you are ready, which is estimated to be in late December. Here is a rough timeline of what that might look like:

•        July 2016 – EHRS Vendor must be ready for IBHIS, with most up to date Client Web Services (CWS) and 837/835 changes.

•        August 2016 – check on TPA modification request with DMH / ACHSA. (There is a pending request to modify the TPA agreement to be more mutual, and to remove some of the high risk terms for Legal Entities (LE))

•        Sept. 2016 – LE staff begin preparedness for IBHIS.... PRM updates, sign TPA, Vendor readiness, etc.

•        Nov. 2016 – LE's final push to have all claims submitted to the IS. CWS GO-LIVE, make client data updates in IBHIS using CWS. (Some vendors are doing this for their customers with bathing, others require lots of key strokes by LE staff, be sure you plan staffing time for this!)

•        *Nov. 31^st, LE's IS cutoff – last day to submit new claims using the IS.

•        Dec. 1^st thru approx. Dec. 25^th – HOLD all new claims; continue PRM and CWS updates; work with DMH to validate initial batch of IBHIS claims (on paper); DMH will create MCA estimates and set amounts for P-Auth codes (LE and DMH to agree on P-Auth amounts & MCA buffer %!). 

•        **Approx. Dec. 26^th – IBHIS Claims GO-LIVE, begin submitting new claims in IBHIS;

•        Jan. 6^th – last day to submit IBHIS pending claims for next month’s reimbursement check.

•        Dec 2017 – Current IS shut-down date.

*Dec. and beyond - You will continue working previously submitted IS claims using the IS, i.e. voids, replacements, etc. until IS shut down.

       ** Your IBHIS Claims GO-LIVE can be sooner if ready (once DMH has issued P-Auths), or later. As long as you submit all pending claims before the Jan. 6^th cut-off, you should have no gap in cash flow.

Note: The standard LACDMH IBHIS timeline assumes agencies will not miss any claims cut-off dates for monthly reimbursement, and therefore, should not need additional cash advances for IBHIS reasons. This may not be the case for everyone, you must map our your timeline and determine risks and plan mitigation if you miss these dates!


Here are some ways to mitigate:

•      DMH will allow LE’s to request a MCA “buffer”, a percentage above the MCA for the fiscal year, to avoid unnecessary denials. E.g. If LE voids a group of IS claims after the IBHIS GO-LIVE and does not replace them in the IS, then you may see claims incorrectly denied in IBHIS at the end of the fiscal year, unless DMH moves the voided claims’ funds from the IS to IBHIS P-Auths. Another example would be if IS claims are denied by Medi-Cal several months after your IBHIS GO-LIVE, and you prefer to re-issue these claims using IBHIS, then you will need these funds moved from the IS to IBHIS P-Auths to avoid these being denied for lack of funds toward the end of the fiscal year. The “buffer” will give you some cushion in IBHIS to avoid denials for lack of funding, however, you will need to carefully track your utilization to avoid over spending to plan.
  
  Question for DMH: How will DMH handle denied claims in IBHIS and the P-Auth amounts? e.g. Will DMH deduct the Medi-Cal fund amounts each time a claim is forwarded to the State, or wait until they have a response from the State? If the former, then will DMH add back the IBHIS denied claim amounts to your IBHIS P-Auths as soon as a denial comes from the State?
  
•      Maximum Contract Allowance (MCA) & P-Auth amounts – During the above claims HOLD time, DMH will calculate the LE’s remaining funding by plan based on their IS data (Maximum Contract Allowance - MCA). DMH will issue the IBHIS P-Auth codes that reflect their remaining funding by plan.  In IBHIS, any claims sent once the plan’s P-Auth code reflects that funding has been depleted, will be denied real-time. If the LE’s MCA is being shared in FY1617 between the IS and IBHIS, it is critical that the LE create their own estimate of their remaining MCA by fund to compare to the DMH MCA calculations prior to issuing P-Auth codes.
  
•      Claims validation just prior to GO-LIVE – DMH will provide a claims validation (paper Excel based method) just prior to your GO-LIVE, which is voluntary. I recommend you take advantage of this step. You will need to complete a DMH Excel template with all claims data for the initial set of claims you intend to submit to IBHIS in your first go-live month, and DMH staff will review the claims data for any issues that would cause rejections of denials. This will assure a smoother GO-LIVE. For large LE’s I recommend you take this approach for 2 months if you find significant changes needed in the first month validated.

As always, hope this provides some clarity and guidance to you! Call me if you need help.

Meaningful Use Incentive Funds available to Behavioral Healthcare Agencies, Deadline Approaching.

DID YOU KNOW THAT YOU QUALIFY FOR INCENTIVE FUNDS
THROUGH THE MEANINGFUL USE PROGRAM,
 AND THEY ARE EASY / QUICK TO OBTAIN?

Meaningful Use funds are still available to you, but not for much longer. The Bottom Line...

• Year 1 incentive = $21,250 for each MD & NP (Eligible Providers or EP)
• You likely qualify now, contractors and/or full time & part time
• Easy to qualify, only 1 data entry staff and 1 provider contact lead needed
• Quick to receive, ~4 – 5 months
• Deadline to complete application is fall 2016
• Forgoing $63,750.00 per EP, over 6 years

Sahara Management Solutions can help you obtain these funds quickly.

I want to make you aware of this service that I have been providing to my customers …. Applying for Meaningful Use incentive dollars. I have been very successful at quickly obtaining the first year Adoption / Implementation/ Upgrade (AIU) incentive payments from the State, for Medi-Cal service providers.

This incentive is $21,250 for each of your MD’s and NP’s (Doctor of Medicine & Nurse Practitioner), even if they are contractors and/or part-time, in the first year.

You are running out of time to apply for this first year incentive, if you do not apply before the fall 2016 cut-off, then you are unable to apply for the remaining 5 payments, for a total opportunity of $63,750.00 per eligible provider.

Also, you are currently being penalized for non-participation via Medicare reimbursement reductions. See my BLOG on this topic HERE.

Trying to do this yourself will be VERY time consuming and VERY frustrating. and unlikely to result in meeting the deadline and receiving the payments. There are hundreds of documents and three websites chocked full of information, but nothing that simply points you to the step by step process. I don't say this to discourage you, but only to warn you. It took me hundreds of dedicated hours to find my way through this maze!

I have a proven process and step by step documentation.My services essentially pay for themselves! Here are the steps necessary that I will help you with, to enable quick receipt of these incentive funds:

·  Planning & Training - an executive overview of the process and timeline; training ONLY one staff member to complete the required data entry (including step by step training materials);

·  Provider Benefit Reassignment - coaching for the provider communication and benefit reassignment steps, including consultation, templates, and best practices; phone and email support to the provider contact;

·  Provider Account Creation - facilitation of the initial provider account creation steps, both at federal and state level; phone and email support to the staff member; coordination with State and Federal help desks;

·  Provider Registration - facilitation of the provider registration steps, both at federal and state level; phone and email support to the staff member; coordination with State and Federal help desks;

·  QUALITY rEVIEW phase - a complete review of each provider registration to avoid submission errors;

·  Provider Final Attestation - facilitation and production of the final attestation documents;

·  State Approval - coordination with State analysts during their approval phase;

·  PAYMENT– assistance with budget assumptions, and tracking and reporting on payment status.

So, don’t hesitate, call me now to start the application process and receive your incentive this year!

Keely McGeehan

ICD-10 deadline, October 1, 2015 service dates; Updates from LACDMH, IS and IBHIS

ICD-10 deadline, October 1, 2015 service

• For DHCS contracted services, beginning in October you may use the ICD-10 codes, for both chart medical necessity compliance and billing (required for claiming), and avoid using DSM (see DMH slides on this); per DMH: “Contract providers will provide DMH with the ICD10 diagnosis for the claim and for CSI admission.” Therefore, what most providers / EHRS vendors are planning on, is to have the clinician choose the DSM 5 and ICD-10 codes for every client (there is no longer a one-to-one relationship between DSM and ICD, so the EHRS cannot determine which ICD-10 code to use based on the DSM 4 or DSM 5 Dx chosen by the clinician. You need to train your clinicians on both ICD-10 codes and DSM 5.
• For other non DHCS contracts, such as Drug Medi-Cal / Substance Abuse, you may also need a DSM 5 Dx starting in October.
• Steps you need to take prior to October 1st service dates:
• If you are an IS DDE claimer... your IS client episode records need the ICD-10 codes entered, or your claims will be returned with a "rule fail", for all service dates beginning Oct. 1st.
• DMH clarified for contract providers who are billing to the IS via data entry (DDE) – DMH is looking into converting some of your client open episodes' Dx in the IS for you (by mid-Sept.), by converting DSM 4/ICD-9 codes to ICD-10 codes (using the State ICD9 to ICD10 crosswalk). However, there is not a one-to-one mapping of ICD-9 codes to ICD-10 codes, so some clients’ ICD-10 codes (5 Axis) will need to be determined by the clinician and then entered into the client’s IS record before you can bill for their services beginning with dates of service October 1, 2015.
  Note:  you need to know when and if DMH does this conversion and how you will know which Dx’s need your clinicians' attention and what to do about them.
  
• Any DDE claims for service dates beginning Oct 1^st that do not have a valid ICD-10 code in the IS record (DDE) will receive a "rule fail" upon claim submission. 
• Your claims need the ICD-10 codes in them, IS EDI and IBHIS EDI, for service dates beginning Oct 1^st.
• Any IS EDI claims for service dates beginning Oct 1^st that do not have a valid ICD-10 code in the claim, will received a "rule fail" upon claim submission. IS EDI claims will proceed without issue, if the client record does not have the ICD-10 code in it, as long as the code is in the claim, there will be no validation against the client record.
• IBHIS EDI claims for service dates beginning Oct 1^st will received a "rule fail" if the claim does not have a valid ICD-10 code in it.  IBHIS will not validate the claim against the client record to see if the client record has an ICD10 code; IBHIS only looks at the diagnosis on the claim.Note: you need to know if DMH will convert the IBHIS client records to the ICD-10 codes. If so, by when and how will you know which ones need your clinicians' attention.
• Your clinical staff need to be trained to select the ICD-10 codes for all intakes and clients with service dates beginning Oct 1st; for DHCS contracted services they do not need to select the DSM 4 as well, but if you want them to, then they need to also select the ICD-10 code (your EHRS can no longer map the DSM to the ICD for you). If you provide non DHCS, such as Drug Medi-Cal, you may also need your clinicians to select the DSM 5...... so seems that a best practice is going to be selecting the ICD-10 and the DSM5 beginning in October.
• NEWS! Just in from a customer (thanks Daniel!) ... LACDMH will use this training material to train their in-house clinicians: http://apps.who.int/classifications/apps/icd/icd10training/

As always, if you see an error in my BLOG, please email me and I will correct it. Thanks!

CPTT Meeting Notes, May 21, 2015

CPTT Meeting Notes, May 21, 2015

The presentation slides are posted here: http://lacdmh.lacounty.gov/hipaa/IBHIS_EDI_Links.htm

Thought I'd share my summary notes, as several of you who couldn't attend have requested them.

·       IBHIS rollouts are on hold. No further contract providers will roll-out onto IBHIS until the known issues are resolved, many claiming issues, some Web Services enhancements needed, as well as PRM automation coming to avoid the triple data entry and resulting delays going on now.

• Therefore, you can focus on your EHRS implementations in-house, and get your IBHIS certification asap
• You can also use this time to apply for your Meaningful Use Incentives (this is complex when your psychiatrists and nurses are contractors, and requires assistance to find your way through all the available information....call me if you need help! I'm working on this for several agencies now.
• If your EHRS vendor is in production with EDI claiming to the IS, your should be asking to move to EDI claiming to the IS during this wait period.... in my opinion. Call if you need help with this.

·    DMH is working on a self-service method for IS Access, replacing hard tokens; so gaining access to the IS for your data entry staff will be much easier, versus the hard tokens used now. Stay tuned.

·     The IS SFT LE Extract data login method is changing in June.  See DMH slides.

·     A New Web Services version RC v201501 – this release is in production as of today June 12th. It includes SIGNIFICANT changes, some of which will change your Web services workflows, particularly around setting up the client Financial Eligibility and Guarantors.  DMH  strongly encourages you to work with their EHRS vendor to review and begin development / modifications needed to integrate with these changes. NOTE: valid USPS zipcodes will be crucial now, they will be validated by IBHIS. See the Release Notes here: http://lacdmh.lacounty.gov/hipaa/IBHIS_EDI_homepage.htm

·    Some changes to the strategy for indication of required forms and data have been made by DMH. See DMH  slides.

·    Some future changes are under discussion for documentation of services with co-providers, may require both providers signatures. You should determine how your EHRS will handle this in an e-signature workflow, and assure it won’t be a manual process to assure each note has both signatures. Let DMH know of any difficulties this may present to you. See DMH slides.

·    And ICD-10 codes will be required on all claims and in client Dx records starting October 1st! I'll write a blog for this next.

Some other tidbits here:

• At the DMH Provider Data Management/Reporting meeting this week, we were told that as of July 1^st the A7 code is expiring, it is used for claims older than 90 days with no adjudication.  DMH has reached out to the State asking whether there will be an alternate code that can be used, no news yet.
• In support of anyone that wants to consider moving to EDI claiming to the IS, ...

  Revised versions of the DMH HIPAA 5010 Companion Guides for the IS claims are now posted. 
  Note: With these changes, the IS will transmit the HMO Medicare Risk Plan indicator on Short Doyle Medi-Cal claims when they have been sent in on the LA County inbound claim.  An IS Alert will be sent out when this change is to take effect, which is anticipated to be by the end of June 2015.

   

  http://lacdmh.lacounty.gov/hipaa/edi_homepage.html

  
  

 

As always, happy to help !