HIPAA AND HITECH Update (50.0K)

Identity-Theft Red Flag Requirements

The Federal Trade Commission requires healthcare organizations that provide credit to patients to comply with identity-theft red flag rules. The organization must set up a process to find "red flags"--actions that might indicate an attempt to steal the person's personal data for illegal use.

The FTC released the final rules on what it calls “identity theft red flags” on November 9, 2007 in the Federal Register (72FR63718). Essentially, the requirement calls for the creditor (healthcare organization, office, or practice) to set up a process so that its staff can determine or identify possible identity theft “red flags” and respond. The rules are flexible, but do require identification of the potential problem areas, what action is to be taken, and a means to revisit the protocol and update as needed. The final rule and other guidance from the FTC provide suggestions for the flags that might be established.

After a number of delays, the rule takes effect Nov. 1, 2009

For further information read the current information at www.ftc.gov/redflagsrule. The rule contains an appendix (72FR63774) to assist businesses to set up the red flags. Helpful information is also offered on the American Medical Association website at

www.ama-assn.org/ama/no-index/physician-resources/red-flags-rule.shtml

CMS eliminates payment for medical consult codes

Effective January 1, 2010, CMS will stop payment for medical consults (99241-99245 and 99251-99255, other than the G codes that are used to bill for telehealth consultations), and redistribute the resulting savings to increase payments for the existing evaluation and management (E/M) services.

The work relative value units (RVUs) for new and established office visits, as well as initial hospital and initial nursing facility visits, will be increased to reflect the higher value of the office visits furnished during the global period.The RVUs for new and established patients will increase by 6 percent in 2010.

As we know, CPT and CMS define a new patient as one who has not received a service from a physician (or another physician in the same specialty, and the same group) in the past three years.

Insert for MGH Update (300.0K)

Update for CPT 2010 Resequencing (24.0K)