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A vendor is a business associate if they create, receive, maintain, or transmit PHI on behalf of the covered entity. They are NOT a business associate just because they happen to be in a building with PHI or could conceivably access it. The functional test matters, not the proximity test.
Forcing BAA execution on vendors who do not meet the functional test creates contractual bloat and weakens the negotiating position with vendors who actually do. Failing to execute BAAs with true business associates exposes the covered entity to OCR enforcement.
Across most payors, the top-five denial reasons account for over 80% of prior-auth rejections: missing clinical documentation, wrong CPT/HCPCS code, service not in benefit plan, step-therapy not completed, and ordering provider not on the patient's plan. The same five repeat across plans because they are the easiest to deny on automation.
Practices that build a five-line pre-submission checklist around these reasons typically cut prior-auth denials by 40-60% within a quarter. The fix is process, not appeals capacity.
The MIPS cost performance category is calculated retrospectively by CMS using attributed Medicare claims; clinicians cannot directly affect what is attributed. The two attribution methods (TPCC and MSPB) capture different beneficiary cohorts. Practices that try to "manage" cost without understanding which patients are attributed to which clinician typically waste effort.
Cost is now 30% of the MIPS final score — the largest single category. Misunderstanding attribution is the leading cause of unfavorable payment adjustments in the next cycle.
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