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Posts in the ‘Fi-Med Services’ Category

Fi-Med returns to its roots, brings back consulting services

Posted by Lisa Velasquez in Fi-Med Services

Fi-Med is again expanding its services, bringing back our consulting services to the independent physicians.  We have been overwhelmed with requests to assist physicians tackle the complexities involved in the financial medical management of their clinics.

Adrian and Christine began Fi-Med Management as a financial medical management consulting firm in 1993.  As the healthcare environment continues to evolve we return to our roots in assisting the independent physician maximizing revenue and reducing operational expenses.  A sneak peak on consulting services includes sophisticated analytics including E&M and Acuity Analysis, Fee Schedule Analysis, Cost and Contract Profitability, and Productivity Analysis to name a few.  Continue to look for additional details on these consulting services.

Healthcare Management Systems (HMS)

Posted by Lisa Velasquez in Fi-Med Services, Mergers and Acquisitions

Healthcare Management Systems (HMS) maintains two divisions operating complimentary functions.  Working together, they strengthen the products and services provided to the medical community.  Richard Usry, HMS Senior Vice President, said “Because HMS bills and collects for medical practices, Turnkey users can be confident the software provided to them includes the latest collection and information tools available.  

Similarly, while operating billing offices for the Management Division, HMS is constantly learning through actual experience and continuously updating the Medical Management System for the benefit of Turnkey users. 

The Turnkey Division combines powerful industry-standard hardware and the HMS Medical Management System software for practices that desire their own independent billing operation. The software provided is specific to each hospital-based specialty, with the focus of automating as many functions as possible, providing the easiest functions for day-to-day operations, and including the most comprehensive reporting available to guide important practice decisions.

The robust HMS software retains its edge because HMS has a unique process for prioritizing its enhancements.   The HMS Users Group, wholly-independent from HMS, meets twice each year to recommend ideas for enhancements to the system.  The group is led by its board of officers and funded by annual membership dues from the client members.  HMS attends all of the meetings, and therefore, knows just what its clients need all the time. 

The Practice Management Division provides billing outsource solutions for groups who do not wish to face the challenge of an internal billing operation.  HMS employs experts to monitor the changes pertaining to each specialty, and maintains memberships in the key organizations that propel and monitor changes in the medical billing and practice management industry, which gives their clients confidence about their investment in the future.

Learn more about Healthcare Management Systems, A Fi-Med Company.

Meaningful Use Defined: When Good Ideas Go Bad

Posted by J. Paul Spencer, CPC, CPC-H in Coding and Compliance, Fi-Med Services, Hot Topics, Industry Updates, J. Paul Spencer, CPC CPC-H

Had she been alive today, today would have been the 101st birthday of actress Ann Sothern. A quick glance at her acting credits includes appearances in dozens of movies and her own situation comedy that ran for three seasons across an acting career that spanned nearly six decades.

You may ask why I’ve opened a blog that deals with medical billing, coding, compliance and health information with a short biography of an old actress. Please bear with me for a few paragraphs.

There is one credit on Ann Sothern’s resume that sticks out in my mind and is relevant to today’s dissertation. In 1965, Ms. Sothern played the voice of a dead woman in a television show that most critics now point to as one of the worst shows in the history of television. That show was My Mother, The Car. The show followed the exploits of a young man who one day buys an antique automobile from a used car lot. When he turns on the radio in the car, who should be on the radio but his dead mother offering life advice from beyond the grave. Mercifully, this show only lasted one season and to my great glee is not available on DVD.

As we stand back and look at this plot line, we begin to wonder not only why such an atrocious idea ever made it to air, but what person, when this idea was pitched to them, thought that something like this would appeal to the viewing public. Worse yet, the young man in the show was played by Jerry Van Dyke, whose entrance onto the American entertainment landscape acts as the ultimate symbol of what happens when we let a talented person’s less gifted siblings share a piece of the spotlight.

I brought forward the example of My Mother, The Car to illustrate that no matter what the quality, all any idea really needs is a benefactor; someone who hears an idea and states “I think that’s great! Let’s run with it”.

Which brings me to the proposed rule defining “meaningful use” of electronic health records (EHR) that was released on December 31st by CMS. In early 2009,when it was announced that physicians would receive incentive payments for the meaningful use of EHR in mid-2011, there was much excitement that a new day was dawning in the way our health care infrastructure managed and shared patient medical information.  Before meaningful use was defined, the Certification Commission for Healthcare Information Technology (CCHIT) created a certification for EHR systems that would meet the standard. Some systems gained CCHIT certification prior to the release of the proposed rule, which I pointed to in an earlier post as premature. 

Since the proposed rule listing 24 specific requirements needed to meet meaningful use was released on the last day of 2009, many practices who took the plunge and purchased an EHR prior to a clear definition of what was needed to meet the standard are experiencing buyer’s remorse, realizing that a large investment has been made for systems that may not meet the standards if the proposed rule is implemented as written.

The requirements demonstrate high ideals of treatment and public health. An example of this is the idea of EHR’s being able to share important patient condition information with immunization registries and public health agencies. Under this proposed requirement, at least one test must be performed to assess the EHR’s ability to provide electronic lab results to a public health agency. We heard a lot about interoperability when the discussion of meaningful use began in earnest last year, but a requirement such as this can only work if the relevant public health agencies have the ability to receive the information electronically.

Also put forth is the proposal that any certified EHR system be able to provide patients with an electronic copy of their health information upon request. The key word in that phrase is “electronic”. While some more sophisticated EHR systems and larger health care institutions now have this capability, this requirement places a large privacy and security burden on smaller practices that lack the IT infrastructure support to create a secure electronic pathway from the office to the patient.  

It is the intersection of high ideals and the execution of the same that presents itself as a formidable challenge to any idea. Between now and the release of the final rule, which is expected sometime after March of this year. I encourage those that have yet to purchase an EHR system, and even those who have implemented an EHR in their practice believing it would meet any standard, to review the proposed rule. If these requirements outlast scrutiny and become final, this may someday be seen as an idea that slowly took on a life of its own, consuming everything in its path until it was too late. This would be similar to the thought all those years ago that a dead mother talking to her son through a car radio would be appealing to a wide audience.

Billing For Consults After “The Apocalypse”

Posted by J. Paul Spencer, CPC, CPC-H in Coding and Compliance, Fi-Med Services, Hot Topics, Industry Updates, J. Paul Spencer, CPC CPC-H

“Orchestral music rises as the first glimmers of an ominous sunrise brings light to a dusty and desolate landscape, where once-plentiful streams of revenue have been vaporized by statute. Small bits of paper with numbers such as “99254″ and “99241″ blow across the feet of our stethoscope-clad hero, as he faces a future full of financial uncertainty and unwanted adventure…”.

We are now two weeks into a world where Medicare has eliminated reimbursement for inpatient and outpatient consultation codes. To many specialists for whom consultations have become a way of life, it is tempting to see themselves as a manufactured post-apocalyptic film character similar to the one above. It is my duty, as a compliance officer, certified coder and budding writer of screenplays to inform you that it doesn’t have to be that way.

In a previous post on this blog, I demonstrated one way to navigate the imperfect crosswalk that exists between inpatient consultations and the CPT codes for initial inpatient encounters (99221 through 99223) that are now to be used in its place. In the past weeks, the Medicare administrative carriers have released their own guidance about what should be billed in place of a consultation code if the documentation does not meet the requirements of CPT code 99221.

For Palmetto GBA, First Coast and WPS, the suggestion is that CPT code 99499 (Unlisted evaluation and management service) be utilized for services formerly billed as 99251 or 99252. When using this code, be aware that it lacks a set payment. The reimbursement of this code is driven on a case-by-case basis and is determined by carrier review of documentation for the service. When billing 99499 to a carrier that accepts it, always be certain to include the documentation for the service.

National Government Services, as well as other carriers, is suggesting that the appropriate inpatient follow-up code (99231 through 99233) be billed in place of a low-level consultation. The choice of code would depend on the depth of the documentation for the service.

The second challenge that has been brought forth is the question of consultations when Medicare is the secondary payer (MSP). In the final revision of the new consultation policy in MedLearn Matters article MM6740,  there are two solutions that can be used. You can either choose not to bill consultations at all to a commercial payer and be reimbursed for E/M services by both commercial and MSP, or you can bill the consultation to the commercial payer, then report the amount paid and bill an equivalent E/M code to Medicare to determine whether additional reimbursement is due.

The first solution is the path of least resistance, as this eliminates consultation billing from your practice immediately and entirely. Financially, this may not be the most advantageous approach. While commercial payers are expected to eventually follow CMS’ lead and eliminate reimbursement for consultations, these codes are still active with commercial payers at reimbursement rates that are typically larger than equivalent E/M codes based on documentation.  Contractually, if you are still receiving healthy reimbursements from commercial payers for consultations, the second approach may be more to your advantage.

The reimbursement landscape has changed, but it has not been irrevocably altered for the worse. The road to reimbursement commensurate with services performed now has a few more detours than it did a month ago, but water recedes and bridges can be rebuilt. With increased attention to documentation detail and increased awareness of the new rules of the road, providers can successfully navigate a world without consultation reimbursement.

Paul Spencer CPC, CPC-H

Meet the New Fee Schedule, AKA 2009 2.0

Posted by J. Paul Spencer, CPC, CPC-H in Coding and Compliance, Fi-Med Services, Hot Topics, Industry Updates, J. Paul Spencer, CPC CPC-H

Welcome to the first post for 2010 on the Fi-Med blog. Knowing some of you the way I do, I gave you 8 days to sober up from your New Year’s celebrations, and I bid you welcome. For some of my more hardcore partying compatriots in the writing community who are reading this while catching up on what you’ve missed, I hope you had a pleasant Valentine’s Day.

I myself spent the early morning hours here in Milwaukee recreating the famous road-building scene in the classic film “Cool Hand Luke”, with the exceptions being that  the dirt and gravel on my shovel was replaced by snow, and George Kennedy was nowhere around to help me finish shoveling.

We’re now in 2010, and while we were celebrating, a few changes occurred to the proposed 2010 Physician Fee Schedule that I thought I’d share with you to bring you up to date.

Perhaps it is better to begin this explanation by reintroducing you to the 2009 Physician Fee Schedule, now held over for two more months. As the journey towards final health care legislation continues in Congress, a temporary pay fix was signed on December 19th by President Obama, which will continue the 2009 fee schedule until February 28th. This halted the planned 21.29% payment cut that was scheduled to go into effect on January 1st.

There are a few changes to note. The current conversion factor increased slightly from $36.0666 to 36.0846. While the assumption would be that this would lead to a temporary nominal increase in reimbursement for the two-month period, this actually depends on your locality.

While the 2009 Fee Schedule was being held in place, planned changes to geographic practice cost indices (GPCI’s) went into effect that are modified based on the area of the country in which you practice. High-cost areas of the country now have a GPCI above the former minimum of 1.000, while lower-cost parts of the country have fallen below 1.000. In all, 54 out of 89 localities are seeing a decrease in their GPCI to a level below 1.000, so while the conversion factor is temporarily raised, most low-cost area providers will in fact see a fee decrease for the first two months of 2010. This is expected to be corrected in the pending legislation, which would extend the GPCI minimum of 1.000 until 2011.

This same pending legislation, which to date has been beaten and battered worse than Lenten cod, is also slated to increase the conversion factor by half of a percentage point for 2010. With the seemingly endless bickering and posturing that has characterized the process for this particular bill, it is best to tell the reader to stay tuned for further developments as the legislation nears completion.

Paul Spencer CPC, CPC-H

Thoughts For The Blue Moon

Posted by J. Paul Spencer, CPC, CPC-H in Community Involvement, Fi-Med Services, Hot Topics, J. Paul Spencer, CPC CPC-H

Today’s a special day on the astronomical calendar. Every 32 months or so, two full moons occur in the same calendar month. We had a full moon back on December 2, and a look to the skies this evening will find that we have another full moon ringing in the New Year to the celebrating world below. In honor of this rare occurrence, I thought I’d take a step away from professional subject matter and bring forth some observations of a more personal nature.

Back in 1977, I was 11 years old, growing up in the suburbs of Philadelphia. I was required to take a book out of the elementary school library. I was always looking for material that interested only me. While this made the graded results of my schooling rather shocking in their downward path, I dare say that my desire for exploration and inquisition has served me better intellectually than many of my peers from so long ago. Looking through the books, I chose one called 2010: Living In The Future by Geoffrey Hoyle.

As a fan of the future, I marvelled at what I saw within the pages. My bed wouldn’t be on a squeaky metal bed frame, but would pop up from the floor with the push of a button. My children wouldn’t be going to a brick and mortar school. They would be going to school via “videophone” (this is what we called web cams in 1977 while we waited for our Ford Pintos to explode due to rear impact). You could leave your car at home and strap on a jet pack, as the cartoon-illustrated skies would be darkened by free-hanging people with fuel-filled propulsion engines strapped to their backs. I’m leaving out moon colonies and environmentally-controlled domed cities, but I think you get the general thrust of this book.   

I don’t know how I can say this without sounding critical of the over 7 billion people currently inhabiting the Earth, but the calendar leaves me no alternative.

Tomorrow is 2010, and we have failed our own future.

This is not some run-of-the-mill failure, such as a misspelling or a briefly untied shoe. This is an international, multi-societal, cross-generational, self-inflicted catastrophe equivalent to laying on one’s back on train tracks as the 5:15 high speed commuter line is within view.

In my civilian life, I am an acolyte of the great scientist and renaissance man R. Buckminster Fuller, who spent more than half of the 20th century attempting to explain to the world at large both layman and academic that the Earth indeed had the resources (both sustainable and non-sustainable) for everyone on the planet to comfortably coexist. To that end, he designed tools for responsible care and habitation of the planet, not only in the realm of housing, but across the width and breadth of design sciences.

I’ve spent a great deal of my post-adolescent life hoping that the powers that be would invest heavily in a future closer to what Fuller imagined, and have been continuously frustrated as vital resources have been heavily tilted to obsolete models of existense. Whether it is the removal of mountaintops in West Virginia for coal or watching a drunken captain of an Alaskan supertanker run aground and spill oil over hundreds of miles of coastline, hanging on brazenly to the past doesn’t appear to be improving anyone’s life in a measurable fashion.

More disturbingly, there appears to be a truth fatigue gripping the world. Turn on any TV news program or surf the darker reaches of the internet for any length of time and a basic set of facts is being reputed by someone who has apparently crawled out from under a rather large, moss-covered rock somewhere who has either an ideological or monetary interest in bringing forth a contrary viewpoint, no matter how ridiculous. As this type of person is slowly given more time to spout nonsense to a broader audience, truths that have sometimes taken scholars and scientists centuries to be realized disappear in waves of reddened faces and screeds in capital letters, replaced with dogma, superstition and an utter lack of intellectual rigor. And admit it, when was the last time you saw a rocket lifting off from Cape Canaveral, and felt any sense of anticipation or excitement?

In looking back, the only thing from that children’s book that came true was the idea of using computers to order food remotely and having it delivered to your house. Currently, this is only in effect for restaurants and pizza parlors and not supermarkets, as was fully envisioned. Thanks to this “innovation”, someone else’s plan for the future has helped to make me, according to my sister-in-law’s Wii Fit Pro, “obese”. I guess if you’re weighed down by calories, it’s somewhat hard to find the energy to fight for a future that benefits more than your perpetually-full digestive tract. My same-old squeaky metal bed frame (push button not included) is a little louder nowadays.

Going back to Buckminster Fuller, he once wrote the following as he contemplated his own actions in the world and how he could be of most benefit to the planet and its inhabitants at large:

I am not a noun, a thing. I seem to be a verb; an evolutionary process, an integral function of the universe”.

We’re now knee-deep in the 21st century. Many people in power across the globe have a great deal invested in making sure your internal drive to be anything more than a noun remains dormant. As we go forth into 2010, it is my hope that mankind’s inate curiosity about its universal place leads to a litany of much-needed, long-dormant questions, followed in short order by a storm of ideas aimed at improving current existence and ensuring future survival. Until my next posting of this nature (August 31st, 2012, according to my astrological calendar), I challenge you to do the right thing, both for yourself and the world at large. Be a verb!

Paul Spencer CPC, CPC-H

Introduction to 2010 HCPCS Code Set

Posted by J. Paul Spencer, CPC, CPC-H in Fi-Med Services, Hot Topics, J. Paul Spencer, CPC CPC-H

Sometimes, honesty is the best policy. With regard to this week’s blog posting, I was woefully unprepared. Any number of reasons for this are available, from the sudden lack of relevant government transmittals and general industry silence ahead of the holidays, to the fact that I still have gifts to buy and have maybe 10 hours of useful daylight left in order to do it.

So, with 9 days before the new year, I present a slapdash overview of relevant changes to the HCPCS code set for 2010. I’m going to attempt as best I can to restrict my updates to codes that I myself have seen our client base utilize on a regular basis, or new codes that represent a service that is widely provided in the world at large. This will keep this posting from slipping precipitously into the Gorge of Too Much Information:

A6200-A6202 – These codes are currently used for composite dressing pads without adhesive borders. These codes are disappearing on January 1, 2010. There are no codes to replace these codes, based on the fact that these codes have been covered based on individual carrier discretion for some time (read: not often or at all).

G0151-G0155 – This represents a new set of codes for 2010 for different types of therapy services provided to patients in either the home health or hospice settings. These services are billed in 15-minutes increments.

G0420 – This is a new code for individual chronic kidney disease education. This code is billed on an hourly basis. Once the actual dollars and cents fee schedule is released for 2010 by Medicare, this code can be accurately assessed for usefulness.

J7322 – The code for Synvisc is changing for 2010. J7322 is being replaced by J 7325. The reason for this has to do with there now being more than one type of Synvisc now available. Code J7325 now covers more than one Synvisc derivative.

Elastic Orthoses – Several HCPCS L codes are being deleted from the HCPCS code set. Since April 1st, 2009, the codes to be deleted have been found by CMS to not meet the definition of a brace and coverage has been denied. The deletion of these codes is a natural progression from that determination. 

The majority of the balance of changes to the 2010 HCPCS code set are an expansion of the existing Physician Quality Reporting Initiative (PQRI) codes. If you are currently utilizing PQRI, a quick review of these codes may be worth a look.

Thus concludes this somewhat informative and not the least bit inspired blog post.  As you conclude you holiday seasons, do your best to show a little kindness. You’d be surprised how far it goes, and how much it will be appreciated. As Randy Newman says, “It’s a jungle out there”.

Introducing the -AI Modifier

Posted by J. Paul Spencer, CPC, CPC-H in Fi-Med Services, Hot Topics, Industry Updates, J. Paul Spencer, CPC CPC-H

A.I.

Up until this week, those two letters stood for a number of different things. Being from Philadelphia, A. I. stood for Allen Iverson for a period of time to any basketball fan (I hear he’s back, but I’m a hockey fan, so let’s move on). In the scientific world, A.I. stands for artificial intelligence. In the case of my one brother, A.I. most often stands for alleged intelligence. Maybe the reader knows a few that I left off this short list.

Beginning on January 1, 2010, the letters “AI” represent a new modifier which stands for “Primary physician of record”.

With the impending elimination of inpatient consultation codes to choose from, physicians once designated as “consultants” will now be utilizing CPT codes 99221-99223 for their first encounter with the patient in the hospital setting in the same way that the admitting physician does currently. With this change comes a need to differentiate between the admitting physician coordinating care and other physicians participating in the care of the patient. Medicare has decided that the best way to do this is for the admitting physician to include a modifier on the charge for the initial encounter. The modifier they have created for this purpose is -AI.

The -AI modifier will be used only by the admitting physician, and only on their initial encounter with the patient in the inpatient setting. In addition, this modifier is to be used for the admitting/primary physician of record for patients admitted to nursing facilities.

According to CMS in Transmittal 1875 announcing the new modifier, if the -AI modifier is mistakenly included by the primary physician on subsequent facility services, the provider will not be penalized with a denial. In spite of this, it is not recommended that the modifier be used in this fashion.

E-Prescribe Reporting Easier for 2010

Posted by J. Paul Spencer, CPC, CPC-H in Fi-Med Services, Hot Topics, Industry Updates, J. Paul Spencer, CPC CPC-H

We are surrounded by cliches in our culture. We hear them virtually every day in our society from one source or another. From my point view, one topic that always plummets into cliche is the topic of change. I’m now past the halfway point in my life, and it’s safe to say that the next person who approaches to me with a happy, revelatory look on their face and says “The only constant is change” as if they have just discovered the Ark of the Covenant has a 50/50 chance of forcibly eating the chair I’m currently sitting in.

Having said that, I’d like to reveal what I feel are two great changes with regard to the reporting of the utilization of electronic prescriptions to Medicare and the reimbursement for this reporting under the current e-prescribe bonus program.

Beginning on January 1, 2010, if a medical provider electronically prescribes at least one medication electronically, this will be reported with the new e-prescribe HCPCS code of G8553. The prior reporting codes of G8443, G8445 & G8446 will be deleted. This change will eliminate any confusion concerning what code to choose. If you e-prescribe one or more medications, G8553 will be reported. If no prescriptions are electronically prescribed, nothing is reported.

In addition, the qualifying for the incentive bonus payment is about to get easier. Currently, in order to qualify for the e-prescribe bonus, a provider must have a 50% rate of electronic prescribing for all prescriptions generated from his or her practice. For 2010, the physician will only need to electronically prescribe 25 times a year in order to qualify.

There are a few things to take into account as we approach these changes. The reporting code must always be reported with a unique face-to-face patient encounter in order to count towards the 25-visit minimum. Also, the definition of electronic prescribing does NOT include faxes.  

In conclusion, if you want an illustration of negative change, as a resident of Milwaukee, I need only look at where the temperatures stood on Thanksgiving and compare them to today. The temperature has dipped into the low teens, and I’ve spent the bulk of the time trying to stay warm at my desk as I type this by playing the more raucous portions of my mp3 player’s catalog. Who knew that Husker Du’s Zen Arcade had a legitimate business purpose? Sometimes, it is of huge advantage to avoid cliche.

Reports Are Falling From The Sky

Posted by J. Paul Spencer, CPC, CPC-H in Fi-Med Services, Hot Topics, Industry Updates, J. Paul Spencer, CPC CPC-H

Here in Milwaukee, we had our first snowfall of the season overnight. While it wasn’t enough to keep me at home today, it was just enough to make the process of getting from here to there just slightly more time-consuming. For someone like me, who operates in this world of ours thinking that a great deal of the world functions specifically to be in my way, it was a typical morning.

As the calendar turned to December earlier this week, I am also reminded that snowflakes are not the only thing  falling from the sky. With the approach of a new calendar year, a number of news releases, reports, pending legislation, industry updates and warning shots are coming from the federal government. Some of these began implementation at the beginning of the fiscal year on October 1, but it helps to review the regulatory landscape on a regular basis. With that in mind, here’s a portion of what we know:

  • The OIG Work Plan - While some of the usual suspects appeared once again on the OIG work plan for fiscal year 2010. there were a few new and not-so-new things that jumped out at me. OIG is again looking at the unbundling of laboratory tests. One of the most surprising bits of news this year was the large fine levied against Quest Diagnostics for violating bundling rules, mainly because this company, under its previous incarnation as Smithkline Beecham Clinical Labs, faced a 9-figure fine for similar violations back in 1996. The OIG has now officially decided to revisit this topic. Other targets of the OIG in the coming year will be E/M services performed in the global period of a surgery, a review of the current payment system for ambulatory surgery centers, practice expense for radiologists, the effects of payments for services referred by excluded providers, and a multi-layered review of claims related to durable medical equipment.
  • The OIG Semiannual Report – In addition to this year’s Work Plan, the OIG just released their semiannual report, which reports a total of almost $21 billion in program savings and recoveries. For fiscal year 2009, the OIG recovered just short of $4.5 billion through investigations and audits. The savings portion of $16.5 billion came through recommendations for putting agency funds to better use which were finally implemented long after they were suggested during the last administration.
  • The 2010 Conversion Factor - Quietly over the Thanksgiving holiday, the projected conversion factor for 2010 was lowered from 28.4061, which represents a 21.2% cut from 2009, to 28.3895, bringing the total cut from 2009 to 2010 to just short of 21.3%. In past years, there has been last-minute legislation passed that eliminated projected cuts to the conversion factor. This year, the urgency to address this issue has disappeared in a wave of uncivil, unproductive and distracting arguments about the future of health care in the United States. With the New Year 4 weeks away as of today, it may be in the best interests of all Medicare Part B providers  to make financial preparations for the coming year that assume a 21.3% reduction in Medicare reimbursement. If this cut is rescinded on the cusp of January, those that have planned ahead will be that much better off.
  • Medicare Fee-For-Service (FFS) Error Rate – CMS reported that the error rate for claims payments under Medicare FFS plans more than doubled from 3.6% in 2008 to 7.8% in 2009. This was a result of increased scrutiny of claims for these plans. This FFS error rate works out to $24.1 billion dollars in improper payments.

 

With the rancor currently displayed in the Legislative Branch of the government, coupled with the attention-deprived caterwauling that defines the 24-hour cable news environment, it will not be the occasional regional snowfall making December a treacherous time for our industry. Much like the Buick-driving senior citizen in a hat, these and other reports will make the best attempt at getting in the way of a pleasant holiday season. As always, look for an opening, give it some gas and do your best to leave it in the dust, but be aware that you’ll more than likely see them again.