Compliance

Three areas of constantly changing compliance standards which the busy clinician has little hope of adequately monitoring:  Billing Compliance, HIPAA Compliance, and the new P4P Best Practices. 

Janus Health maintains online monitoring of all three topics and provides clinicians with continuously-updated suggestions as to how to make changes in their facesheet to meet evolutions in billing practices or filings for Pay for Performance (P4P) bonuses.  By meeting the current and proposed electronic reporting standards and enabling a paperless, mobile charting AND communications system, the JanusOS^SM allows you to BE compliant and STAY complaint in the future.

Billing Practices

The template chart provided to clinicians by Janus was developed over two decades and 300,000 housecalls billed to Medicare.  Due to the targeted nature of home visits by CMS Carriers, over 5,000 Carrier-denied claims had been appealed to the Fair Hearing and Administrative Law Court resulting in an overall reversal rate of 92%, whether calculated on collected revenue or actual overturned denials.  In the last five years, twenty-one Comprehensive Medical Reviews were overturned 100% at the Fair Hearing level (now called Re-Determination).

Janus provides this template chart based upon expert representation at all levels of this audit process.  Housecall payments are frequently audited due to the higher average level of service rendered to this patient population and apparent inconsistencies at the Carrier level.  The template makes compliant charting easy on one page and avoids the added expense of three page dictations, which are not, in fact, a good defensive mechanism for the housecall clinician.

Many housecall physicians have little time to understand the complexities and unique aspects of how each Carrier performs the audit function.  With extensive experience in five states with different CMS Carriers, the Janus template charts were designed to meet the requirements at all three levels of Carrier screens: the initial technical screen by clerks looking at compliance with the E/M coding requirements; the appeals screen where free text is used to describe why a housecall was made instead of an office visit, and the advanced, physician-to-physician level where a face-to-face encounter determines payment at the Re-Determination hearing or in Administrative Law Court.

It should be mentioned that the uniqueness of the Janus compliance system places more emphasis on what is NOT included in features than what IS included.  For instance, the housecall physician does NOT need complex disease state management algorithms which have little application in the advanced care of the frail elderly.  Such large databases, common in many EMRs, prevent scalability of the network in your practice.  Janus provides ‘anytime, anywhere’ wireless broadband access through its VPN to your preferred “Favorite” resources on the internet to avoid duplication of resources and slow response times.

HIPAA Compliance

The use of paper medical records is essentially a non-compliant practice.  It is impossible to protect the names of your patients on the chart, or even the chart itself, during the frequent transfers and drop-offs required in a multi-clinician group practice setting.  Janus converts all Private Health Information (PHI) to digital means and meets the highest standards present or proposed for certification of the EMR.  Janus monitors and maintains the standards represented by the CCHIT process, an on-going certification process for EMRs which will soon become mandatory for all CMS billing.

The labor intensity of patient signature acquisition on medical records for permissions, etc. is well-known to the housecall clinician.  Janus allows any mobile clinician with a tablet computer to simply open a template form (which they may have customized for their own practice) and have the patient sign directly into the electronic chart.  With no paper being generated, no PHI issues are compromised and a paper signature cannot be lost.

The electronic standards for transmission of PHI are one of the highest cost barriers to the compliant mobile practice.  The requirements for using a changing syntax standard (currently HL-7), 128 bit encryption (which may change), and other evolving federal or state standards makes data transfer highly intensive.  The current crop of so-called “EMRs” do not account for the slow upload speeds of the wireless broadband community, since they were constructed for the office physician who either uploads over his LAN cable in the office or downloads at available high-speed cable rates.  Janus was designed from the beginning for slow, wireless upload speeds using high value encryption, so additional encryption requirements will not produce a legacy problem.

Pay For Performance Measures

On July 1, 2007, physicians became eligible for the first tranche of bonus P4P codes.  All physicians treating patients with diseases eligible for specific performance reporting have access to a 1.5% bonus if they simply submit a code to report compliance with the standard in over 80% of their patients.  This program will expand rapidly with the CMS intent clearly to foster better compliance with national Best Practices and use electronic chart reporting to screen for payment up front.

The original Janus Beta Site, the Call Doctor Medical Group in San Diego, has been selected as one of the few practices to participate in a three year CMS Demonstration Project called the Medicare Care Management Program.  JanusOS^SM allows simple clicking on an easily customized template chart for P4P compliance reporting, so the significantly higher payments for the Demo (up to $200,000 over three years for the Call Doctor Medical Group), as well as the current 1.5% bonus, can be rewarded with essentially no administrative burden other than a few button clicks at the time of the housecall.

The Janus Document Management System anticipates both the coming mandate for electronic charting and the need for frequent changes into the template chart to meet a clinician’s changing needs for P4P documentation.  As a result, we foresee no need to re-engineer the various background software programs for the P4P revolution which has caught many EMRs unaware.