|OANP Answers Questions About CMS Notices to Enroll in Medicare for Prescribing and Referring – HERE’S HOW.
Laura Culberson Farr l Executive Director, OANP
Many of you received a notice like the one above inviting you to enroll in Medicare in order to continue prescribing for your Medicare patients. Several people, including staff at OANP, contacted CMS to figure out how and if this applies to Naturopathic Physicians since Medicare does not recognize NDs as an eligible provider type. Unfortunately, we all received wildly different answers ranging from “you can apply,” to “your patients are out of luck, they need to find another prescriber.”
After 4 calls and several different people, OANP was finally able to get some straight answers.
The Bottom Line:
If you have any Medicare patients for whom you manage prescriptions OR do any kind of referrals to specialists or other Medicare providers, you MUST register with CMS as an “Eligible to Order and Refer” provider.
Step 1: Download and complete Form CMS8550. Under Medical Specialty Information, remember that CMS does not recognize naturopathic doctors in its definitions as a “physician” or a “physician specialty.” In their eyes, NDs are a “Non-Physician Specialty” and in this category you would check the box “Unlisted Non-Physician Practitioner Type (Specify).”
Step 2: Send the application to the following address, depending on your preferred method:
USPS Mailing Instructions
Medicare Part B
Attention Provider Enrollment
PO Box 6702
Fargo, ND 58108-6702
Medicare Part B
Attention Provider Enrollment
900 42nd Street South
Fargo, ND 58103
It should take 60-120 days to process. Effective June 1, 2016, CMS will no longer cover prescriptions or referrals written by a provider unless you are registered in this way with CMS. So to avoid interruptions in care with your Medicare patients, you should submit the application ASAP.
The Deeper Explanation:
In 2014, CMS issued rules that providers needed to either enroll in Medicare or Opt Out officially of Medicare in order for prescriptions or referrals to be covered under Medicare Part D. CMS subsequently became aware that there are many providers, including certain pharmacists and providers like naturopathic physicians (among other provider types) who have state authority to prescribe, but do not meet the CMS definition of “physician” or “eligible professional.”
One year later, CMS recognized that valid prescriptions and referrals written by these non-eligible professionals would be denied because the prescriber is neither enrolled in nor opted-out of Medicare. The rule was modified in May, 2015 accordingly:
“To prevent unintended interruptions in coverage and potential harm to beneficiaries, this IFC requires that pharmacy claims and beneficiary requests for reimbursement for Medicare Part D prescriptions, written by prescribers other than physicians and eligible professionals who are permitted by state or other applicable law to prescribe medications, not be rejected at the POS by the plan if all other requirements are met. These prescribers are defined in this IFC as “other authorized prescribers.”
But Medicare still wants to know who are these “other authorized prescribers” before it will authorize payment for prescriptions or referrals. This is why many of you have received notice from CMS like the image above, inviting you to “enroll” – but really they are inviting you to register in their category of “Eligible to Order and Refer.”
If you do not register (i.e., your paperwork completely processed) by June 1, 2016, prescriptions or referrals written by you for your Medicare patients will not be covered.
The many different confusing answers we have received stem from the email invitation that asks you to “enroll” or “opt out.”
Please be clear: NDs may not enroll in Medicare. And if you cannot enroll, Medicare also cannot recognize you as eligible to opt out.
By completing CMS8550, you are neither enrolling in nor opting out of Medicare, you are simply registering yourself as an “Eligible to Order and Refer” non-physician provider to prevent any potential interruption to your Medicare patients’ access to prescriptions and needed referrals.
|News From the ED
|HAPPY NEW YEAR! Wrap Up From 2015 and Moving Into 2016
Laura Culberson Farr l Executive Director, OANP
Last year marked my 10th year of working with the OANP, and closing out the year spurred a little more introspection than usual. There’s always so much that needs to be done that I sometimes get caught up in all the things that we haven’t yet accomplished. While forward thinking can be good, I had some time over the holidays to really reflect on what we accomplished last year – which serves as a nice backdrop moving forward into 2016.
Last year saw a massively successful legislative session – 5 distinct issues that OANP either passed, helped to defeat, or kept alive so that we could continue working on them. It was the largest number of issues that OANP has tackled at once. This was certainly not our intent going into the session – we are usually very careful about prioritizing our limited resources. But sometimes opportunities arise or threats come out of the blue, and I’m extremely proud that everyone rallied from our lobbyists to our legislative committee and passionate volunteers like Hilary Andrews. The end result was a successful session and more importantly a stronger team!
OANP also made headlines in 2015 by filing the first class action lawsuit challenging insurance carriers’ provider discrimination practices under the Affordable Care Act. The suit will have national ramifications, took over a year of preparations, and will be a focus for OANP for at least the next year or two.
We also celebrated our 20th annual conference with more breakout sessions, more entertainment, a reinvigorated Living Legend Dinner (thank you Dr. Tori Hudson!), and the new addition of a post-dinner dance.
Thank you! To everyone who joined or renewed their membership with the association, and who donated throughout the year. Collectively we raised almost $7,000 for our Legal Action Fund, and $4,000 for our Political Action Committee. While those aren’t huge sums of money, it’s more than we have ever raised in the past and is a great start!
2016 Moving Forward
So what next? The OANP Board is meeting at the end of January to create a 5 year strategic plan for the association. But we know a few things will be on the front burner:
• A new website that will be more user friendly, full of resources and mobile friendly!
• A new CE library where you can find CE for free or for purchase.
• Ongoing work on the class action lawsuit.
• Groundwork for the 2017 legislative session, when we hope to tackle cleaning up the many little statutes that exclude NDs because we are not in the definition of “physician” (i.e., signing on POLST forms, concussion evaluations, etc).
The work may be never ending, but one thing is certain – it continues to keep us moving forward as a profession and all of us at OANP are thrilled to be a part of it!
|NEW SAFE OPIATE PRESCRIBING GUIDELINES
Bridghid McMonagle, ND l OANP Board Director
Portland metro area hospitals and health providers announced in December new community-wide safe opiate prescribing guidelines for treating chronic non-cancer pain. The goal of the new standards is to help reverse the epidemic of prescription drug overdoses in the Portland metro region. Click here to view the guidelines.
Oregon has one of the highest opiate prescribing rates in the United States and this rate cannot be explained by health issues that would cause pain. A new Multnomah County Health Department report finds that drug overdoses claimed more than two lives a week in Multnomah County in 2014. In 2014, half of all fatal overdoses were associated with prescription opiates.
Many NDs treat chronic pain as either a specialist or as a patient’s primary care provider. As a profession, we have an amazing opportunity to shine in controlling chronic pain in a way that minimizes or avoids opiate addiction. But many patients come to naturopathic doctors already on extremely high doses of prescription opiates. It’s imperative that all NDs are familiar with these new guidelines, and take the lead on safely decreasing unsafe doses, and most importantly on helping patients find better ways to live with chronic conditions.
|DO YOU HAVE STAFF? MAKE SURE YOU KNOW ABOUT CHANGES TO OREGON PAID SICK LEAVE LAW
Bridghid McMonagle, ND l OANP Board of Directors
If you are an Oregon employer, make sure you know the changes regarding Oregon Paid Sick Leave Law that are effective January 1, 2016. You may also want to consult with an attorney to have an employee handbook crafted for your clinic. This provides employees with details regarding holiday and sick pay, expectations at the office, and many other vital operations of your clinic. I have heard of attorney's charging typically $1,500-$3,000 for this. They will often come to your clinic and review the handbook with your employess and be able to answer any questions at that time.
The law firm that I have dealt with over the past few years was kind enough to put this article together regarding Oregon Paid Sick Leave. Below are some highlights as well.
Remember, even if a claim is bogus, you still have to pay to defend yourself. Please do as much as you can to protect your practice.
Click for Full Article
|A WARM WELCOME TO NEW GOLD CORPORATE SPONSOR: SPRAGUE ISREAL GILES, INC.
SPONSOR: Sprague Israel Giles (SIG)
Sprague Israel Giles, Inc. is very proud to be an OANP Corporate Partner and to support the Oregon naturopathic community. Since 1958 we have been providing expert insurance services to the medical community, and in response to the unique insurance needs of successful naturopathic physicians and clinics, we worked to develop the first comprehensive malpractice insurance program that covers many of the emerging naturopathic modalities that are not adequately covered elsewhere. Make sure to cover what you actually do in your practice, and please contact us to learn about the advantages of our Natural Insurance Program.
For more information, call us at 800.526.0635 or visit: http://www.siginsures.com/natural_insurance.html
|LABRIX CLINICAL SERVICES: Customer Service, Fast Results, and Training Opportunities
SPONSOR: Labrix Clinical Services
Labrix Clinical Services was founded 12 years ago by Erin Lommen ND and Jay Mead, MD with the goal of raising the bar on the quality and efficiency of salivary hormone testing. Labrix’ efficient business culture is guided by the themes of quality service and good, honest work, which translates to the best laboratory experience for you and your patients. Many practitioners partner with Labrix and take advantage of many benefits included with their testing account, and see a significant increase in efficiency as a result.
Time is of the essence in a busy practice. When you get your Labrix hormone or neurotransmitter test reports back, sometimes you want input from one of the Labrix staff physicians. Well, help is a phone call away, Labrix will usually have a staff physician available immediately and at the most within a couple of hours, no need to schedule an appointment for follow up support. Most test results are ready within 2-5 days (from the time samples are received at the lab.)
Labrix knows how busy you are as a practitioner and how important is to stay on top of the newest research and clinical protocols for your patients. The Labrix Clinical Spotlight Video Series was developed to focus on symptoms, testing solutions and treatment options, all clocking in at under 10 minutes in length. You can find these videos at labrix.com/clinicalspotlightvideos. If you want more in depth training, consider attending a live training or watch any of the free full-length webinars at labrix.com.
For more information on becoming a Labrix provider or to find out more about live training opportunities (most are CE accredited for Oregon NDs) please email email@example.com.
|NATIONAL ACHIEVEMENTS: Updates on Office-Use for Compounded Drugs
Mike Jawer l Director of Government and Public Affairs, AANP
The end of 2015 saw two very significant achievements in the fight to protect the right for physicians to access compounded drugs for in-office use.
First, the International Academy of Compounding Pharmacists and its partners successfully got language included in the committee report that accompanies the FDA’s 2016 appropriations bill. The language does two things:
1. Tells FDA that office-use of compounded drugs continues to be allowed under federal law, and directs the agency to issue within the next 3 months a guidance document spelling out how office-use compounding will work.
2. Instructs FDA, within 3 months, to report on when it will complete its review of compounded drug ingredients.
Secondly – and perhaps most helpfully – FDA has established a ‘safe harbor’ whereby it will allow the use of any compounded drugs or drug ingredients while they are in the agency’s queue for evaluation and so long as they do not present safety concerns. This is for the express purpose of avoiding disruptions to patient care. In its comments on behalf of the profession, AANP obviously endorsed this FDA action as well as other recommendations, such as including in the safe harbor all compounded ingredients that have historically been used safely.
These “victories” do not mean that in-office use of compounded materials has been given the green light again. But it does take us one step further in getting the FDA to back away from the severe interpretation they have taken on compounded drugs. Stay tuned for what we hope will be more good news in the first half of 2016!
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2016 Board Members
Carrie Baldwin-Sayre - President
Wendy Abraham - Vice President
Kaley Bourgeois, Secretary
Rebecca Principe - Treasurer
Jeff Clark - At-Large, Legislative Chair
Sheryl Estlund - At-Large
Aubrey Harding - At-Large
Bridghid McMonagle - At-Large
Martin Milner - At-Large
Wendy Vannoy - At-Large, CE Chair
Clair Hamilton Araujo - Student Rep