Using Facebook’s New Job Search Feature


by Noreen Quadir, Social Media and Communications Specialist

Facebook has released a new feature that allows employers to post career opportunities for free, making it easier for prospective candidates to find and apply for jobs online. As a private practice, you can quickly find the right fit for a position by posting the job opportunity on your Facebook page under the new “Jobs on Facebook” section. This new section has listings in the local area so users in your community can come across your post and apply directly on the social platform. Candidates can fill out their name, education and employment history, and a short cover note (1,000-character limit). You will then receive their application in your Facebook message inbox. Candidates will also be able to apply on your page under the new “Jobs” tab, where your career opportunities will be listed. Simply post your job listings in this section and your current openings will show up in people’s newsfeeds.

Advantages

There are many advantages to using Facebook’s new job search feature. With 1.87 billion active users, your Facebook job listings will reach a larger talent pool, as compared to LinkedIn which has 467 million users. More users means you will have a higher chance of finding the most qualified candidate for a position through this platform than other job boards. The network also simplifies the employee search by allowing you to receive applications through the Facebook Messenger app, where you can reply back via text or a video/audio call. Conducting pre-screenings and interviews can be done through Messenger as well. Another advantage is the ability to review applications on the go with your mobile device. If you have a really busy day, you can quickly check your phone to see messaged applications between appointments or on a coffee break. People following your page will see your job postings and can also share them on their page where their friends can also see it. You may also have businesses in the medical community that are following your page — if they share your post it will reach even more people with an interest in medicine and healthcare. Consider reaching out and asking if others will share your post, giving it a wider reach and greater access to potential talent for your practice.

Easy to Post and Share

Posting a job opportunity on Facebook is very easy and takes little time. When you go to your business page, you will see an option that says “Create Job”. By clicking on that, you will be asked to fill out the details for the job, including title and description of duties and requirements. As this feature is somewhat new, not all Facebook pages have the Jobs tab showing yet, but you can also create a job listing simply by going to your status box on the main page. Underneath the box where you can type an update, you will see various options for postings, such as sharing a photo or video. In the second row, there’s an option to Publish a job post — click on that and you will be taken to the same form to fill out your job details.

publish job fb

You can and should add a visual component to your job posting. An appealing photo will make your job listing attractive and will result in more interest. Choose a photo that best represents your practice’s office and environment. A photo of your staff smiling at work or a photo that displays the beautiful interior design of your office are always good options. You want to show potential employees what’s great about working at your practice. WIthin the job posting form, you can fill out include salary, location and job type (part-time, full-time, contract, etc.). Once you finish filling out the job description, just click “Publish Job Post” and it will immediately be published on your page and appear in people’s newsfeeds.

After you publish your job listing, you will have the opportunity of boosting the post to reach even more people and target the audience for your post, making it an even more effective strategy for finding candidates. Once your post is live, you can click on the “Boost” button below it. You will then be asked to pick a targeted audience, where you can enter interests your prospects might have (i.e. medicine, healthcare, etc.) and an age range. If the position is entry-level, you may want to select a typical age range for recent grads. And if it’s a role that requires years of experience, you may want to select an age range that is older. It’s important to keep in mind what the role is and what interests, skills and experience your ideal candidate has. That will help you to determine the targeted audience for your boosted post. Once you choose your audience, you can enter the budget you want to spend. The more you pay, the more people the post will reach. By entering a certain amount of money, Facebook will let you know the average number of people the post will reach. This usually depends on your targeted audience and will help you determine how much money you should spend. You will only get charged when a candidate clicks on the job post.

Facebook has long been a very useful marketing tool for private practices, offering opportunities to communicate with their patients and the community through business pages. With the addition of the Jobs section, medical practices now also have the ability to quickly and easily find qualified employees and choose candidates from a larger talent pool through Facebook.

 

P02-Telehealth


By Tiffany Lauria,

With the rapid expansion of telehealth services nationally, CMS is continuing to broaden the ability of practitioners to perform alternative visits and have these visits recognized and reimbursed.

Effective January 1, 2017, CMS will recognize a new Place of Service Code: P02- Telehealth. The descriptor for this code is: The location where health services and health related services are provided or received, through telecommunication technology.

The professional service that is being provided via a telecommunications system by the physician or practitioner at the distant site will be paid at the current fee schedule amount for the service provided at the facility rate. Payment for an office visit, consultation, individual psychotherapy or pharmacologic management via a telecommunications system will be made at the same facility amount as when these services are furnished without the use of a telecommunications system. Modifiers GT (via interactive audio and video telecommunications systems) and GQ (via an asynchronous telecommunications system) are still required when billing for Medicare Telehealth services.

Medicare Practitioners who may bill for covered telehealth services include Physicians, Nurse Practitioners, and Physician Assistants, among other clinicians and are subject to state law. The Center for Connected Health Policy: The National Telehealth Policy Resource Center is a non-profit organization that has a repository of state telehealth policies located on their website at: http://www.cchpca.org/. Practitioners may find it helpful to review their state laws when deciding to implement telehealth services into their patient care.

For more information, on code P02-Telehealth, please see CMS change request 9726: https://www.cms.gov/Regulations-and-Guidance/Guidance/Transmittals/downloads/R3586CP.pdf.

 

The Trump Effect on Mega-Mergers


In the latest issue of Verden ViewPoint we discussed the likely impact of proposed health insurance company mega mergers. It remains to be seen how the election of Donald Trump could affect the deals between Anthem & Cigna, and Aetna & Humana but it’s entirely possible that a Trump administration would be pro merger.

With the Anthem/Cigna deal already before the courts and the Aetna/Humana trial scheduled for December, it’s fairly safe to assume that decisions in both cases will be made before Trump is set to take office in January but that likely won’t be the end of it.

Conservative Republican Senator Jeff Sessions was recently nominated by Trump to be Attorney General, and while we can’t know how Sessions would deal with antitrust cases, we do know that Trump has said he wants less government regulation of business.

It’s not clear how Mr. Sessions would have the department handle antitrust cases, but Mr. Trump has previously said that he wants “deep cuts” to government regulation of business. It’s doubtful that the DOJ would drop the cases but it’s also entirely possible that the losing party will appeal and that’s where Trump’s influence may come into play. Where a Trump administration will stand on antitrust issues can’t really be known until key positions in Federal Trade Commission and Justice Department are made but it’s not far fetched to think a Trump administration will be more lenient in terms of a settlement favoring a big insurer.

 

 

 

CMS Seeking Practices for CPC+


by Tiffany Lauria, Project Coordinator, Researcher, and Practice Consultant

CMS is now soliciting applications from primary care practices that wish to enroll in Comprehensive Primary Care Plus (CPC+), their five-year advanced payment model program. The application period ends September 15, 2016 and is accepting a total of 5,000 practices split across two tracks- 2,500 into track 1 and 2,500 into track 2.

The CPC+ program offers a financially sound opportunity for practices in a select 14 regions to increase their revenues while continuing to work on transitions that improve quality and care management, and the use of certified technology in patient care and reporting. Primary practices who have already transitioned into Patient Centered Medial Homes, should definitely consider applying, as the program goals align well and many of your PCMH functions have essentially prepared you for CPC+, with a higher probability of qualifying for the higher reimbursed track 2 program.

In order to qualify, your eligible primary care practitioners must bill under one tax identification number, have a minimum of 150 Medicare beneficiaries, and ideally, 50% of the practice’s patients would be covered under Medicare and the participating payer umbrellas. Let’s take a look at some of the financial benefits if you qualify.

Medicare intends to pay a Per Beneficiary Per Month Care Management Fee that is risk-adjusted per the diagnosed Hierarchal Condition Codes (HCC). For track 1 practices, this averages $15 per beneficiary per month, and track 2 practices average $28 per beneficiary per month, with your most complex Medicare patients warranting a $100.00 per month. These are the “sickest of the sick” in your practice.

risk tier chartSource: https://innovation.cms.gov/Files/x/cpcplus-practiceapplicationfaq.pdf

In addition, practices will be rewarded for meeting quality measures, such as patient experience and utilization measures, with an additional performance based incentive payment for each Medicare beneficiary, per month, as high as $4.00 monthly per Medicare patient for those practices qualifying for track 2.

Track 1-2 chartSource: https://innovation.cms.gov/Files/x/cpcplus-practiceapplicationfaq.pdf

How does this all add up? Let’s say your practice has 150 Medicare beneficiaries, and you have been accepted into track 2 for the five-year term of the program. If you continue to meet all quality and utilization measures each year, using the average monthly payments of $28.00 PBPM for Care Management and $4.00 PBPM Incentive payments, your take away looks something like $57,600 annually for participation. That equals $288,000 over the five-year program, for 150 patients.

Plus, your practice will still continue to bill Medicare fee-for-service for track 1 practices. Track 2 practices will slowly decrease your fee-for-service billing in lieu of a percentage of Comprehensive Primary Care Payments, that are intended to reimburse for the more total care you are providing your patients, even encompassing at home visits and other alternative means of patient care.

CMS has not outlined a specific payment model to be used by the private payers that are participating in CPC+. It is expected however that payment incentives will be similar, with them paying per member per month payments for covered members and an increased revenue to cover the additional care management functions that are expected. Without specific direction from CMS, there is of course no guarantee that payers will be providing an adequate reimbursement model. However, with the number of payers putting forward PCMH incentives and looking for ways to improve their satisfaction ratings, we just may see a worthwhile investment on their part.

CMS will be asking practices to report on practice use of these incentive funds. The goal being to ensure that these funds are being re-invested into the practice, with enhanced staff training and care management procedures. And ultimately, as these payments are going to be paid prospectively, if your practice fails to meet certain benchmarks, be prepared to pay back a percentage to CMS. This is where the ’risk’ to your practice comes in.

Are you already providing team-based care? Following up on Emergency Room and specialist visits? Using your EMR to provide recall reports and stratify patients by diagnosis and procedure? Then aim for track 2 approval, with the understanding that CMS reserves the right to offer you track 1 instead. I would encourage you to create a log-in through the CMS Application Portal and review the application questions to get a sense of what is being asked of applicant practices. This is a no-obligation way to determine if your practice meets base requirements. The CMS CPC+ page contains a number of resources. Scroll to the bottom of the page to review multiple links and FAQs to help you make your determination about applying. And of course, contact The Verden Group team if you have specific questions or would like help in applying and implementing the transitions necessary in practice.

 

 

 

 

 

 

 

CMS May Delay MACRA


By Jose Lopez, Senior Consultant, The Verden Group

In our most recent issue of ViewPoint Magazine, we provided some tips on how to prepare for the reporting requirements and shift to quality payment models under the proposed Medicare Access & CHIP Reauthorization Act (MACRA). MACRA was scheduled to take effect on January 1, 2017. However, after feedback and pressure from most of the professional medical societies and specialty membership organizations, Andy Slavitt, the Acting Administrator for the Centers for Medicare and Medicaid Services (CMS), recently indicated MACRA could be delayed from the proposed January 1 start date.

The final rule for MACRA is not expected to be released until November 1, 2016, only two months prior to the current proposed effective date of January 1, 2017. This would put unbelievable pressure on providers, particularly those in small practices, to scramble to meet the requirements of MACRA in a very short period of time. The Verden Group encourages CMS to delay implementation of MACRA, and for practices to fully understand, prepare for, and implement changes in their workflows to demonstrate the cost effectiveness and high quality of care they provide to their patients.

Many State Medicaid Meaningful Use Attestations Delayed


For Medicare providers, the deadline to attest for the 2015 reporting period with CMS was March 11, 2016. However, due to recent revised requirements, many states have not yet established a 2016 deadline for providers to attest for the 2015 reporting period with their Medicaid EHR Incentive Program. If fact, many states are only accepting 2015 reporting period attestations for adopt, implement, or upgrade (AIU), and Meaningful use Modified Stage 2 attestations are not yet available.

If you are a Medicaid provider, visit your State Medicaid EHR Incentive web site and subscribe to their Listservs to be kept informed if attestations or deadlines have been or will be set.

Verden ViewPoint: Leadership Issue


This quarter’s issue focuses on Leadership. Susanne wrote a brief contemplation for the magazine, posted below. What do you think Leadership is (or isn’t)?

Leadership means different things to different people. Some people believe you have to be born with it, with certain “leader-like” qualities, while others say it can be nurtured (such as Dr. Scott Schams’ view in Take A Hike).

Personally, I think you need a bit of both. Being emotionally intelligent and listening to others is key to creating connections, but if you fall short on the delivery, you are likely to viewed as a “well-intentioned manager” but nothing more. If you don’t take the time to learn how to make real connections, you’re not practicing strong leadership. I believe that in order to lead effectively, you must be able to both connect and inspire people and you must also lead by example.

Even less extroverted personalities can make fine leaders if they are able to push themselves to step out in front and lead the pack. When we look to our public leaders today we see very few who embody these qualities: very few, but not none. Over the past two months I have watched with fascination as Justin Trudeau has stepped into his new role as Canada’s Prime Minister, with dignity, empathy and a real ability to connect.

From my perspective, those are the qualities that today’s leaders need to bring to the table — in business, in politics and in our home life. How do you define leadership? Leave us a comment below . . .

You can read the magazine here: www.VerdenViewpoint.com

 

HIPAA Legal Updates — Breach Reporting Requirements


By Sumita Saxena, Senior Consultant, The Verden Group

There might be some confusion regarding the breach reporting requirements mandated by the Health Insurance Portability and Accountability Act (HIPAA) and further enforced by the Health Information Technology for Economic and Clinical Health (HITECH) Act. A breach is considered any acquisition, access, use or disclosure of Protected Health Information (PHI) which compromises the security or privacy of the PHI. However, if the disclosed PHI has been rendered unusable, unreadable, or indecipherable to unauthorized individuals, an adequate risk assessment may determine that a sufficiently minimal or nonexistent risk is present, thereby excluding the event from the definition of a breach.

The most basic example of a breach occurs when one patient’s records are accidentally sent or disclosed to another patient or individual. While this may seem trivial in a circumstance in which the content disclosed is rather limited, physicians must be aware of how to identify a breach and understand their obligations with respect to reporting.

Every HIPAA breach is reportable; the differentiating factor in reporting is determined based on the number of individuals affected by the event. In instances where fewer than 500 individuals are affected by the breach, practices must maintain a system of logging or otherwise documenting these breaches that occur during the calendar year. Practices must then submit a detailed account of all such events to the Secretary of the U.S. Department of Health and Human Services (HHS), through the HHS Office for Civil Rights, no later than 60 days after the end of the calendar year. Immediate notification to the Office for Civil Rights is required in the event that a breach affects more than 500 individuals.

Recent OIG reports signal an upcoming increase in OCR activity and oversight of HIPAA covered entities, even in the absence of a breach.

On September 29th, the Office of Inspector General (OIG) in the U.S. Department of Health and Human Services (HHS) released two reports which reviewed the successes and shortcoming in the Office for Civil Rights’ (OCR) oversight of Health Insurance Portability and Accountability Act (HIPAA) compliance for covered entities. OCR is responsible for overseeing covered entities’ compliance with the HIPAA standards, which include the Breach Notification Rule, the Privacy Rule and the Security Rule. In one report, the OIG provided conclusions and recommendations from their study on covered entities’ compliance with the HIPAA Privacy Rule, while in the other report, the OIG provided conclusions and recommendations from their investigation of OCR’s follow-up on breaches of patient health information which are reported to OCR. In both studies, the OIG reached some similar conclusions. The guidance provided by these reports should be recognized by providers for what it is: harbingers of OCR’s likely future enforcement activity.

One of the key findings by the OIG likely to have a direct impact on providers: OCR will now proactively audit covered entities to monitor compliance with the Privacy Rule, as opposed to its traditional approach of initiating investigations as a result of complaints or breach reports. The fact that OCR has not been proactively auditing covered entities allows for some level of comfort for covered entities, as there is not a great concern that OCR will conduct an investigation of a covered entity unless a potential breach or violation were reported. It is likely that this will be changing in the very near future, as the OIG has recommended that OCR improve its oversight of covered entities and take a proactive stance, by instituting a permanent audit program, as opposed to OCR’s current reactive posture. In addition, the OIG recommended improving the tracking system which OCR uses to keep records about investigations of covered entities. Such improvements in record-keeping and tracking investigations could mean that OCR will be more likely to impose penalties, as it will be able to more easily determine when covered entities are the subject of multiple investigations.

Regarding the follow-up of breaches, the OIG made some similar recommendations concerning the need for OCR to improve its tracking system. The OIG recommended that OCR more uniformly enter information about breaches, whether large or small, into a searchable database. At present, OCR has largely focused on thoroughly investigating large breaches (e.g. breaches of 500 or more affected individuals) that are reported to it. However, the OIG has now recommended that OCR also track and follow-up on small breaches that are reported to it. This could have a significant impact on providers who may have experienced several small breaches, as it will be more likely that OCR will now closely track and examine covered entities that experience several small breaches. In addition, the OIG recommended that OCR maintain more complete documentation in its database of corrective actions taken by covered entities that experience a breach. Currently, because OCR does not keep thorough records of corrective actions, covered entities may be able to get away with implementing few changes if they experience a breach. Once OCR implements these recommendations to better document corrective actions taken by covered entities, it will place greater scrutiny on these corrective actions to ensure that the covered entities carry out the necessary changes and prevent the occurrence of a similar breach in the future.

It is extremely important for providers to understand how to comply with HIPAA, as well as what to do if they experience a breach. These reports serve to emphasize the importance of compliance and the ways in which OCR will begin to more actively investigate HIPAA compliance. Here at The Verden Group we can offer assistance in reviewing your HIPAA protocols and ensuring you have all the required forms up-to-date and properly disseminated to your patients.

 

 

CMS issues Final Rules for Stage 2 and Proposed Rules for Stage 3


By Jose Lopez, Senior Consultant, The Verden Group

On October 6, 2015, the Centers for Medicare and Medicaid Services (CMS) and the Office of the National Coordinator (ONC) released the final rules (click here to view) for modifications to Stage 2 and 2015 reporting requirements, as well as proposed rules for the third stage of the Meaningful Use incentive program.

Meaningful Use Stage 2 Changes

As expected, CMS finalized the modifications for the 2015 reporting period and some Stage 2 requirements (see my earlier blog post about details on those anticipated changes). CMS says it is providing a simpler, more flexible set of stage 2 regulations for 2015 through 2017 as the meaningful use regulation era gives way to CMS’s transition to value-based compensation. In summary:

  • The rules also allow for a 90-day reporting period for providers in 2015, and new providers in 2016 and 2017.
  • Many of the measures of personal health engagement have been drastically reduced (patient portal and e-messaging requirements).
  • Clinical quality measures for both hospitals and providers will remain the same.

The Verden Group applauds the relaxation of these measures to reflect the real challenges that practices and hospitals are facing. More than 60% of hospitals and about 90% of physicians have yet to attest to stage 2!

Meaningful Use Stage 3 Measures

In spite of calls from most of the major medical associations to delay the onset of Stage 3, CMS also announced that Stage 3 will go on as planned and will not be delayed. In summary, major provisions pertaining to Stage 3 meaningful use include:

  • There will be 8 objectives for eligible providers and hospitals.
  • In Stage 3, more than 60 percent of the proposed measures require interoperability, up from 33 percent in Stage 2.
  • Public health reporting will include flexible options for measure selection.
  • Clinical Quality Measures (CQM) reporting are aligned with the CMS quality reporting programs.
  • Finalizes the use of application program interfaces that enable the development of new functionalities to build bridges across systems.

In short, CMS is attempting to address the two areas in Stage 3 that have been the primary barriers for successful Stage 2 attestation: interoperability and patient engagement. In 2017, Stage 3 requirements are optional, but providers who opt to start Stage 3 in 2017 will have a 90-day reporting period. Come 2018, all providers must comply with Stage 3 regulations using a certified EHR.

Industry Reaction

Despite a public outcry from the healthcare community to delay the onset due to the lack of successful Stage 2 attestation, Stage 3 is set to begin as an optional requirement for physicians and hospitals in 2017 and a requirement in 2018. The American Medical Association applauded CMS for allowing a hardship exemption for physicians who are unable to attest in 2015 but called the final rule, as a whole, “deeply disappointing.” The American Hospital Association urged CMS to delay the implementation of Stage 3 and focus instead on “ensuring that providers could easily and efficiently share health information to support care delivery and new models of care.” The American College of Cardiology says that the program requirements “remain difficult to implement.”

The final rule for Stage 3 includes a 60-day comment period, which is longer than is typical, suggesting that there may be additional modifications or delays. As such, the political fight to delay the onset of Stage 3 of meaningful use may not be over, and we expect many changes may be coming before the rule is finalized.

A Post-HITECH World

When Congress passed the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA), it essentially sunset the meaningful use payment adjustments (penalties for noncompliance) at the end of 2018. Instead, Congress has called for the establishment of a Merit-Based Incentive Payment System (MIPS), of which the meaningful use program will form one component. CMS will continue to consolidate its current incentive/adjustment programs under the umbrella of MIPS as it further transitions from encounter-based payments to value-based compensation. The Verden Group will continue to monitor industry reaction and comments submitted to CMS on the final Stage 3 rule in order to guide our clients through successful Meaningful Use Attestation and beyond.