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BEHIND THE SCENES: REGENCE PROVIDER AMENDMENT
By Susan Rosen and Julie Johnson
April 27, 2020

In December of 2019, WA Regence Blue Shield sent out an “Update to your agreement effective April 1, 2020” to some credentialed healthcare providers. Included with the letter from Regence was an amendment to several addendums that were to “supersede the requirements in any other agreement documents” of the “Regence BlueShield Participating Agreement,” also referred to as the “Washington Professional Services Agreement” by the Washington Office of the Insurance Commissioner (OIC). This letter went out to some credentialed healthcare providers, including massage therapists, but was intended for all healthcare providers on their network. It is unclear as to why only some healthcare providers received this notice.

There were several areas of concern in this amendment and WSMTA decided to consult with an attorney specifically regarding the changes to the addendum regarding “Record-keeping and Audits.” This section stipulated that Regence can audit one time per year with 15 days notice and under certain circumstances, the cost of the audit will be paid by the provider. It also outlined a provider dispute resolution process that created concern.

Every provider contract and any new amendments are required to be filed and approved by the Washington Office of the Insurance Commissioner (OIC) before it can be implemented and enforced. In the process of investigating these changes, our attorney discovered that these amendments were filed on December 26, 2019 and "Disapproved" by the OIC on January 16, 2020 under “RCW 48.44.020(2)(a)&(f), RCW 48.43.730, and WAC 284-170-480(7) for failure to comply with the minimum standards of the code.” We noted in the comments under the Provider Dispute Resolution Process “This filing contains multiple and conflicting dispute resolution procedures which makes the process unclear to the provider...” and “The agreement cannot limit the provider’s right to any type of judicial remedy under WAC 284-170- 440(4)...”

WSMTA assumes Regence could refile some or all of these amendments at some point in the future and we will follow up with our concerns when they do. We invite you to join our organization and help support necessary legal counsel regarding any new amendments to our provider contracts. As individual providers, legal counsel is often cost prohibitive and negotiation with insurance companies can be difficult. By collaborating and pooling our resources under WSMTA, we can increase access to reliable information and effective, appropriate action. 

If you are interested in reading the OIC language regarding the disapproval of this addendum, we have provided the document here. 

January 16, 2020 Disapproval of Washington Professional Services Agreement from WA Regence BlueShield 

Disclaimer:  These statements are our best interpretation of the information provided to WSMTA at the time this account was written. We encourage you to always read your contracts and any new amendments. Contact your provider representative if you have concerns or questions. WSMTA Members are also encouraged to contact WSMTA if they have concerns. WSMTA and its representatives assume no responsibility for errors in this content.

CHANGES TO PRE-AUTHORIZATION REQUIREMENTS FOR UNIFORM MEDICAL PLANS IN 2020

Uniform Medical Plans have some new pre-authorization guidelines that started on March 1, 2020. CPT code 97112, among others, are subject to the new pre-authorization rules. This article summarizes some of these changes with links to the latest Certificates of Coverage for the various plans with UMP. 

UMP Pre-Authorization Requirements & Massage Coverage 2020

HEALTH SAVINGS ACCOUNTS

On October 30, 2019, the Washington State Massage Therapy Association (WSMTA) Clinical Practices Program sponsored an in-person consultation/CE with Lori Taylor, licensed insurance broker, on Health Savings Accounts (HSAs). She included what HSAs are, how our clients can set them up, how to contribute to them and how to utilize them to cover our services. Massage therapy is an “eligible expense" if the patient has a prescription, letter of medical necessity or a doctor's directive on record (in their IRS tax file) to verify “qualified HSA medical expense".

Health Savings Accounts for Individuals and the Self-employed

CONTINUING EDUCATION AUDITS

Every month the Department of Health audits 2% of the license renewals which have continuing education due. A shocking 50% of therapists fail the audit. This is not always due to a lack of education hours, but can also be due to not having hours in the required categories. The Board of Massage has developed a handy tracking form which lists the requirements and space to enter your continued education classes.

Print out the form, write in any classes when you take them, attach your certificate, and you are ready for a successful audit.

There will likely be some changes to CE requirements in the near future. We will let you know when the regulations become effective and supply you with the link to the updated form.

VOLUNTEERS

Our Board and Committee members are all unpaid volunteers working for you. Our little group could use individuals willing to take on jobs big and small. It allows you to connect with other LMT professionals, receive mentorship, find out the latest discoveries in our profession, receive CE hours for certain activities and support other up and coming LMTs. We are looking for volunteers interested in helping with, but not limited to:

  • Making contacts with medical insurance companies, provider networks/provider services including those with open panels, 3rd party payers and other professional healthcare organizations.
  • Research
  • Content development for the website like forms, articles and imagery.
  • Suggestions and organization of educational opportunities
  • Attendance and reporting on professional meetings and conventions

Our Board and Committee members are all unpaid volunteers working for you. If you have a story idea, an educational experience or ideas to share, please contact us. Please specify your interest in the Clinical Practices Group, our coding subcommittee or if you are looking for volunteer opportunities.

info@myWSMTA.org

COVID-19 FORMS

Clinical Practices Program is providing a variety of examples of forms from active WA massage practitioners to use as templates for resumption and provision of in-person healthcare treatment during the COVID-19 public health crisis. These may include:

  • informed consent
  • advisory and acknowledgment of risk
  • protocol descriptions
  • checklist for verification of no COVID symptoms or increased exposure

These are provided as a starting point. They do not reflect any legal requirements or the only way these forms could be created. They should be customized so it reflects your actual practice and process.The purpose of these forms is to:

  1. Set expectations for the use of your services
  2. Advise and explain to patients/clients procedures and protocol during the COVID-19 Pandemic
  3. Facilitate your clients understanding, acknowledgment of new procedures and protocol
  4. Obtain your client’s agreement to comply with all COVID-19 protocols
  5. Acknowledge that in spite of all precautions there remains a risk of transmission
  6. Consent to treat

Whether they are sent in a pre-appointment email, reviewed at time of service or posted on the website, the key is to communicate your practice has changed its delivery of services to optimizing safety and health. Obtaining signatures or initials on the forms will hopefully assure they have read it, but it is not a liability waiver or legally binding agreement. 

The documents below are in MS Word format for easy modification to your practice needs. We hope you find them helpful.

COVID 19 Integrated Form (.docx)

COVID 19 Symptom Check (.docx)

COVID 19 Office Protocol (.docx)

COVID 19 Informed Consent/Office Protocol(.docx)

WHAT CLINICAL PRACTICES DOES FOR YOU

In Washington State, massage therapists are in a unique position, licensed by the state and credentialed by insurance as health care providers.  LMTs are included in insurance provider networks.  The Clinical Practices Program (CPP) mission is to be a communication portal (conduit) to address issues that impact clinical practices at the state level, while bringing best practice information to individual massage therapists and clinics.  We bring our voices, our knowledge, our experience and collaborative approach to Washington State's regulatory, legislative and insurance arenas.  We also prioritize effective communication with our members as well as other professional organizations in the healthcare field, particularly rehabilitation therapy.

Our current and ongoing focus is to provide the most up-to-date and accurate information for Best Clinical Practices and for compliance with our massage laws as well as other regulations that apply to healthcare providers.  We seek and participate in opportunities to work with networks and insurers on behalf of Washington LMTs to address issues including but not limited to credentialing, improving access to provider networks, network adequacy, prior authorization requirements, payers compliance with reimbursement regulations.

The Coding and Documentation Work Group

This group is a subcommittee under the Clinical Practices Program. Our focus is to research, network and share resources on issues of coding, documentation and other key components of clinical practice. Our goal is to share information and provide tools for licensed individual practitioners and clinical group.


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