BE AWARE: CLAIMS FILING IS AFFECTED BY CHANGED FEDERAL REGULATIONS

For a number of years third party payer claim forms have required an NPI number (National Provider Identifier number) on all paper insurance claims.  Now all electronic transactions including claims and eligibility verifications must also have an NPI number on the claim.  The latest changes concern how health care providers use NPIs.

The NPI is a government-issued identification number for a variety of health care providers: Entity Type 1 (Individual NPIs) and Entity Type 2 (Organizational NPIs).  Type 1 indicates solo practitioners; Type 2 is used for “Organizational” providers including clinics, hospitals, dental schools, and group practices.

Under new regulations both Entity Type 1 and Entity Type 2 claims must include an NPI on any claim for prescription drugs for patients who have Medicare Part D prescription drug benefits.  Also a specialist may now request the Type 1 NPI from a referring dentist in order to complete the claim form.

There are other requirements too involved to discuss thoroughly in a brief blog.  For more information, go to www.cms.gov/Regulations-and-Guidance/HIPAA-Administrative-Simplifcation/NationalProviderStand/education.html.  Scroll to the “Downloads” heading and click on “NPI Requirement for Prescribers”.

ATTRACT NEW PATIENTS WITH OVERT ATTENTION TO THEIR CHILDREN

Warm personal attention with an extra measure of care and concern shown for youngsters is a winning way to attract and keep new patients and their children.  When parents see that you and your staff are dedicated to keeping them and their children orally healthy for a lifetime, you’ll have loyal, long-term, trusting patients who enroll in your Recare System and accept recommended treatment. 

The American Dental Association has a selection of three attractive, informative brochures which will help you educate parents about their children’s dental health from infancy through pre-teen years.  Your Child’s Teeth: Helpful Hints for Parents and Care Givers (W 177) includes advice for expectant mothers, teething, nutrition, oral care techniques for children, sealants, injury prevention and so on.  It’s an excellent piece of literature that says, “We care about your child’s oral health.”

Your Child’s Teeth from Birth to Age 6 (W 236) has an updated dentition chart and emphasizes the importance of first dental visits by one year of age plus lots more valuable information for parents.

Your Child’s Teeth from Ages 6 to 12 (W 239) has a wealth of information pertinent to the mixed dentition ages along with excellent photographs teaching step-by-step home care techniques.  Ordering information is available at www.ADAcatalog.org or call 1-800-947-4746.

EMPLOYEE? INDEPENDENT CONTRACTOR? WHICH CATEGORY FITS YOUR SITUATION?

How should workers in your practice by classified?---Employee?---Independent Contractor?---and what difference does it make?  The classification affects the payment of employment taxes, benefits, retirement plan funding, etc.  In summary, the items listed are examples of what must be paid by an Employer for an Employee; whereas,  they are not paid for an Independent Contractor who must, therefore, pay his or her own.  The IRS monitors such payments closely, believing that 20% or more of workers for whom taxes should be paid are misclassified as Independent Contractors, thereby “cheating” the IRS out of taxes owed for Employees.  In case of an audit which, incidentally, are increasing to as many as 6000 random audits this year, the IRS uses 20 criteria to determine the category into which each worker in your office fits.  Bottom line:  most workers, even temporary fill-ins and prospective staff members doing a working interview, are Employees.  The primary criteria for classification as an Employee is the control the Employer has over the employee’s work, such as responsibilities, work hours, patient load, furnishing of equipment and supplies, payment of regular wages and benefits, etc.

An Associate Dentist is one of the few exceptions who can be classified an Independent Contractor IF he or she practices under a corporate structure which he or she owns.  In this case, the practice owner contracts with the Associate’s corporation as an Independent Contractor providing dental services in the owner’s office.  Therefore, appropriate taxes are paid by the Associate/Independent Contractor.

Clinical and business staff are considered Employees unless they are Employees of a staffing agency that contracts with the dentist/owner.  Even hygienists who are paid by the hour and whose work hours vary by the day or week are considered Employees by the IRS.

If the IRS reclassifies an Independent Contractor as an Employee, all back payroll taxes, interest, and penalties will have to be paid by the owner/employer/dentist.  And the misclassified Independent Contractor becomes liable for taxes and penalties for excess contributions to the practice retirement plan made while mistakenly working as an Employee. 

Since the IRS is determined to stop all misclassification of workers so that the agency can collect payroll taxes owed by Employers for Employees, we recommend you and your CPA evaluate each worker in your office and make certain each is classified correctly.  Both the number of IRS random audits and any resulting penalties are increasing significantly.

CDT 2015 CHANGE REQUESTS

I’m mentally chastising myself because in spite of my best intentions, I let time slip by without reminding you in September or October that November 1 is the deadline for submitting change requests you’d like to see made part of the CDT 2015.  Suggestion:  mark your 2014 calendar so that by late next summer you can submit suggestions for changes to the 2016 version.

The American Dental Association is responsible for the annual review and maintenance of the CDT Codes used to report dental treatment provided by dentists and hygienists.  These standard codes allow specificity and uniformity when claims are filed, and the CDT descriptors are the only means of reporting delivered treatment via electronic claims.

CDT 2014 is the current available version, and CDT 2015 is now under review with change requests submitted by dentists, specialty organizations, third party payers, and the ADA.  It is interesting to note that the CDT 2014 includes 29 new procedure codes, 18 revised procedure codes, four deleted codes, and seven modifications to the subcategories and their descriptors.  This proves that suggestions from care providers and their professional organizations do matter and are often implemented.  Your opinion and voice make a difference.

For more information on how to submit a change request, visit www.ada.org/3831.aspx.