As the end-of-year countdown begins, we’re looking at changes that will impact the wound care industry in 2018. For the next several weeks, we’ll be running a series of insightful blog posts from our team of experts. This entry is from Randall Brooker, CHT, HBOT Safety Director, VP of Program Operations.
As we near the end of 2017 and optimistically venture toward 2018, it’s important to remain diligent about being responsible stewards of compliance with regard to Hyperbaric Oxygen treatments. Increased scrutiny from payers and regulatory bodies continues to ramp up, while the diabetic foot indication for HBO is under a constant bombardment of negative outcomes reporting. With all of that going on, I think it’s important to remind the medical community that HBOT remains a viable treatment modality for many disease states, including the diabetic foot.
Continuing the theme of our “Five Things” expert blog series, this week I’d like to point out five current or upcoming initiatives that will likely affect hyperbaric oxygen therapy in the coming year:
The Office of Inspector General (OIG) Report: A new report will be released in 2018. Previous versions expressed concerns of payments for non-covered conditions, lack of documentation justifying coverage, and over-utilization. This new report could be a game changer with regard to Medicare coverage for hyperbaric treatments. Be sure to read it carefully and make any necessary corrections in your practice or wound program to ensure that you remain compliant in this important area. Wound Care Advantage partners will have the added benefit of in-depth analysis, recommendations, and EHR adjustments to meet the new requirements.
Fallout from the Palmetto GBA service-specific prepayment complex review: In this review, 58.2% of 655 total claims were denied for various reasons. The top three denial reasons were:
- No documentation of medical necessity (73%)
- Failure to follow recommended protocol (12.78%)
- Lack of physician orders (7.12%)
Because of the dollar amount involved with the denials ($2,736,517.21), we foresee increased scrutiny in these areas from the remainder of the Medicare Administrative Contractors (MACs). I recommend taking a few steps now in preparation: Put a process in place to review all potential HBO patient’s charts with these fallouts in mind, and proactively modify your EHR to meet these challenges.
At WCA, our specialty in-house team of experts review documentation from our programs every night, ensuring compliance and the highest level of accuracy.
Expect more HBOT-experienced Recovery Audit Contractors (RACs): Providers with high error rates after three rounds of Targeted Probe and Educate (TPE) may be referred to CMS for additional action, which may include referral to a Recovery Audit Contractor (RAC). RACs with experience in HBO are more likely to identify issues in documentation, medical necessity, or utilization, which may require a Medicare payback for both the physician and facility. Carefully reviewing what we learned above from Palmetto and incorporating changes in those areas may minimize that risk.
HBO trained Joint Commission inspectors: Over the past year, we’ve seen an increased knowledge of HBOT in Joint Commission inspectors across the country. In our opinion, this raises the bar on patient care issues because the inspectors have a higher level of training and a solid understanding of HBOT as a treatment modality. HBOT has a potential for harm or loss of life if performed incorrectly or without adherence to industry standard safety protocols. Make sure your unit is meeting the standards at all times, and this will be an easy transition to weather.
A new edition of NFPA-99: Available now, but dated 2018, is the latest version of the NFPA-99. Chapter 14 remains dedicated to hyperbaric facilities. You can register on the NFPA website for free online access to the latest edition, but it is highly advisable to purchase a hard copy for your unit for easy reference. When you’re reading it online, you can quickly note the changes from the previous version by using a key at the bottom of each page. Anyone involved with hyperbaric operations should study and adopt the new version where applicable.
The new year will undoubtedly be a challenging one in the hyperbaric industry. Careful consideration of these changes and challenges, along with a diligent watch for any unforeseen issues, will better position your hospital to continually meet the needs of patients requiring HBO therapy.