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There are different views as we discuss marketing activities in the healthcare arena. Yet, while some may even consider marketing healthcare services unethical the reality of the situation is that technology changes are forcing us to rethink strategies in terms of how to capture customers and run a successful business.

Marketing itself is a tricky area as you can throw money at it and never get the desired outcome. Another point to consider is that there is no such a thing as a sure-fire method that will work for everyone every time. Last, no marketing campaign can be allowed to…

Effective January 1, 2016, Medicare revised its “incident to” billing rules requiring that incident to services are billed under the physician who directly supervises the auxiliary personnel (i.e. the person performing the incident to service).

Most incident to services require direct supervision (defined below) of auxiliary personnel providing the incident to services.  When a physician’s billing number is used on a claim form, the physician is stating that he or she performed the service or directly supervised the auxiliary personnel performing the service.

What is FIPA?

FIPA is a law that went into effect July 1, 2014.  FIPA was enacted to protect the  security of confidential and personal information.  FIPA requires certain entities, referred to as “covered entities,” to report breaches of personal information to Florida’s Department of Legal Affairs.   Covered entities are also responsible for reporting breaches of their third party agents.  With the prevalence of hacking, data mining, and other activities that routinely threaten the security of electronic data, it is important for Florida businesses to understand their obligations under FIPA, establish policies and procedures to timely handle and report data breaches, and ensure that their third party agents report data breaches upstream so the covered entity can meet its reporting obligations.  FIPA also contains requirements for disposing of customer records.

Who must comply with FIPA?

    FIPA applies to “covered entities,” which means a sole proprietorship, partnership, corporation, limited liability company, trust, estate, cooperative, association, or other commercial entity that

NEW HHS GUIDANCE SUGGESTS EMR VENDORS AND OTHER BUSINESS ASSOCIATES CANNOT HOLD PROTECTED HEALTH INFORMATION HOSTAGE

The Department of Health and Human Services (“HHS”) recently issued guidance regarding the practice of a Business Associate cutting off a Covered Entity’s access to Protected Health Information (“PHI”). This may occur when a healthcare provider refuses to pay its electronic medical records (“EMR”) vendor or when the provider decides to switch vendors. The EMR vendor may cut off access to the EMR and the Covered Entity is left without access to its patients’ records.

MACRA is upon us and the urgency to act is paramount. However, rather than panicking and throwing away resources without a plan, we recommend more of an analytical approach. Find what tasks are needed, determine where you are, decide upon what can you do, make a plan and implement on a timely basis.

October 2^nd, 2017 is the last day to start collecting data for MACRA. For some healthcare professionals this means nothing so let me put it into context:

Failure to act will expose some healthcare professionals and organizations to a 4% penalty on payments which may go…

Just last week I received an email from one of my suppliers.  The gist of the email was as follows:

“On September 1^st, 2017, we were informed by our 3^rd Party Ecommerce Provider that their software platform which hosts our website experienced a data breach.  The investigation indicates the intrusion began in early July 2017 and was remediated prior to August 24^th, 2017.  During this time, the attackers gained access to certain customer information.”   

The sad part is that certain customer information turned out to be our credit card information with all corresponding information needed to complete transactions. Worse than…

I started this article and previous seminars by referring to MACRA as Medicare’s new payment system. However, that concept is incorrect and an oversimplification of MACRA.  MACRA stands for “Medicare Access and CHIP Reauthorization Act” and while the same will affect how Providers will get paid it is not necessarily a payment system.  Medicare considers MACRA a Quality Program and refers to MACRA as their Quality Payment Program.  At this point in time I feel comfortable writing that MACRA is a data collection initiative from Medicare that uses a bonus program as an incentive to get Providers to participate. Using…

“We live in interesting times.”

“It is the Wild West out there.”

“Change equals opportunity.”

I have heard all of these before and I keep hearing them as it relates to healthcare business. I have also heard that there is no money in medicine; and of course all the rumors about socialized medicine. Sad part about it is that I’m also seeing Providers getting out of the business and giving control to business people who are eager to jump in.

The truth is that the business of medicine is changing and medical schools do not train its students in the…