Sunday, November 09, 2014

I Bet This Goes Badly! Has The Feel Of A Government Department Really Out Of Their Depth.

This popped into the ether from the Department of Human Services on Friday 7 November 2014.
Sent: Friday, November 07, 2014 1:59 PM
Subject: Department of Human Services Advice: MEDICARE ELECTRONIC CLAIMING - Patient Contribution Update [SEC=UNCLASSIFIED]


The Australian Government Department of Human Services (Human Services) anticipates implementing the Patient Contribution Budget Measure from 1 July 2015.  Implementation is subject to the passing of the necessary legislation. With the proposed introduction of Patient Contributions for general practitioner, pathology and diagnostic imaging services, sites will need to check whether the patient has a concessional status and may choose to charge a patient contribution at the point of service as appropriate. These sites will require changes to their practice management software to transmit claims which include a patient contribution. Vendors who provide software to these sites will be required to develop and implement changes to their Medicare Online software and/or Medicare Easyclaim integrated software to provide the new functionality.
Subject to legislative changes, from 1 July 2015 the Medicare benefit will be reduced by $5 for all patients for:
  • General Practitioner (GP) consultations in Category 1, Groups A1, A2, A11, A22 and A23;
  • out-of-hospital Diagnostic Imaging (DI) services in Category 5, Groups I1, I2, I3, I4 and I5; and
  • out-of-hospital Pathology episodes containing services in Category 6, Groups P1, P2, P3, P4, P5, P6, P7, P8 and P10.
A patient contribution of $7 will be introduced and this may be charged by the provider.  A maximum of 10 patient contributions per calendar year across in-scope GP consultations, DI services and Pathology episodes will be payable by concessional patients (including children under 16), where the provider charges a patient contribution. If the provider chooses to set their own fee for an in-scope service, the provider has charged a patient contribution if the charge is at least $7 greater than the Medicare benefit. The annual cap of 10 patient contributions is  called the Service Cap.  After 10 patient contributions have been charged the Medicare benefit for concessional patients (including children under 16) for these services will revert to the full amount. All patient contribution amounts charged will be excluded from the Original Medicare Safety Net (OMSN) and the Extended Medicare Safety Net (EMSN).
Changes to legislation will be required to allow providers to charge the patient a $7 patient contribution where patients assign their Medicare benefit directly to a provider.
A Low Gap Incentive (LGI) will also be introduced and paid to providers that accept a concessional patient’s (including children under 16) assignment of Medicare benefit, and charge a patient contribution of $7 only. Once concessional patients reach their annual Service Cap, the provider will continue to receive the LGI where they continue to accept the assignment of benefit (bulk bill), and do not charge a patient contribution.
The bulk bill incentive will also cease for in-scope services for:
  • GP consultations;
  • out of hospital Pathology services; and
  • out of hospital DI services.
The bulk bill incentive will continue to be paid for other GP and Pathology services which are not within scope.
These changes will affect software which supports Bulk Billing and/or Patient Claiming for GP consultations, out of hospital Pathology and out of hospital Diagnostic Imaging services.
The software design will include a verification service that will support medical practices and health professionals in determining when to charge or not charge a patient contribution, including when the service cap has been reached.
Medicare Electronic Claiming Client Adaptor Support Policy (Medicare Online and ECLIPSE)
(This section should be read in conjunction with the Medicare Electronic Claiming Client Adaptor Support Policy released 14 October 2014)
To ensure successful implementation of the Patient Contributions budget measure, the department will be making new logic packs available which will be compatible with the May 2009 Release client adaptor version and above.
A new client adaptor will also be made available in 2015 which will meet the requirements for Patient Contributions and resolve some known issues identified in existing adaptors.
The following client adaptor versions identified in the Medicare Electronic Claiming Client Adaptor Support Policy as N, N-1 and N-2, will be compatible for Patient Contributions:
Adaptor Release                 Version
(back to 2009 - Omitted)
In scope vendors who DO NOT meet the client adaptor minimum supported requirements
Vendors who do not currently have a Notice of Integration (NOI) for a client adaptor version of May 2009 Release or above, will need to upgrade to a supported client adaptor and implement the new logic packs and receive a new NOI.
Vendors in this group have 2 options which are:
1.        Commence an upgrade now to a currently supported Client Adaptor N-1 (June 2014 preferred) and then implement the new logic packs in 2015. This may help spread the development time required and reduce the 2015 NOI process.
2.        Upgrade to the latest release (June 2015) and implement the new logic packs.
In scope vendors who DO meet the client adaptor minimum supported requirements
Vendors who have an existing NOI for a client adaptor version of May 2009 Release or above, will need as a minimum to implement the logic pack changes required for Patient Contributions and receive a new NOI.
You may still choose to upgrade to the latest client adaptor (June 2015), however due to the compressed timeframes, priority will be given to the development, testing and support of vendors who do not currently meet the minimum supported requirements.
Vendors NOT in scope for Patient Contributions
Vendors not in scope for Patient Contributions and who do not meet the minimum supported requirements in the Client Adaptor Support Policy will be given an extension to 1 December 2015 to upgrade their adaptors to a supported, N or N-1, version.
Schedule and Testing
Human Services is currently developing a strategy to streamline NOI testing arrangements for Patient Contributions. Further testing information will be provided as soon as practically possible.
  •  A new NOI will be required for the logic pack changes..
  • Beta CD release is scheduled for January 2015.
  • NOI testing can start utilising the Beta CD as of January.
  • Final CD release is scheduled for release May 2015.
  • Human Services Patient Contribution release is scheduled for June 2015 for a 1 July implementation.
Further Communication

As the Patient Contribution measure is subject to the passage of legislation, Human Services will be working closely with the Department of Health to ensure regular updates are provided to vendors. Human Services will be holding a number of forums to discuss the implementation of this measure. Teleconferences will be arranged in coming weeks so that vendors have the opportunity to raise questions and clarify information.

Human Services is unable to provide any additional information at this time other than what has been provided in this message. Should you have any questions in relation to the implementation of Patient Contributions, please email Questions will only be accepted by email and individual responses may not be provided. However, your questions are a valuable part of this process and will be used to develop a Q&A that will be distributed to all vendors. We will also endeavour to answer as many questions as possible during the teleconferences.
----- Ends

Note the lack of additional info - bold!
What is going on here is that providers of practice management software are being asked - in the absence of any certainty as to legislation or timing of implementation - to undertake a major development project with little hope of being remunerated for their time and effort. At the very least funding for all to undertake this work needs to appear and quickly.
Worse than that you will note that the e-mail has no sense of just how this will be implemented - most especially the 11th patient visit cancellation of the co-payment. Just how is this to happen in real time, how are refunds to be made and so the questions go on and on.
The whole unlegislated co-payment idea is tricky, with 10 payment cap more tricky and with no funds to develop the software to implement it is a joke. Note that is all meant to be designed, tested, implemented and working in 7 months (with 2 months lost for the silly season!).
If I was involved I would demand either legislation having been passed (and full funding)  or full financial indemnity for all expenses + a considerable uplift for inconvenience before lifting a finger!
Dream on Government. Just plain ridiculous, as is the whole co-payment policy in my view!

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