A Quarterly Publication of Florida Medical Group Management Association

Florida MGMA NewsFlorida MGMA News

Vol. XIV Issue II

Summer 2016

MARK YOUR CALENDARS! Florida MGMA Annual ConferenceJune 22-24, 2016 - Hyatt Regency Grand Cypress, Orlando

The Florida MGMA 2016 Conference will be held June

22­24 at the Hyatt Regency Grand Cypress. We have

over 100 of our members signed up to attend and we

hope you are planning to join us! You can sign up to

attend on our website at www.flmgma.com under the

Education Tab or on our Home Page. Be sure to loginfirst to receive the member rate on the conferenceregistration fee! Our discounted “Early Bird” rate has

been extended till May 25th so take advantage of these

savings.

Make your hotel reservations directly with the Hyatt

Regency Grand Cypress at (407) 239­1234 and identi­

fy yourself as part of the Florida MGMA to receive our

group rate of $189 per night. Make your reservations

online by going to our website at www.flmgma.com

by going to the Education Tab and then 2016 Annual

Conference page and click the button provided (in

blue). Reservations will be accepted in our group

block until May 20, 2016 or until the group block is

sold out.

The Hyatt Regency Grand Cypress is an excellent loca­

tion for a quick summer vacation right in your backyard!

The hotel includes a 850,000 gallon lagoon­style pool that

has 12 waterfalls, a water slide, a rope bridge, and a

swim­through rock grotto with a hidden jacuzzi. Also

included is use of the fitness center as well as various

bikes and boats and even a rock climbing wall...all at no

additional cost!

We look forward to having you in attendance at our

Conference. Please contact us at: lisa@flmgma.com

you have any questions.

2015 ­ 2016 BOARD OF DIRECTORS

President

Sherry Mills

North Florida Surgeons

President Elect, Conference Chair

Lori­Ann Martell, LPN, CMPE

Advanced Medical Center, Inc.

Treasurer

Ilene Gilbert­Droge, FACMPE

Practice Administrator

Past President

Marynell Lubinski, FACMPE

Miami Jewish Health Systems

Florida Collaborative Chair

Dori Siverio­Minardi, MPH, MBA, CMPE

Women’s Care Florida

ACMPE Representative

Tom Menichino, FACMPE

The Villages Health

ACMPE Representative

Lori­Ann Martell, LPN, CMPE

Advanced Medical Center, Inc.

Vice President ­ North East

Patricia Pugh

Jacksonville Center For Reproductive

Medicine

Vice President ­ North West

Chip Geitz, CPA, CMPE

Medical Center Clinic

Vice President ­ Central

Gerry Bessette

Medical Associates of Brevard

Vice President ­ Central West

Tracey Mitchell

USF Physicians Group

Vice President ­ South East

Rob Parker

Memorial Healthcare System

Past President at Large

Michael A. Franks, MPA, CMPE

Premier Dermatology

Member At Large

Kevin Pizzuti, CMPE

The Villages Health

Executive Director

Lisa Beard

(561) 452­6702 ~ flmgma@yahoo.com

My message to all Florida MGMA

members is to encourage you to attend

the annual Florida MGMA 2016 confer­

ence at the Hyatt Regency Grand

Cypress in Orlando, FL.

This year the Conference will be held

on June 22­24, 2016 and with the

tremendous line up of speakers you will

not want to miss this Conference!!!

Reminder to make your hotel reserva­

tions with our MGMA group block which

is open until May 25, 2016, or until the

group block is sold out. This hotel is a

vacation paradise and what perfect tim­

ing in the middle of summer to plan a

get away for your family and enjoy all

that Orlando has to offer.

The theme this year describing so

many of us is the Amazing Race…of

Medical Practice Management. Lori­

Ann Martell, Conference Chairman and

Lisa Beaird, Executive Director, have

put together a wonderful line up of

speakers, topics and activities.

The opening session on Wednesday

will be presented by Mary Kelly, a very

well known speaker from Denver, in

regards to “Change Management”

Survive and Thrive in the New

Economy”. Change is something we

experience every second in healthcare

and Mary Kelly’s session will offer to all

levels of management ways to imple­

ment and achieve success while going

through changes in our offices.

Wednesday evening we will have an

opportunity to have some great fun and

relaxation with Casino Night and a

great dinner which will give you the

opportunity to meet other Florida

MGMA members. Florida MGMA, I am

proud to say, has over 500 members

with eleven local chapters in Florida

and our newest Chapter from Panama

City.

Bright and early Thursday morning

Florida MGMA Collaborative

Committee will meet with Doria Siverio

chairing this hard working committee.

There will also be several breakout

sessions offering a variety of topics

including:

HIPPA Security Audit

Healthy Conversations for ToughIssues

Employment Law 101:Avoiding theEmployee Race to the Courthouse

The Payer Contracting Process:Negotiating and Managing Like a Pro

Payer Credentialing and ProductParticipation­Avoiding Related Denials

Ethical Leadership­Who are You

What do You Stand For

Making your Business IntelligenceDrive Improvements in Your Practice

Risk Management Strategies forPhysician Practices Applying RiskReduction Strategies to EnhancePatient Safety

Practice Management 101 – Equippingthe Next Generation of PracticeMangers for Success

A Message from the President

Sherry MillsFlorida MGMA President

2 continued on page 3

3

A Message from the President,continued

Thursday’s General Session will be presented by

Geeta Nayyar, MD, MBA “Social Media, Women,

and Patient Engagement” Listening to the Digital

Voice and Reaching Today’s Healthcare Consumer.

On Friday we have the MGMA Washington Update

– presented by Susan Falk from National MGMA

Department of Government Affairs in Washington,

DC. And “Pathway to Certification and Fellowship

with the ACMPE” presented by Lori­Ann Martell,

CMPE. The closing session will be presented by CJ

Coolidge “People Driven Business­Things are start­

ing to crack”

I also want to take this opportunity to personally

thank the vendors that participate and support

Florida MGMA. Without the support of the vendors

we would not be able to have a conference with this

magnitude. The Exhibit Hall will give everyone an

opportunity to see new products, ideas and meet

our vendors.

I have been attending the conference for many

years and along with the education and knowledge

I bring back to my group I enjoy the opportunity for

the networking. I have developed some wonderful

friendships throughout the years and value the net­

working in building a successful practice.

See you in June!!

Sherry Mills

President, Florida MGMA

Florida MGMA Conference Exhibitors

Agency for Healthcare

Administration

Alltek Services

CareCloud

Danna­Gracey, Inc.

Echo, a Healthstream

Company

Florida Blue

HealthPort | IOD

Insurance Office of

America

ITG Diet

Kareo

Landrum Professional

Employer Services

M*Modal

MagMutual

Marketing Works

MediGain

MedPro Group

Navicure

NORCAL Mutual

Insurance Company

Oros Risk Solutions

Physician Business

Services, LLC

Physicians Trust

Points Group

ProAssurance

Pulse

Singlecare Services, LLC

SkyCreek Health

Stericycle

Communication Solutions

TeleVox

The Doctors Company

The LBA Group

Tobacco Free Florida

TransWorld Systems, Inc.

UnitedHealthcare

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MIPS: Coming Your Way

Last week, the Centers for Medicare & Medicaid

Services (CMS) released a Proposed Rule in the

Federal Register. This massive, 962­page document

describes the government’s approach to future

Medicare reimbursement, as required by the

Medicare Access and CHIP Reauthorization Act

(MACRA), which was signed into law in April of 2015.

The new program is the Merit­based Incentive

Payment System (MIPS), with the government’s stat­

ed goal to transition to a new payment model based

on an assimilation of the programs requested of

physicians today. Instead of the Electronic Health

Record (EHR) Incentive Program, the Physician

Quality Reporting System (PQRS) and the Value­

based Payment Modifier (VBPM), the government is

fusing them together into a single payment platform.

The new payment model is based on a MIPS

Composite Performance Score (CPS), calculated on

a 0 to 100­point scale. The score, designed based on

CMS’ conversions of measures and activities to

points, determines your Medicare payment adjust­

ment – up or down. Geared to commence in 2019 as

required by MACRA, CMS is using the coming year –

calendar year 2017 – to base the initial reimburse­

ment. Unlike past programs, this isn’t a voluntary

process. All physicians (except for new ones or

those with only a trickle of Medicare business) are

enlisted, as well as a vastly expanded list of health

care professionals.

Let’s break down the proposed categories of the

MIPS CPS for the 2017 reporting year:

Quality: This category, which replaces the multitude

of quality indicators being requested by the various

government programs today, counts for 50% of the

first year payment program. While PQRS required

nine criteria, MIPS drops the count to six measures,

offering new specialty measure sets as well as indi­

vidual standards. From a reporting perspective, there

are a multitude of methods by which to report, includ­

ing most of those available by PQRS today.

Resource Use: Accounting for only 10% of the score,

CMS also dubs this category as “costs”; designed to

parlay the cost component of the VBPM program, the

score is calculated based on a behind­the­scenes

assessment of your Medicare claims, with no

required reporting of data per se.

Clinical Practice

Improvement Activities:

A totally new category,

this is probably the one

that will bring the

biggest surprise.

Eligible health care pro­

fessionals will report a

minimum of one activity

out of 90 proposed for a

score to which 15% is

attributed, with addition­

al credit for more

actions. The activities

include care coordina­

tion and after­hours care, with most of the list of 90

falling under practice operations. Of note, if you are a

patient­centered medical home, you automatically

get the full credit for this category.

Advancing Care Information (ACI, the government’s

proposed new term for meaningful use [MU]):

Replacing MU, this category, which accounts for 25%

of the score, features the measures related to the use

of an EHR system. Think of it like MU Phase 2,

although fundamental changes are in store. These

include participating as a group practice, dropping

the “all or nothing” aspect of the program, and elimi­

nating the measures related to computerized

provider order entry (CPOE) and clinical decision

support (CDS). Given the fact that physician assis­

tants (with few exceptions) and nurse practitioners

were not eligible to participate in MU in the first place,

CMS is exempting these advanced practice providers

from the ACI category. The tally for this category is

centered on a base score, a performance assess­

ment and even a bonus point. Just like MU today,

you’ll report a numerator, denominator or yes/no for

the criteria. While there’s a new name, the standards

required for reporting are familiar, to include protect­

ing health information, electronic prescribing and

patient electronic access.

You may have heard that you can get out of the new

MIPS program – and even qualify for a boost in reim­

bursement – by being a member of an “alternative

payment model” (APM). That’s correct, but CMS

reveals – not surprisingly – that the model must be a

specific so­called advanced APM. To be a qualifying

APM participant, you are obligated to have a certain

Elizabeth Woodcock,MBA, FACMPE

continued on page 6

5

MIPS: Coming Your Way, continued

percentage of your patients or payments through an

advanced APM during the reporting year (2017 for

the 2019 payment adjustment, for example). These

advanced APMs, which include CMS Innovation

Models and Medicare Sharing Savings Program

Tracks 2 and 3, must require participants to use an

EHR system (more than 50%, for the first year, climb­

ing to 75% by year two), base payment on quality

(including at least one outcome measure) and take

financial risk. The final criterion is really the deal

breaker, with explicit financial risk standards.

In essence, if you want to get out of MIPS and

achieve an additional, automatic, lump sum bonus of

5% of your Medicare reimbursement, CMS is making

sure that dodging the new payment structure puts

you in an entity that mirrors the principles of MIPS.

CMS is accepting comments on the Proposed Rule

now, so it will likely be the end of the year before we

fully understand the new payment model. This leaves

little time to prepare for the initial reporting period for

MIPS, which commences January 1, 2017, with

adjustments in 2019. According to CMS, you’ll get

your first feedback report in July 2017. Four percent

is at risk, but more “losers” will drive the eligible

bonus for high performers to 12% to ensure the

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wrednd und aeusse irs aecivred sns atcudore pcna.setailfifs atd iny anapmoe Ccna

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required budget neutrality for the program. Plus, an

additional 10% is available for “exceptional” perform­

ance. The potential upside is very compelling, but

there are clearly a set of hoops to jump through to get

there.

CMS is no longer dabbling in payment adjustments –

either you’re in, or you’re out. Increase your knowl­

edge base in the coming months, in order to ensure

success in 2017.

For more information, go to this link for CMS’ sum­

mary of the proposal.

https://www.cms.gov/Medicare/Quality­Initiatives­

Patient­Assessment­Instruments/Value­Based­

Programs/MACRA­MIPS­and­APMs/NPRM­QPP­

Fact­Sheet.pdf

­ Elizabeth Woodcock, MBA, FACMPE, CPCWoodcock & Associates

www.elizabethwoodcock.com

6

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Welcome New Florida MGMA Members

Active Member

Lynda Barrie

Kirland Healthcare Solutions, LLC

Malabar

Jennifer Black

HCA Physician Services Group

Hudson

Roxanne Cato

First Physicians Group

Bradenton

Melanie Herring

St. Vincent’s Physician Enterprise

Jacksonville

John Hornberger

Orthopedic Center of Palm Beach

County

Lake Worth

Melissa Jimenez

Gastro Health, PL

Miami

John Kasper

Brooks Rehabilitation Hospital

Jacksonville

Esperanza Llaneza

Pedro P. Llaneza, MD, P.A.

Miami

Tamara Martin

Pain Consultants of West Florida

Pensacola

Donna McCool

Southeast Orthopedic Specialists

Jacksonville

Mufei Niu

Gastro Health, PL

Miami

Lynn O’Leary

All Florida Orthopaedic Assoc.

St. Petersburg

Ana Pardino

Gastro Health, PL

Miami

Rachel Pedulla

Florida Orthopaedic Associates,

P.A.

Orange City

Robert Phelan

Cancer Specialists, LLC

Jacksonville

Gina Schell

BayCare Medical Group

Clearwater

Ron Thompson

Cancer Specialists, LLC

Jacksonville

Miriam Tyson

HCA West Florida Division

Tampa

Debra Vosler

Gulfcoast Vascular Surgeons

Fort Myers

Teresa Welch

Pediatrics, University of Florida

College of Medicine

Gainesville

Affiliate Members

Taher Hamid

Alltek Services

Lakeland

Thomas Hofstetter

Points Group

Florham Park, NJ

Donald Wood

SkyCreek Corporation

Herndon, VA

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The Exit Interview: A Tool for Litigation Avoidance and Corporate Healthcare Compliance

It is important for all employers, including those in the

health care industry, to conduct exit interviews with

departing employees. The consistent use of exit

interviews serves numerous purposes, including pro­

tection of sensitive business information, achieve­

ment of overall improvement in workplace environ­

ment, and curtailment of employee turnover.

Using the Exit Interview

Exit interviews provide additional benefits to entities

that deal with and are regulated by the federal gov­

ernment, such as those in the health care industry.

With the numerous regulations and certification

requirements applicable to health care facilities, exit

interviews should be part of an institution’s overall

compliance program. An effective health care compli­

ance program will permit an entity to identify and

address possible regulatory or statutory violations, as

well as provide information necessary to assess the

potential for litigation.

Health care facilities that participate in government

reimbursement programs must be sensitive to fraud

and abuse litigation under various statutes, including

the antikickback statute, the Stark law (anti­self­refer­

ral), and a number of civil and criminal statutes

addressing false claims and fraudulent billing.

Attention to these compliance issues will, in turn,

lessen the possibility that an entity will become the

target of an investigation by the OIG, HCFA, HHS, the

DOJ, or some other federal or state agency.

Health care employers should also use the exit inter­

view to gauge the possibility for “general” employ­

ment litigation, such as a claim by a departing

employee for wage payment, harassment, or dis­

crimination.

In order to address issues of compliance, and to pre­

vent or prepare for litigation, exit interviews should be

used to elicit information concerning illegal or unethi­

cal behavior, workplace quality, personnel issues

such as quality of training/supervision, and other

issues stemming from the employment relationship

generally.

Uncovering Damaging or Illegal Behavior

When probing the possibility of illegal or unethical

behavior or practices in the workplace, a health care

employer should explore whether an employee

knows of circumstances suggesting that: 1) billing or

medical records were altered; 2) false or misleading

documents were submitted to a government agency;

3) expense reports were padded or falsified; 4) items

of value were offered or accepted for referrals; or 5)

legal or regulatory violations were covered up. To that

end, the following topics should be explored:

­ Did the employee witness any conduct that he or

she would characterize as either unethical or illegal?

Was the employee ever asked to engage in conduct

that he or she believed to be either unethical or ille­

gal?

­ Has the employee heard rumors or reports of uneth­

ical or illegal conduct which he or she considered

credible?

­ Were any company documents, including docu­

ments created by the employee, removed from the

institution and not returned? Does the employee

have any copies of documents anywhere off premis­

es?

­ Has the employee ever given company documents

to persons not employed by the facility? Has anyone

else at the facility done so?

­ Has any government investigator, agent, or attorney

interviewed the employee or asked to interview the

employee about possible unethical or illegal conduct

relating to the facility?

10

The Exit Interview: A Tool for Litigation Avoidance and Corporate Healthcare Compliance, continued

­ While employed with the company, did the employ­

ee or any family member own, operate, invest in,

assist, or otherwise have an interest in any company

or enterprise which competes with or does business

in the health care industry?

The above list is by no means exhaustive. The list

should be expanded to address areas of concern for

an employer; it should also be tailored to address the

employment circumstances of each departing individ­

ual.

Employees in coding or billing departments provide

but one example of the importance of the exit inter­

view. Because those employees are directly involved

with issues of reimbursement, they have a hand in

creating the documents that are submitted to the gov­

ernment for payment. If these documents contain

false information or statements, they may provide the

basis for litigation under the False Claims Act. A civil

action for a false claim will include, among other

things, inquiry into an institution’s awareness of gov­

ernment billing policies and requirements, as well as

an examination of an institution’s own billing prac­

tices and policies. The knowledge possessed by an

employee involved with reimbursement is crucial

because that knowledge may be imputed to the

employer in litigation. Thus, it is imperative to learn

what employees in reimbursement­related positions

know before they leave the facility’s employ.

Ascertaining the Possibility for Litigation

An employer should not overlook the use of the exit

interview as a tool to explore general facets of the

employment relationship. Discussion with a departing

employee will enable an entity to identify and assess

the possibility for civil litigation stemming from that

individual’s employment. This litigation can take

many forms, but employers should be especially sen­

sitive to the possibility that a departing employee may

be harboring a claim of employment discrimination or

harassment. To that end, the exit interview should

focus on an individual’s:

­ Reason(s) for leaving. If the individual was termi­

nated, it is crucial to examine his or her understand­

ing of the events leading to the termination. A similar

inquiry should be made if the departing employee

was subject to disciplinary action.

­ Beliefs concerning whether appropriate opportuni­

ties for advancement were available.

Comments concerning the level of pay and provision

of other benefits.

­ Overall assessment of working conditions, including

the workplace “dynamic” and interactions with super­

visors and peers.

Health care institutions should also use the exit inter­

view to learn more about an individual’s assessment

of workplace quality. Thus, topics that should be

raised and discussed during an exit interview include

an employee’s opinion of the supervision he or she

received, evaluation of the effectiveness of training,

likes and dislikes about the institution and/or its poli­

cies, recommendations for change in the workplace,

and overall assessment of working conditions.

Applying Information Learned

If the exit interview reveals that an employee encoun­

tered no illegal or unethical practices, the form used

and notes made during the interview should be

placed in the departing employee’s personnel file. If,

on the other hand, the interview reveals that an

employee may have witnessed illegal or unethical

practices, or if information is uncovered which sug­

gests that a departing employee has a complaint of

harassment or discrimination, counsel should be noti­

fied immediately. An investigation must follow in order

to diffuse the situation, assess whether the employee

has viable claims, plan for the possibility of litigation,

and preserve testimony and documents, should liti­

gation ensue.

Information uncovered during an exit interview simply

cannot be ignored, and statements made by depart­

ing employees must be taken seriously. Using the

exit interview to monitor the potential for wrongdoing,

unethical behavior, unsafe or unsound business

practices, and litigation will help the health care

employer run a more efficient facility.

­ Reed Tinsley, CPA

www.rtacpa.com

11

Post Office Box 380124

Birmingham, AL 35238­0124

Visit us on the web at www.flmgma.com