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Practice Management: Highlights and Dates to Remember for 2016

Posted on 11/29/15

2016 is at our doorstep, and like last year, the New Year promises continued change in the evolving healthcare industry. The following are highlights of specific highlights and dates to remember as we prepare for 2016:

Meaningful Use Attestation System

January 4, 2016 is the opening date for the Meaningful Use Attestation System. All providers are eligible for a 90-day reporting period in 2015. Stage 1 and Stage 2 Meaningful Use reporting requirements have been modified. Practices should have already visited the website to review specific modification details in preparation for the February 29, 2016 deadline.

PQRS Reporting Deadline

To avoid future payment penalties, the PQRS Reporting Deadline is currentlyFebruary 26, 2016.

POS Code Changes

Be certain to pay close attention to the Place of Service (POS) codes you are using beginning January 1, 2016 for Outpatient Hospital Claims. POS Code 19 has been added to indicate services were rendered at an off-campus outpatient hospital. POS Code 22 has been revised to indicate services were rendered at an on-campus outpatient hospital.

OIG 2016 Work Plan

The U.S. Department of Health and Human Services (HHS) Office of Inspector General (OIG) work plan summarizes new and ongoing OIG reviews with respect to HHS programs and operations. Here are a few newly added projects for FY 2016:

  • Anesthesia Services – Non-Covered Services

    – The OIG will specifically review anesthesia services to determine whether the beneficiary had a related Medicare service. Medicare will not pay for items or services that are not “reasonable and necessary.”

  • Physician Home Visits – Reasonableness of Services

    – The OIG will determine whether Medicare payments to physicians for evaluation and management home visits were reasonable and made in accordance with Medicare requirements. Since January 2013, Medicare made $559 million in payments for physician home visits. Physicians are required to document the medical necessity of a home visit in lieu of an office or outpatient visit.

  • Prolonged Services – Reasonableness of Services

    – The OIG will determine whether Medicare payments to physicians for prolonged evaluation and management (E/M) services were reasonable and made in accordance with Medicare requirements. The necessity of prolonged services is considered to be rare and unusual.

This is just a snapshot of numerous newly added projects to the OIG FY 2016 Work Plan. It’s important to review the plan in its entirety to evaluate how changes will impact your practices. The full plan can be found at

About the Author

Johna Kennedy-Preston

Kerkering, Barberio & Co.
1990 Main St., Suite 801
Sarasota, FL 34236
(941) 365-4617

Ms Kennedy-Preston provides clients with expertise in revenue cycle management, coding education, managed care contracting, mergers and start-up ventures, Medicare recoupment and reporting issues, credentialing with insurance carriers and assistance with state and federal licensing. Guidance is also supplied for operational improvement, policy development, procedure design and implementation, including electronic health record set up and workflows, compliance with third-party due diligence and regulatory requirements, as well as training of healthcare professionals in critical topics, both fundamental and emerging.

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