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Briefing: Basic Policies. Date: 25 March 2010 Time: 1110-1200. Objectives. Recognize the differences between statutes (laws), regulations, policies, directives, instructions, and manuals Identify those policies that directly affect how you do your job. Statutes (Laws) v. Regulations. - PowerPoint PPT Presentation
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2010 UBO/UBU Conference
Health Budgets & Financial Policy Briefing: Basic Policies
Date: 25 March 2010
Time: 1110-1200
2010 UBO/UBU ConferenceTurning Knowledge Into Action
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Objectives
Recognize the differences between statutes (laws), regulations, policies, directives, instructions, and manuals
Identify those policies that directly affect how you do your job
2010 UBO/UBU ConferenceTurning Knowledge Into Action
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Statutes (Laws) v. Regulations
Statutes (Laws)
Passed by the legislative branch– United States Congress– State legislatures
Provide broad basis of “do’s and don’ts”– Usually so broad, they need implementing
“guidance”
2010 UBO/UBU ConferenceTurning Knowledge Into Action
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Statutes (Laws) v. Regulations
Regulations
Developed by executive branch agency responsible for that subject matter
Help clarify the intent of the law– Examples
Medicare law– Regulation promulgated by CMS (part of DHHS)
Military health care– Regulation promulgated by TMA (part of DoD)
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Statutes (Laws) v. Regulations
Regulations – Stages
Notices – Announcements to the public– MAC rates– DD Form 2569
Proposed Rules– Implementing new law– Changing existing regulations– Comment Period
2010 UBO/UBU ConferenceTurning Knowledge Into Action
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Statutes (Laws) v. Regulations
Regulations – Stages
Final Rules– Summarize comments from proposed rules– Have the force of law– Interim Final Rules may be effective immediately
with Comment Period
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Statutes (Laws) v. Regulations
2010 UBO/UBU ConferenceTurning Knowledge Into Action
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Policies
Developed as needed Further interpretation of a regulation
2010 UBO/UBU ConferenceTurning Knowledge Into Action
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HA Policies
Permanent Prohibition Against Requiring Certain Injured Members to Pay for Meals Provided by Military
Treatment Facilities
(FY NDAA 09 – 4 Feb 2009)
MTFs must furnish meals at no cost to military members receiving inpatient or outpatient services for an injury, illness, or disease caused while in combat
Includes medical recuperation or therapy or other continuous care
2010 UBO/UBU ConferenceTurning Knowledge Into Action HA Policies
DHP Accounts Receivable Policy
(2 May 2008) Policy to recognize, collect, and report accounts
receivable Goal: Improve the accuracy of financial statements and
prepare DHP-funded activities for audit Compliance by each Financial Statement Reporting
Entity (FSRE) required by 30 September 2008– Delayed until 30 September 2009
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2010 UBO/UBU ConferenceTurning Knowledge Into Action HA Policies
Policy Guidance for Provision of Medical Care Provided to DoD Civilian Employees Injured or Wounded While
Forward Deployed in Support of Hostilities (24 September 07)
DoD Civilians who become ill, injured, wounded while
forward deployed are eligible for medical evacuation and treatment in MTFs as if they were military personnel
Worker’s Compensation – employee is treated at no cost
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2010 UBO/UBU ConferenceTurning Knowledge Into Action HA Policies
HA Policy 08-007Policy for Billing and Collections for
TPCP, MSA, MAC in MTFs
Billing and collection activities may be performed by MTF personnel, other Government personnel, contract personnel, or any combination of personnel
Billing and collection activities may be performed at the MTF, other Government location, contract location, or any combination of locations
MTFs are not restricted to using TPOCS or the MSA module in the Composite Health Care System
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2010 UBO/UBU ConferenceTurning Knowledge Into Action HA Policies
HA Policy 08-007Policy for Billing and Collections for
TPCP, MSA, MAC in MTFs
The Services must provide management data to TMA UBO on request
The Services should implement best business practices to manage their collections programs and to meet TMA UBO reporting requirements
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2010 UBO/UBU ConferenceTurning Knowledge Into Action HA Policies
HA Policy 08-002
Policy for Billing for Care Furnished by Military Treatment Facilities to Federal Employees for On-the-Job Injuries
and for Occupational Health (8 April 2008)
Bill NAF at IAR for Occupational Health and OTJ injury Do not bill DoD when furnishing Occupational Health or
care for OTJ to appropriated fund DoD employees Bill all other federal agencies at IAR for Worker’s Comp Bill employees for all other care unless they are a
beneficiary
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HA PoliciesHA Policy 07-026
Policy for Billing Non-Department of Defense Beneficiary Newborns
DoD has a legal obligation to recover reasonable cost of health care services to non-DoD beneficiaries
MTFs are to bill for newborns of family member daughters and for certain former Service members– Bill for services from time of birth to time of discharge– Use full reimbursement rate
2010 UBO/UBU ConferenceTurning Knowledge Into Action
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HA Policies
HA Policy 06-010
HIPAA Security Compliance
Implements DHHS Security Standards HIPAA Security charges organizations to protect e-PHI
against any reasonably anticipated threats or hazards to the security and integrity of the information
Protect against any reasonably anticipated uses or disclosures that are not permitted under HIPAA
Retain compliance documentation for six years
2010 UBO/UBU ConferenceTurning Knowledge Into Action
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HA PoliciesHA Policy 05-020
Policy for Cosmetic Surgery Proceduresin the MHS
To accomplish wartime mission, we need specialists skilled in reconstructive cosmetic surgery
– These specialists need to perform surgery regularly to keep up their skills/certification
– Cosmetic procedures are authorized in direct care system under limited circumstances
Only privileged staff/residents in plastic surgery, otorhinolaryngology, ophthalmology, dermatology, oral-maxillofacial surgery may perform cosmetic surgery
– 20% of their practice
2010 UBO/UBU ConferenceTurning Knowledge Into Action
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HA Policies
HA Policy 05-020Policy for Cosmetic Surgery Procedures
in the MHS
Civilians providers may only perform if they are employed full-time by MTF
Cosmetic surgery performed “space available”– May not exceed 20% of the physician’s case load
Only for TRICARE-eligible beneficiaries– Active duty must have written permission from unit
commander All patients must pay
– Complications are not a covered benefit
2010 UBO/UBU ConferenceTurning Knowledge Into Action
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HA Policies
HA Policy 04-028Termination of Subsistence Surcharge for Uniformed
Services Personnel in MTFs
Do not collect daily subsistence surcharge from Active Duty or retired members hospitalized for medical care
2010 UBO/UBU ConferenceTurning Knowledge Into Action
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HA Policies
Compliance Plan Implementation Policy
(28 February 2002)
“The adoption and implementation of compliance programs significantly advances the prevention of fraud, while furthering the mission of providing quality care to patients”
MTFs and other DoD-designated billing activities must establish and comply with compliance guidelines– Establish a compliance plan focused on coding and billing
ethical conduct– Perform a compliance audit at least quarterly
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HA Policies
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DoD Issuances
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Instructions (DoDIs)
Implement policies– Prescribe how to carry out a policy– Include assigning responsibilities
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Instructions (DoDIs)
DoDI 6015.23 - Delivery Of Healthcare At Military Treatment Facilities: Foreign Service Care; Third-party Collection; Beneficiary Counseling And Assistance Coordinators (BCACs)– Implements policy, assigns responsibilities and
prescribes procedures for Healthcare delivery at MTFs International military reciprocal healthcare agreements Beneficiary Counseling and Assistance Coordinator
responsibilities
– Authorizes Classification Nomenclature and Definitions Relating to Fixed
and Non-fixed MTFs (DoD 6015.1-M) Military Treatment Facility Uniform Business Office (UBO)
(DoD 6010.15-M)
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Instructions (DoDIs) DoDI 6010.23 – DoD/DVA Health Care Resource
Sharing Program– Implements policy, assigns responsibilities, and prescribes
procedures to develop/operate DoD/VA Health Care Resource Sharing Agreements when it is determined that resource sharing will improve access to quality health care or increase cost-effectiveness of the health care provided by MHS and DVA to beneficiaries of both Departments
DoDI 6025.18 – Privacy of Individually Identifiable Health Information in DoD Health Care Programs
– Was originally a Directive (6025.18)– Establishes policy and assigns responsibilities to implement
standards for privacy of individually identifiable health information
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Instructions (DoDIs)
DoDI 6040.40 – Military Health System Data Quality Management Control Procedures
– Policy to implement the MHS Data Quality Management Control (DQMC) program
DoDI 6040.42 – Medical Encounter and Coding at Military Treatment Facilities
– Implements policy, assigns responsibilities, and prescribes procedures for the documentation and coding of outpatient medical encounters in MTFs
2010 UBO/UBU ConferenceTurning Knowledge Into Action
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Instructions (DoDIs)
DoDI 5505.12 – Anti-Fraud Program at Military Treatment Facilities (MTFs)
– Implements policy, assigns responsibilities, and prescribes procedures to prevent, detect, report, and evaluate suspected fraud by contracted civilian healthcare providers at all DoD MTFs
2010 UBO/UBU ConferenceTurning Knowledge Into Action Instructions (DoDIs)
DoDI 1000.24 – Confiscation of Fraudulent Identification (ID) Cards at Military Treatment Facilities– MTFs must have an ID card fraud policy program – MTFs have a duty to identify and eliminate eligibility
fraud– Checking eligibility in DEERS – MTF must seek recovery of costs for any medical
care furnished to anyone found to be ineligible
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2010 UBO/UBU ConferenceTurning Knowledge Into Action Instructions (DoDIs)
DoDI 1000.24 – Common situations that affect eligibility:– Separation from the Service– Eligible children reach the age of 21 (except for
certain situations)– Divorce from a sponsor (unless the spouse meets
certain eligibility requirements)– Sponsors must report, within 30 days, any change in
their own status, or that of a family member, that affects eligibility for medical care.
Otherwise, they run the risk of being financially responsible for any medical care provided
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2010 UBO/UBU ConferenceTurning Knowledge Into Action Instructions (DoDIs)
DoDI 1000.24– MTFs should ensure that a responsible individual
reviews the daily CHCS report listing individuals who received care and are not in DEERS
– MTFs are not the final decision-makers on beneficiary eligibility for care
Only Service Personnel offices can make final determinations of beneficiary eligibility
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DoD Directives (DoDDs)
Broad policy documents Establish or describe policy, programs, and
organizations Define missions Provide authority Assign responsibilities
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DoD Directives (DoDDs)
DoDD 5400.11 – DoD Privacy Program
DoDD 6010.04 – Healthcare for Uniformed Services Members and Beneficiaries
The Uniformed Services shall operate medical and dental treatment facilities in accordance with applicable law, regulation, and policy
The CHAMPUS/TRICARE health care entitlement shall be provided consistent with current law
Health care beneficiaries shall be provided access to military treatment facilities
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DoD Directives (DoDDs)
DoDD 6025.13 – Medical Quality Assurance (MQA) in the Military Health System (MHS)
– Establishes DoD policy on issues related to MQA programs and activities
DoDD 6040.41 – Medical Records Retention and Coding at Military Treatment Facilities
– Establishes policy and assigns responsibilities for administering medical records retention and encounter coding
– Provides medical records retention and coding reporting– Provides guidance for medical records retention and
encounter coding at MTFs
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DoD Publications
Implement or supplement a Directive or Instruction– Provide uniform procedures for management or
operational systems and disseminating administrative information
Manual– Guidance document that has procedures with examples
for performing specific tasks
2010 UBO/UBU ConferenceTurning Knowledge Into Action
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DoD Publications
DoD 6010.15-M– UBO Manual
DoD 6010.13-M– MEPRS Manual
DoD 7000.14-R– DoD Financial Management Regulation
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DoD Publications
DoD 5400.11-R– DoD Privacy Program
Prescribes uniform procedures for implementation of the DoD Privacy Program
DoD 6025.18-R– DoD Health Information Privacy Regulation
Outlines uses and disclosures of protected health information
DoD 8580.02-R – DoD Health Information Security Regulation
Implements HIPAA
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DoD Publications
DoD 6015.1-M – Glossary of Healthcare Terminology
Uniform glossary of healthcare terminology for use throughout the Department of Defense
DoD 6025.13-R– Military Health System Clinical Quality Assurance
Program Regulation Identifies the various components comprising DoD’s
efforts to ensure that beneficiaries receive quality care
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Summary
Recognize the differences between statutes (laws), regulations, policies, directives, instructions, and manuals
Identify those policies that directly affect how you do your job
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Quiz
True or False:– Congress passes HA Policies– A policy is more important than a statute– Cosmetic surgery is a free covered benefit for all
TRICARE beneficiaries