Wednesday, January 20, 2021

Many Healthcare Pardon's in Trump's Last Week

A journalist made the same conclusion, with a more detailed report:

https://medcitynews.com/2021/01/trumps-pardons-included-healthcare-execs-behind-massive-frauds/

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According to NBC, President Trump issued 70 commutations and 73 pardons on the day before leaving office, as covered in many news sources.  The White House.gov list was taken down due to the change in the administration (was here).     The Trump archives show 11 executive orders on January 18 (here).

See the archived website here, many of these are also listed at NBC here.

Quite a number the clemency actions involved healthcare cases.

  • John Estin David, CEO of healthcare company, commuted.
  • Dr Frederick Nahas, obstructing healthcare investigation, pardon.
  • Todd Farha and 4 other executives of an HMO, full pardons.
  • Salomon Meglen, healthcare fraud, commuted.
  • John Duncan Fordham, healthcare fraud, pardon.
  • Dr. Scott Harkonen, fraud re healthcare advertising, pardon.
  • Dr. Faustino Bernadett, hospital kickback scheme, tangential, pardon.
  • Dr. Robert Corkern, bribery, pardon.


Monday, January 18, 2021

Link to Notes on Noridian MolDx Public Meeting on Molecular Microbiology Panels

On January 11, 2021, MolDx and Noridian hosted a two hour workshop with about 8 experts on the uses of molecular microbiology panel tests (e.g. Biofire type tests.)

My general client notes summarizing the meeting and putting it in context are here:

https://drive.google.com/file/d/1C-K_yRbuWirXdoqpWBlgBFR5X-4LsRtQ/view?usp=sharing

A link to an UNOFFICIAL cloud transcript of the meeting is here:

https://drive.google.com/file/d/1vrlYp8EXYBbuFMDJSH2S6vaPkDIjJn0I/view?usp=sharing

At some point (a couple months?) Noridian will post an official transcript.



Wednesday, January 13, 2021

MFN Actual Rule: November 27, 42 FR 76180-259 (80pp)

 https://www.federalregister.gov/documents/2020/11/27/2020-26037/most-favored-nation-mfn-model

https://www.govinfo.gov/content/pkg/FR-2020-11-27/pdf/2020-26037.pdf

2020 CMS 1127 MFN Drug Price Euro Rule CMMI 85FR76180 80pp.pdf




Virus Database GISAID (Influenza and COVID)

 https://www.gisaid.org/




Enabling rapid and open access to epidemic and pandemic virus data

The GISAID Initiative promotes the rapid sharing of data from all influenza viruses and the coronavirus causing COVID-19. This includes genetic sequence and related clinical and epidemiological data associated with human viruses, and geographical as well as species-specific data associated with avian and other animal viruses, to help researchers understand how viruses evolve and spread during epidemics and pandemics.


GISAID does so by overcoming disincentive hurdles and restrictions, which discourage or prevented sharing of virological data prior to formal publication.


The Initiative ensures that open access to data in GISAID is provided free-of-charge to all individuals that agreed to identify themselves and agreed to uphold the GISAID sharing mechanism governed through its Database Access Agreement.


All bonafide users with GISAID access credentials agreed to the basic premise of upholding a scientific etiquette, by acknowledging the Originating laboratories providing the specimens, and the Submitting laboratories generating sequence and other metadata, ensuring fair exploitation of results derived from the data, and that all users agree that no restrictions shall be attached to data submitted to GISAID, to promote collaboration among researchers on the basis of open sharing of data and respect for all rights and interests.





Sunday, January 10, 2021

AMA on Professional Component, Lab services, 2005, 1999

 

August 2005 page 9

Professional Component for Clinical Laboratory Services (CPT codes 80048-89356)

Although the use of modifier 26, Professional Component, and clinical laboratory services has been previously addressed in the CPT Assistant (May 1999), the discussion continues to surface as an area of great interest among our members and subscribers. Building upon the May 1999 foundation, this coding update further expands upon the role of the pathologist with respect to their capacity in the clinical laboratory setting.

The use of modifier 26, Professional component, is required for CPT codes 80048-89356 in those instances when the physician is only billing for the professional component of the laboratory tests (eg, medical direction, supervision or interpretation). This method of reporting is appropriate when the technical and professional components are performed by different providers. A written report for an individual patient is not a requirement for having performed a professional component service.

Pathologists often report the professional component of clinical laboratory tests because they oversee the clinical laboratory and are responsible for the results. As stated in the College of American Pathologists Professional Relations Manual (pages 151-152 under the section Pathologist Professional Component Billing for Clinical Pathology Services):

Professional component billing is one valid method of billing for the professional services of pathologists in the clinical laboratory. In many communities, the standard practice is for the pathologist to direct bill patients for the professional component of clinical laboratory services. When the pathologist bills a professional component to a non- Medicare patient, no payment is made by the hospital to the pathologist for this service. The hospital's bill for the technical component covers hospital costs for laboratory equipment, supplies and non-physician personnel--it does not include the professional services of the pathologist.

Pathologists in their capacity as medical directors of hospital clinical laboratories provide valuable, necessary medical services for patients. These services and responsibilities, often called clinical pathology professional component services, include:

  • Ensuring that tests, examinations, and procedures are properly performed, recorded and reported
  • Interacting with members of the medical staff regarding issues of laboratory operations, quality, and test availability
  • Designing protocols and establishing parameters for performance of clinical testing
  • Recommending appropriate follow-up diagnostic tests, when appropriate
  • Supervising laboratory technicians and advising technicians regarding aberrant results
  • Selecting, evaluating, and validating test methodologies
  • Directing, performing, and evaluating quality assurance and control procedures
  • Evaluating clinical laboratory data and establishing a process for review of test results prior to issuance of patient reports
  • Ensuring the hospital laboratory’s compliance with state licensure laws, Medicare conditions, Joint Commission on Accreditation of Healthcare Organizations standards, the College of American Pathologists Laboratory Accreditation Program,and federal certification standards

In closing, when reporting the professional or technical component of a procedure or service, it is important to familiarize yourself with the various reporting requirements of individual insurance companies in your area. These reporting and reimbursement policies may vary from one insurance company to another.

The book Medicare RBRVS: The Physicians' Guide can be ordered by contacting the American Medical Association's Customer Service department at (800) 621-8335.

For information regarding the College of American Pathologist (CAP) manual, contact the CAP at (800) 323-4040.

References:
American Medical Association. Medicare RBRVS: The Physicians' Guide 2005. Chicago, Ill: AMA; 2005.

College of American Pathologists. Professional Relations Manual. 12th ed. Northfield, Ill: CAP; 2003: 151-152. 


Tuesday, January 5, 2021

Director of CMS CAG posted; may be simply reclassification paperwork

Director, Coverage and Analysis Group, CMS, is posted as open January 4 to February 4, 2021.  One commenter noted this may be simply a "reclassification" of the same job.  See NYT on the topic, October 2021, here.

https://www.usajobs.gov/GetJob/ViewDetails/587235900







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https://www.usajobs.gov/Help/working-in-government/unique-hiring-paths/senior-executive-service/


There are a couple of different options for you if you’re looking for a senior executive level job in the Federal Government.

  1. The Senior Executive Service (SES)
  2. Senior executive level jobs outside of the SES

Senior Executive Service (SES)

The Senior Executive Service (SES) consists of executive positions, including managerial, supervisory, and policy positions classified above General Schedule (GS) grade 15 or equivalent positions in most Executive Branch agencies of the Federal Government.

To be qualified for an SES job, you must demonstrate exceptional leadership, managerial and people skills and know how to build partnerships and communicate with customers. Senior Executives in the SES share a broad perspective of government grounded in the Constitution, and make sure federal executive management is responsive to the needs, policies, and goals of the Nation.

Eligibility for the Senior Executive Service (SES)

Anyone is eligible to apply to an SES position (as long as you’re a U.S. citizen or national), but to be qualified, you must meet the five Executive Core Qualifications (ECQs).

Executive Core Qualifications

The ECQs help determine if you have the broad executive skills needed to succeed in a variety of SES positions. The ECQs are required for entry to the SES and are used by many departments and agencies in selection, performance management, and leadership development for executive positions. The five ECQs are:

  1. Leading Change
  2. Leading People
  3. Results Driven
  4. Business Acumen
  5. Building Coalitions

Learn more about the executive core qualifications Applying for a job in the Senior Executive Service

There are two ways you can apply for a Senior Executive Service position:

  1. Apply directly to a federal agency for a specific SES position.
  2. Apply for an SES Candidate Development Program (SESCDP).

An SESCDP identifies and prepares aspiring senior executive leaders. If you graduate from this program and your ECQs are certified by an OPM-administered Qualifications Review Board (QRB) then you’re eligible for (but not guaranteed) career appointment to an SES position without further competition.

Senior executive level jobs outside of the SES

Not all senior executive level jobs are in the SES. Agencies in the competitive or excepted service may have executive level jobs, where you may not have to meet the same qualification requirements as in the SES.

How do I know if a job is a Senior Executive job?

In the job announcement look for the This job is open to section. If you see this icon  or this icon , it's a senior executive job.

How do I know if the job is in the SES?

There are two ways to know if a job is in the SES.

  1. The pay scale & grade will begin with an "ES"-which means Executive Service.
  2. The Requirements - Qualifications section will list the Executive Core Qualifications (ECQs) as a requirement.

Documents you may need

  • OPM QUALIFICATIONS REVIEW BOARD CERTIFICATION FOR SES

    The Qualifications Review Board (QRB) reviews and certifies the executive qualifications of each person applying to a Senior Executive position. You must pass the QRB assessment to be considered for a Senior Executive job.

Upload and submit through USAJOBS

You can upload and save documents to your USAJOBS account. Once uploaded, you can submit these forms with your job application as needed. Sign into USAJOBS or learn how to upload documents.