SCGhealth Blog

OIG to CMS: We’re Worried About How You Review Extrapolation

Monday, February 26, 2018

By Marla Durben Hirsch

Physicians may soon see some welcome relief when it comes to dealing with denied Medicare claims and overpayment demands involving statistical sampling, also known as extrapolation. The Office of the Inspector General (OIG) announced this month that is has added to its work plan a review of how the government is applying “statistical methods” during the Medicare fee-for-service administrative appeal process. 

Medicare program integrity contractors are authorized to use statistical sampling to determine how much a provider had been overpaid. 

Statistical sampling applies the rate of billing errors found in a sample of claims to a similar total group of claims. Medicare auditors use this methodology regularly.

However, providers often disagree with the calculated result and challenge these statistical estimates by using Medicare’s five step administrative appeals process. According to the OIG’s announcement, if an extrapolation estimate is overturned during this process, the provider is liable for any overpayment upheld in the sample, but not the full extrapolated total. The OIG acknowledges that the difference is “often substantial.” 

The first two levels of appeal, conducted by Medicare Administrative Contractors (MACs) and Qualified Independent Contractors (QICs) “play a critical role in deciding which extrapolations will be upheld.” Evidently the OIG has determined that these contractors may be dropping the ball and has decided to review whether they are “reviewing statistical estimates in an appropriate and consistent manner.” 

In other words, the OIG knows that mistakes can be made when applying extrapolation and wants to make sure that they’re being caught. The errors include:

  • The underlying audit that the sampling is based on is wrong. For instance, the audit used the wrong codes or wrong error rate in determining whether there was any overpayment.
  • The rules of extrapolation weren’t followed. For example, it’s only supposed to be used in certain situations, such as when there is a sustained or high level of payment errors.
  • The sample wasn’t valid. For instance, the sample may have been too small.
  • The government made a math error.

In addition, the government is supposed to give the provider a report of the extrapolation so that the provider can review it but that doesn’t always occur or is provided late, so that the provider must file an appeal before having had a chance to see if the calculations are correct. 

The OIG probably has two objectives here. It not only wants to ensure that the appeals process is working correctly, but also to reduce the logjam of appeals currently choking the appeals process

The OIG has previously reported that providers are more likely to have an adverse determination overturned only after getting to the third level of appeal, the administrative law judge (ALJ) level, which is the first stage independent of the Centers for Medicare and Medicaid Services and the first stage which allows hearings. The OIG found fully favorable results in just 20 percent of cases decided at the QIC level of appeal, compared to a fully favorable result 56 percent of the time at the ALJ level. 

Why this review is important to physicians
This new review is good news for physicians and other providers, and could have a major impact. It may uncover inconsistencies and other issues with the way that MACs and QICs currently handle extrapolation appeals and could ultimately lead to improvements in not only the use of extrapolation but also the appeals process itself. 

It may mean that fewer sampling mistakes will be made so fewer appeals will need to be filed, and if an appeal is filed, a mistake may be caught sooner on appeal.

It may also raise awareness among physicians that they should not take extrapolation calculations at face value but review them carefully and challenge them if necessary.

Gimme 15 Minutes-How are New Medical Codes Made?

Friday, February 23, 2018

Join us on Monday, March 12, 2018 at 12:00 PM for a free webinar event covering how medical codes are made.

Have you ever wondered about the process that goes into making a new CPT code? What about the decision making behind ICD-10 (and soon ICD-11) codes? In this webinar Jen will tell you everything you want to know about the when, what, who and why behind the creation of medical codes.

If you are interested in this free event, you can register here. After registering, you will receive an email about how to access the webinar.

Won’t be available for the event? No worries! All our past webinars are posted to our YouTube channel. Keep an eye on our events schedule so you can keep your calendar free for the next one.

We Fired Amazon's Alexa

Wednesday, February 21, 2018

By Clay Dubberly, Intern 

Amazon’s Alexa is being criticized by the healthcare industry, not because of a design error, but because of its passive listening ability. This function led Jennifer Searfoss, CEO of SCG Health to ban Alexa from its premises.

Alexa is an “intelligent personal assistant” capable of voice interaction, music playback, making to-do lists, setting alarms, streaming podcasts, playing audiobooks, and offering other real-time information.

The way Alexa works is by listening for its wake word (its name) which prepares it to analyze a command. It then listens and responds to everything that it hears afterward. You can ask it questions about the weather, converting measurements, or even for help shopping. It can even be used as an intercom.

In a medical environment, it can be used to help physicians take notes, remotely monitor patients, or allow them to ask health-related questions.

Passive listening and hacking: The Downsides to Alexa

The problem is that Alexa is listening to its surroundings at all times. This means that 24/7, she can be picking up personal information, which is sent back to Amazon or a potential hacker.

“There’s too much risk to be hacked,” Jen Searfoss says. “SCG Health used to have the device in its building,” but “We kicked Alexa out of our office after considering the vulnerabilities of the passive listening technology.”

There isn’t just a “possibility” of being hacked; it’s a reality. There are already several documented instances of Alexa being compromised. One way is through a “Dolphin Attack,” which is when it picks up frequencies which humans are unable to hear.

In this type of attack, hackers increase the frequency of a voice command to over 20,000hz and can play it through another phone’s speaker. While humans can’t hear this, smartphones will pick it up. Another concern for users is that a device that’s been compromised looks no different from one that hasn’t been compromised.

After picking up the frequencies, Alexa can carry out the command without the user’s permission. All that’s needed to do this is a battery, a smartphone, an ultrasonic transducer and an amplifier. All of this is readily sold online for a low price.

After a successful attempt, invaders can open your garage door (granted the right technology is installed) or make calls.

Another way Alexa can be hacked involves pre-installing software onto the device which transforms it into a wiretap that records any sound picked up onto a computer at another location.

Forbes successfully tested this out. One of the disadvantages (to the hacker) is that it takes several hours of installation on the hacker’s part, but this still poses a threat to anyone that buys Alexa from a secondhand source.

In one of those less-concerning instances when hacking is used for something good (or at least something funny), Alexa was hacked into a Big Mouth Billy Bass -- one of those wall-mounted fish that sings songs like “Don’t Worry Be Happy” or “Take Me To The River.”

Alexa isn’t HIPAA compliant. Here is how Amazon plans to fix it.

Another big concern for Amazon’s Alexa (as if being hacked wasn’t big enough) is that it’s not HIPAA compliant. As such, its use in healthcare is extremely limited.

The idea of having a device which could be recording patient data presents a clear threat: “It’s collecting info that has PII,” Ms. Searfoss says.

To help Alexa reach HIPAA compliance guidelines, Amazon recently hired a HIPAA Compliance Agent to help them reach legal requirements, including Business Associate Agreements (BAA), federal and state laws, and standards and regulations. The Compliance Agent is expected to help ensure that “technology and business processes meet [Amazon’s] HIPAA BAA requirements, as well as all applicable federal and state laws, regulations and standards.”

Some healthcare organizations have begun testing the device’s capabilities despite the risk. WebMD allowed Alexa to deliver its web content to users at their own homes for example. The Beth Israel Deaconness Medical Center (BIDMC) ran a successful pilot study in an inpatient setting (without actual patient data). It eventually plans to use it in a clinical setting, but not until Amazon signs a BAA.

The Boston’s Children’s Hospital (BCH) also experimented with using Alexa to give info to its clinical staff, but because it didn’t have a BAA only non-identifiable health information was used. The BCH also created an Alexa skill called KidsMD, which allows users to ask advice for when their kids have a fever.

SCG Health will continue to stand strong and enforce its ban on Alexa -- at least until Amazon approves a business associate agreement.

Winter Liabilities- It’s Not Too Late to Keep Yourselves and Your Customers Safe

Monday, February 19, 2018

By Audrey Landers

On February 2nd, the famed meteorologist Punxsutawney Phil declared that we would be having a long winter. After seeing the snow and freezing rain that has struck our office since then, we certainly believe him. 

With winter weather comes ice and with ice come falls, slips and all kinds of accidents. Our clients tell us stories all the time! Several years ago a delivery man slipped on the ice in front of a two-story medical center and slid under his truck! The poor guy was stuck on the freezing ground for nearly an hour before someone on the second story saw his arm waving from underneath the vehicle. This same story played out again this year, when our own CEO Jen Searfoss heard a woman crying for help as she was walking into a store. The woman had fallen on the icy parking lot and, just like the delivery man, slid under her car.

The idea that a patient could hurt themselves on your property may seem like bad luck. But beyond their injury, there is another issue: liability. 

It is all too common for businesses to focus only on employee liability, completely ignoring the risks seen by customers and delivery people. While many businesses do well with day-to-day liability prevention, for some reason that all tends to go out the window when winter hits. This is even more true for lesser-prepared businesses located in the south. 

You can help decrease your liability in these dangerous conditions by making sure you keep your property safe, and by clearly marking anything that may be a danger. As the winter season continues and snow continues to melt and refreeze, here are a few things you can do to make sure you have done your due diligence in maintaining the safety of your property:

  • Spread salt in the parking lot
  • Keep walkways shoveled and clear of snow
  • Place cones around the most dangerous areas of icy parking lots to redirect traffic
  • Place “drive slow” and “slippery” signs outside
  • Place “wet floor” signs inside
  • Place mats or carpet tiles at the entrance to allow patients, customers and employees to dry their shoes
  • Remain aware of the conditions so you can take additional action as necessary

While some of these may seem like a lot of work, it’s less work than fighting a lawsuit from a patient, third party or staff. It is better to overprepare than to be caught unprepared.

Gimme 15 Minutes- February Events

Friday, February 16, 2018

We are wrapping up the month with three great events.

On Monday, February 19 we are pulling double duty once again to bring you two webcasts in one day!

From 12:00 PM to 12:15 PM Jen will be going over highlights from the massive Bipartisan Budget Act. 

From 12:30 PM to 12:45 PM Jen will be explaining the new process allowing those participating in MIPS as individuals to view their 2017 quality performance scores.

Our final Event for February will be held on Monday February 26.

Tune in from 12:00 PM to 12:15 PM to learn more about business associates and why they matter.

Not interested in any of these events? We would love to hear what questions you want answered.

Won’t be available for the event? No worries! All our past webinars are posted to our YouTube channel. Keep an eye on our events schedule so you can keep your calendar free for the next one.

Maryland Healthcare Providers: Prescription Drug Monitoring Program required for those who prescribe and dispense controlled substances

Thursday, February 15, 2018

By Audrey Landers

Effective today, Thursday, February 15, 2018 all Maryland healthcare providers that prescribe or dispense controlled dangerous substances (CDS) will be required to register as part of the Prescription Drug Monitoring Program (PDMP) in order to obtain or renew their CDS registration.

If you have already registered with the PDMP then you will have no issues with obtaining or renewing your CDS as PDMP registration never expires, even if you don’t use it.

If you are not registered with the PDMP and try to obtain or renew your CDS license then your application and payment will be returned to you with a notification that PDMP registration is required.

If you are not registered with the PDMP, you can register for free on their homepage.

If you aren’t sure whether you are registered with the PDMP or not, you can check by attempting to register. If you fill out the form and you have already registered then the system will state that you have been registered and send you a confirmation code to enter.

About the Prescription Drug Monitoring Program
A PDMP is a state-run electronic database that is used to track controlled substances. Maryland’s PDMP monitors Schedule II-V drugs. Healthcare practitioners can use the database to electronically report the prescription and distribution of controlled substances. This information can then be accessed by physicians, nurse practitioners, and others in order to care for their patients. Healthcare professionals may only access information regarding their own patients. The PDMP also supports research and education related to prescription drug abuse and the opioid epidemic.

KNOW QPP Enrollment Deadline Extended!

Wednesday, February 14, 2018

By Audrey Landers

Enrollment for 2017 KNOW QPP was originally going to end today, but we realized that some of you were heartbroken at the thought of missing the deadline! Worry not, we’re officially extending our enrollment until March 1, 2018 at 7:00 PM EST.

You’ve got more than enough time to let us help you avoid a penalty, or maybe even get a bonus!

2017 Subscription Options

 90 Days of Data


 90+ Days of Data
       2018 Reporting Prep      


If you have any questions, don’t be afraid to ask Gina or give us a call at 888-886-8054

To make sure we are there whenever you need us, we will be keeping extended hours until the end of MIPS reporting season on March 31. You'll be able to get ahold of us from 7 AM to 7 PM Monday through Saturday.

Do You Have What It Takes to be an Olympic Physician?

Monday, February 12, 2018

By Audrey Landers

The 2018 Winter Olympics officially began on February 8. As the weeks progress millions around the world will watch athletes who have trained their entire lives for this golden opportunity to compete in the largest sporting event in the world. 244 American athletes are competing in PyeongChang, South Korea this year with a team of Olympic physicians at their beck and call.

Just like the athletes, physicians train for years for the opportunity to go to the Olympics. On top of the years of school and residency, physicians will also have to endure a grueling selection and training process, all at their own expense. The first step in the process is to contact the national organization representing the sport whose Olympic team you would like to travel with. If you get selected it’s time to start getting your paperwork together: an aspiring Olympic physician will have to submit the expected cover letter, CV, resume and references with their application, as well as copies of their state license, Board of Certification certificate, all additional certifications, malpractice insurance (You must be insured for at least $1 million), and a current CPR/AED certificate. Oh, and don’t forget the non-refundable $90 application fee. By the way, if you have any felonies, disciplinary actions or sanction, don’t even bother applying, you must have a squeaky clean record.

Applicants will then have the opportunity to travel, at their own expense, to a training facility where they will spend 2 weeks being evaluated. It’s important that a physician is able to work well under pressure, be quick thinking and communicate effectively with coaches, athletes and other staff. If they pass this evaluation period then they may be invited to volunteer at domestic and international competitions leading up to the Olympics, where they will continue to work under intense scrutiny.

If a physician finally makes it to the Olympics, they may stay with their sports team but it’s likely they will also work with other groups as well. The Olympics are chaotic, in the 2014 there was an estimated 14 injuries per 100 athletes, with nearly 40% preventing further training or competition. Between 16 hour days and being on call 24/7, Olympic physicians are under just as much pressure as the athletes they treat. 

At the end of the day, its worth it. Aside from the fame and increase in patients some Olympic physicians may see, most are happy just to have the once-in-a-lifetime opportunity to participate in the global event. Dr. Marcia Whalen, who was the head team physician for USA Water Polo from 2008 to 2012, spoke about the surrealism of being able to watch from the sidelines as her team won the gold medal in 2012 “I’m looking at a poster in my office of the athletes standing poolside with the American flag and the gold medals in their hand… I have the same picture on my phone because I was right there watching them at the time.”

10 Tips For Getting Hired In The Healthcare Industry

Wednesday, February 07, 2018

By Clay Dubberly, Intern

If you’re looking for a job that pays well, work in healthcare. The healthcare industry is expected to grow 18% by 2026, which outpaces the rate of any other field.

Here’s a list of 10 tips to keep in mind before your interview with a health employer:

1. Be confident.
Do you believe in your capabilities to learn new skills, perform at a certain level, attain a goal, or achieve your own definition of success? Jim Taylor of psychology today defines this as confidence, and emphasizing that confidence precedes success. Be ready to discuss your goals, past successes, and even your past failures. Make sure you look your interviewer in the eye as well. 

2. Be passionate.
Your potential employer can tell if you have a passion for patients/customer service rather than the desire for money. The former is preferred. Remember, people come before profit. Highlight your social/communication skills. You can do this as simply as asking, “How are you?” Or saying “Thank you for your time.” If you express that you’re kind, polite, and passionate, you’re more likely to land the job.

3. Be organized.
Are you organized? When you get told something important in the interview, have a pen and paper ready to take notes, as well as a printed copy of your resume, regardless of whether or not your interviewer has already seen it. 

4. Have questions ready to ask.
You’ll come off as prepared and intelligent if you have questions ready to ask when you’re prompted for them. You can ask about what tasks you’d be given, when your expected start date would be, or something about the company that you were unable to find online. 

Note: It’s inappropriate to ask about benefits during your interview. Asking basic pay/salary information is acceptable, however. 

5. Have a good answer to, “Why did you apply to work for us?”
Jennifer Searfoss, the CEO of SCG Health said that once someone replied to this question with, “Honestly, I don’t remember applying.” Do you think they got the job? 

Be ready to discuss your values, how they align with the organization, and what skills you can bring to the table as well as what you can take away.

7. Be flexible.
Flexibility doesn’t mean accepting a double eight-hour shift when another RN calls out, but rather being able to adapt to different situations, accept and adapt to changes in the healthcare world, or even a revamping of your own responsibilities. Flexibility can also encompass cross-training, or learning different skills for other roles so that way you can cover for someone who’s sick, thereby making yourself more valuable to the company.

8. Have a personalized cover letter/resume that highlights what matters.
Make sure you highlight what’s relevant when you send your resume out. For example, if you’re applying work at the front desk (which is something you’ve done before) but your resume has your experience as a daycare owner at the top but your prior work as a front desk receptionist at the bottom, you should switch the two. 

If you’re sending a cover letter in, make sure you clarify why you want to work for the company, why you think you’d be a good fit (as we discussed in point five), and make sure your spelling and grammar is error-free. 

9. Do your research.
Conduct an in-depth review of the company. Figure out its chain-of-command, values, mission statement, vision, services/products offered, website, and social media. The more you know, the better your answer to “Why do you want to work for us?” will be. 

You’ll also be making sure that it’s actually an organization you’d want to work for.

10. Prepare to be researched.
What does this mean? It means that your name will more than likely be searched online.
If you have a Facebook picture of you clearly intoxicated stumbling alongside a keg while holding a beer on your Facebook photos, you might want to consider taking that down.
If you have anything else on any of your social media profiles -- Instagram, LinkedIn, Twitter -- that you wouldn’t want your parents or grandparents to see, your potential employer probably shouldn’t see it either.

While the healthcare industry is booming and admittedly is different from other fields, an interview at a medical facility is just like an interview anywhere else. These 10 tips will help you anywhere you go, whether you’re applying as a medical assistant or a receptionist. Good luck!

P.S. Did you know SCG Health is hiring?

MIPS Measure #236- Controlling High Blood Pressure

Monday, February 05, 2018

By Audrey Landers

High blood pressure contributes to nearly 1,000 deaths in America every day. This major health risk contributes heavily to heart attacks, strokes, heart failure and kidney disease. High blood pressure has almost no noticeable symptoms, which is why it is important for patients to get screened often. 

But what about once they are screened and first learn they have high blood pressure? The number one priority is to control it. Less than half of people with high blood pressure have it under control, but if they can manage it then their risk of stroke, heart disease, and even death can go down significantly.

When helping a patient control their blood pressure, you also have the opportunity to report the Merit-Based Incentive Payment System (MIPS) measure #236: Controlling High Blood Pressure.

MIPS measure #236 is a high-priority outcomes measure, meaning you can get bonus points for reporting it. The measure is defined as the percentage of patients between the ages of 18-85 whose high blood pressure was controlled during the measurement period. It should be reported at least once during the 12 month performance period for patients with high blood pressure.

It is important to note that only blood pressure reading taken by a clinician in your office will be accepted. You may not use patient reported readings, readings taken for diagnostic testing purposes, or readings taken the same day as a major surgical procedure. If you do not record a blood pressure reading then it will be assumed that the patient’s blood pressure is not under control.

This measure has a very high benchmark, requiring a minimum of 91.07% to get ten points when reporting through a QCDR.

Quality Data Code  Performance  Service Provided 
Performance Met 

Most recent systolic blood pressure
<140 mmHG 



    Performance Not Met    

Performance Met

Most recent systolic blood pressure
≥140 mmHg


Most recent diastolic blood pressure
<90 mmHg 

G8755 Performance Not Met 

Most recent diastolic blood pressure 
≥90 mmHg 

G8756 Performance Not Met

   No documentation of blood pressure measurement    
no reason given 

For more information, you can view the entire measure here. This measure can also be reported through electronic clinical quality measures (eCQM) using CMS measure CMS165v5.

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