Medicare Dare
On yesterday's CMS NPI Roundtable, the fine folks (and I truly mean that) from the Office of E-Health Standards and Services repeated their admonishment that they can't investigate a suspected violation without someone filing a complaint. You can remain anonymous, they said, but remember that if you do, it can be hard to reach resolution, because the process is designed to elicit a back-and-forth exchange between the parties to reach consensus.
They said, in the 500 or so transaction complaints filed thus far, there have been no instances of retribution.
(Go tell that to your CFO, quick!)
What they did not mention is that OESS never publishes the results of such disputes, much less details of the proceedings. What they did not mention is that there have been absolutely no fines imposed for transgressing the Transactions and Code Sets Final Rule in the four and a half years since the end of the October 2003 contingency.
(Thought Experiment: Apply those same enforcement rules to traffic violations and imagine what the fenders on your car would look like. That's what TCS looks like.)
But even as we careen toward May 23, with 80 - 90% of claims currently being submitted in a way that would fail the NPI-only edits Medicare insists it will put in place on that date (this according to our survey, based on provider's own reports of all claims, not just Medicare claims), who is going to volunteer to take on the biggest gorilla in the healthcare jungle?
Um, how about me?
Look, the reason I can say the things I say here, the things you readers tell me you wish you could say, but can't, is because my little company does not rely on Medicare for a single penny of its meager operation.
That's the good news.
The other news?
We rely on you.
You've already seen that we can and will file and prosecute challenges in the standards arena, when we submitted a direct challenge to Medicare's Secondary Provider edits (that eleventh hour change they talked about on yesterday's call went out via email overnight -- and it's still noncompliant, and it will still cause massive disruptions to provider revenues). It took a while, and we kept quiet about it, but we got the opinion we knew was right. X12 took the daring step to stand up for the rules we created together as an industry.
Will OESS do the same?
I'd like to see. Would you?
Here's the deal I will offer you.
You help us do it, and we will share the results here. Right in the great wide open.
We need to sell some papers. We need you to buy a copy of our NPI Contingency Status Survey report -- not cheap at $995 [Ed. note: there's a MAY DAY! special going on over at http://surveys.hittransition.com. The report is half price May 23 through 31.], but well worth the price of admission. You get the full results of the survey, plus the analysis of why continuing forward on the course we are on will snare the industry in a needless and heedless mess, and what can be done about it -- inside your organization and as an industry -- if we act now. And, under our Buy-One, Send-One deal we will send even an additional electronic copy of the analysis to the trading partner or government official of your choice. (This is a limited time offer. Your mileage may vary. Not to be taken with alcohol.)
The report will be available as soon as I can get all the rest of the words and charts poured into the massive document [Ed. note: Done. 106 glorious pages with hyperlinked citations of all the rules CMS is violating and misinterpreting and all the ways this is bolloxing up any plan for an NPI-based future. Dozens of charts, three spreadsheets with questions and answers, all de-identified to protect the innocent, and, of course, guidance to help you work through the tangle of contradictory demands being placed on your operational staff.] . But you can buy it now.
If we can sell ten copies -- just ten! -- we will take the fight to OESS to enforce against Medicare. We will tell them that admitting they are violating their own regulation is not enough. They need to stop it before the bounce claims from here to Timbuktu.
And we will share the process with you.
Go. Buy it. Help us out here, folks. We're doing this for you.
Comments