Ensure Your Physician’s Signatures Pass Muster By Answering 2 Key Questions

EMR signature pitfalls could be a daily challenge with which you often deal. Check your answers against our experts’ advice to verify your group’s signature compliance.

Question 1: Some of our physicians use handwritten signatures on their charts and others prefer electronic signatures. Is either kind acceptable?

Answer 1: According to CMS documents, Medicare requires a legible identifier for services provided or ordered.  The identifier — or signature — can be electronic or handwritten, as long as the provider meets certain criteria. Legible first and last names, a legible first initial with last name, or even an illegible signature over a printed or typed name are acceptable.  You’re also covered if the provider’s signature is illegible but is on a page with other information identifying the signer (letterhead, addressograph, etc.).  Also be sure to include the provider’s credentials.  The credentials themselves can be with the signature or they can be identified elsewhere on the note.

Pre-printed forms might include the physician’s name and credentials at the top, side, or end.  All qualify as acceptable documentation as long as the coder or auditor can identify the provider’s credentials.  You can also use a signature log to back up your physician’s documentation.  The log should contain each provider’s printed or typed name and credentials, along with their signatures and initials. You can reference the signature log in order to verify a note that contains an otherwise unidentifiable signature.  This is an important resource when providers are signing notes that do not include their typed or pre-printed name.

Make sure that you update signature logs at least once a year.  Create separate logs by provider (physicians, CRNAs, AAs, residents, etc.) to help simplify tracking.  Stamped signatures don’t meet the CMS requirements.  Because a signature stamp can be used...

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Multi-Provider Coding: Modifier 62 Can Save You $4k

When you come face-to-face with multi-provider situation, the last thing you would want is to mess up your coding by assigning the wrong modifier(s).

Imagine a 70-year-old female patient presenting with COPD and coronary artery disease, status post myocardial infarction (CAD s/p MI) having a 28 mm of inner diameter thoracic aortic aneurysm. Imaging studies indicate the aneurysm to be descending. The cardiologist, together with a thoracic surgeon, decides to perform an open operative repair with graft replacement of the diseased segment.

The main key in a multi-provider scenario is to treat each physician’s work as a separate activity. However, deciding when to report a case as co-surgery, assistant surgery — or something else — has more to it than meets the eye. Find out what with this expert’s advice.

You know that a modifier is at hand in this case, but more importantly you should be able to tell what role each modifier plays in order for your procedure codes to blend well together. Here are the most common modifiers used in multi-provider situations:

  • Modifier 62 (Two surgeons). Append this to each surgeon’s procedure when the physicians perform distinct, separate portions of the same procedure. Also referred to as co-surgery, modifier 62 applies when the skill of two surgeons (usually of different skills) is required in the management of a specific surgical procedure.
  • Choose between modifier 80 (Assistant surgeon), modifier 81 (Minimum assistant surgeon), and modifier 82 (Assistant surgeon [when qualified resident surgeon not available]) when one surgeon assists the other with multiple portions of the case rather than completing his work independently. What to look for? Make sure your physician indicates in his documentation that he’s working with an assistant surgeon, what the assistant surgeon did, and why he or she was used during the case.
  • Attach modifier AS

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Look Up New Observation Codes When Reporting ‘Middle Days’

2011 brings a new coding option when reporting the middle day of observations that last longer than two days. Check out this expert advice on how CPT additions will affect your FP’s observation care services coding starting on Jan. 1, 2011.

Until this point, coding for the “middle days” of an observation service caused problems. Although not the norm, there are times when a physician admits a patient to observation and she remains in that status for three or more days. CPT 2011 addresses these middle days between admission and discharge by introducing three new E/M codes. The additions parallel the hospital subsequent care series in terms of component requirements and time frames:

  • 99224 – Subsequent observation care, per day, for the evaluation and management of a patient, which requires at least 2 of these 3 key components: Problem focused interval history; Problem focused examination; Medical decision making that is straightforward or of low complexity. Counseling and/or coordination of care with other providers or agencies are provided consistent with the nature of the problem(s) and the patient’s and/or family’s needs. Usually, the patient is stable, recovering, or improving. Physicians typically spend 15 minutes at the bedside and on the patient’s hospital floor or unit.
  • 99225 — … an expanded problem focused interval history; an expanded problem focused examination; Medical decision making of moderate complexity. Counseling and/ or coordination of care with other providers or agencies are provided consistent with the nature of the problem(s) and the patient’s and/or family’s needs. Usually, the patient is responding inadequately to therapy or has developed a minor complication. Physicians typically spend 25 minutes at the bedside and on the patient’s hospital floor or unit.
  • 99226 — … a detailed interval history; a detailed examination; Medical decision making of high complexity. Counseling and/or

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96446 And Dozen Others Join The List of CCI Edits

Effective Jan. 1, 2011, new CPT codes and, inevitably, new Correct Coding Initiative (CCI) physician edits are there for physicians. For version 17.0, “19,822 new edit pairs have been added to the database while 9,778 have been terminated, for a net gain of 10,044 new edit pairs,” according to Frank Cohen, MPA, MBB, of the Frank Cohen Group, in his Dec. 14, 2010, “NCCI Version 17.0 Change Analysis” announcement.

The main edits you want to be sure to watch for are those related to new code 96446 (Chemotherapy administration to the peritoneal cavity via indwelling port or catheter).

The 96446 non-mutually exclusive (NME) edits are largely what you would expect based on other chemotherapy code edits — bundles with E/M, anesthesia, venipuncture and other vascular procedures, for example. You want to be sure to watch which is the column 1 code and which is the column 2 code for these bundles.

CCI places E/M codes 99217-99239 in the column 1 position and 96446 in the column 2 position. On the other hand, CCI places 96446 in the column 1 position and E/M codes 99201-99215 in the column 2 position, as shown below:

Column 1 Column 2
99217-99239 96446
96446 99201-99215

Remember that if you report both codes in an NME edit pair without a modifier, Medicare (and payers who adopt these edits) will deny the column 2 code and pay you only for the column 1 code. The edits in the table above all have a modifier indicator of 1, meaning that you may override the edits with a modifier when appropriate, such as in the case of distinct,...

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Senate Stops Physician Payment Cuts

Physicians could feel a little looser on their spending thanks to a hold on the 2011 Medicare Physician Fee Schedule cut. On Nov. 18, the U.S. Senate unanimously consented to halt the Medicare planned conversion factor cut for a 31-day period. The U.S...

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59400, 99212, 99213: How to Add Complication Visits to the Global Ob Package

Hint: You can report complications before or after delivery.

You can receive increased reimbursement when your ob-gyn provides additional visits outside of the normal global ob package, but you’ll have to make sure you’ve coded high-risk or complicated obstetrical care correctly – and that means perfecting your ICD-9 coding skills.

Insist on Perfect ICD-9s

You have to link the ICD-9 code on the CMS-1500 claim form (boxes 21 and 24E) to an E/M code, for example, to demonstrate the reason for the additional service. You can add this to the claim that includes the global service, or you can submit it as an additional claim.

Example: A 33-year-old patient, gravida 3, para 2 (both normal spontaneous vaginal delivery [NSVD] full term), is seen in the office 19 times due to developing pre-eclampsia. After the delivery, you review the case and find that the patient required six additional visits (beyond the usual 13) for this care. The documentation for three of these visits supports reporting 99212 (Office or other outpatient visit for the evaluation and management of an established patient … Physicians typically spend 10 minutes face-to-face with the patient and/or family), while three of the visits have more extensive documentation that supports reporting 99213 (Office or other outpatient visit for the evaluation and management of an established patient … Physicians typically spend 15 minutes face-to-face with the patient and/or family).

In addition, after delivery, the patient experiences prolonged pain and irritation due to a hemorrhoid. The ob-gyn sees her for a thrombosed hemorrhoid, which he incises in the office two weeks post-delivery. Finally, the ob-gyn rechecks the patient at her six weeks postpartum visit.

Break it down: When coding for this patient, remember the claim form must note both the CPT codes describing the additional services, as well as the diagnoses that...

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CPT 2011: Goodbye 90465-90474, Hello Vaccine Administration Component Coding

You’ll soon capture counseling per disease.

For combination vaccines that may involve counseling on as many as five different diseases, getting paid as though you counseled on one never seemed fair, but CPT 2011 lets you capture that extra counseling work.

Although multiple component vaccines require counseling on each disease, physicians have only been able to capture counseling for vaccine administration once per administration. CPT 2011 solves the problem with new immunization administration with counseling codes that you’ll code per vaccine component. 

CPT 2011 deletes 90465-90468 (Immunization administration younger than 8 years of age … when the physician counsels the patient/family … per day). Codes 90471-90474 (Immunization administration …) remain.

Use 90460 as Vaccine Administration With Counseling Base Code

No more looking at administration route when choosing which immunization administration with counseling code. For vaccine administration, you’ll assign one code for each vaccine’s initial component:

  • 90460 — Immunization administration through 18 years of age via any route of administration, with counseling by physician or other qualified health care professional; first vaccine/toxoid component.

 Definition: A component refers to the antigen in a vaccine that prevents disease caused by one organism.

CPT streamlines your coding of the vaccine counseling codes by giving you one universal base code. The code includes “any route of administration.” You no longer have to choose a different code based on whether the code is intramuscular/subcutaneous or oral/intranasal.

 Step 2:  Report Second Vaccine Component With +90461

Coders can breathe a sigh of relief as the complexities over deciding which 90465-90468 code to use as the base code will soon end. CPT 2011 gives you only one vaccine administration with counseling base code (90460). For each additional vaccine component, you report the same add on code:

  • +90461 — Immunization administration through 18 years of age via any route

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Comply With Medicare Signature Rules or Risk Payments

Question: One of our physicians likes to sign everything with just his initials, or sometimes an illegible scrawl. Do we need some type of documentation to support what an auditor might not be able to read? Answer: Yes, you would be wise to keep a sign...

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Hip Arthroscopy, Observation Receive CPT 2011 Coding Updates

2991x, 9922x medical procedure CPT 2011 codes added.

If you’ve been frustrated about the lack of arthroscopic hip surgery codes that CPT offers, CPT 2011 will change that, with three new codes that debut on Jan. 1.

In fact, CPT will introduce over 200 new codes in 2011 to help keep your coding more specific than ever, spanning several categories, from dermatology to orthopedics to cardiology, and beyond.

In orthopedics, you’ll benefit from the following three hip arthroscopy codes, which will be excellent additions to CPT.

  • 29914 – Arthroscopy, hip, surgical; with femoroplasty (ie, treatment of cam lesion)
  • 29915 – Arthroscopy, hip, surgical; with acetabuloplasty (ie, treatment of pincer lesion)
  • 29916 – Arthroscopy, hip, surgical; with labral repair

Check out New Observation Codes

CPT adds to your E/M coding options with the introduction of three new observation codes, as follows:

  • 99224 – Subsequent observation care, per day, for the evaluation and management of a patient, which requires at least 2 of these 3 key components: Problem focused interval history; Problem focused examination; Medical decision making that is straightforward or of low complexity. Counseling and/or coordination of care with other providers or agencies are provided consistent with the nature of the problem(s) and the patient’s and/or family’s needs. Usually, the patient is stable, recovering, or improving. Physicians typically spend 15 minutes at the bedside and on the patient’s hospital floor or unit.
  • 99225 – Subsequent observation care, per day, for the evaluation and management of a patient, which requires at least 2 of these 3 key components: An expanded problem focused interval history; An expanded problem focused examination; Medical decision making of moderate complexity. Counseling and/or coordination of care with other providers or agencies are provided consistent with the nature of the problem(s) and the patient’s and/or

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History of Present Illness Must Be Taken by MD, NPP

Don’t let nurses do the doctor’s work, or risk downcoded E/Ms upon audit.

The only parts of the E/M visit that an RN can document independently are the Review of Systems (ROS), Past, Family, and Social History (PFSH) and Vital Signs, according to a June 4, 2010 Frequently Asked Questions (FAQ) answer from Palmetto GBA, Part B carrier for Ohio. The physician or mid-level provider must review those three areas and write a statement that the documentation is correct or add to it.

Only the physician or non-physician practitioner who conducts the E/M service can perform the History of Present Illness (HPI),  Palmetto says.

Exception: In some cases, an office or Emergency Department triage nurse can document “pertinent information” regarding the Chief Complaint or HPI, Palmetto says. But you should treat those notes as “preliminary information.” The doctor providing the E/M service must “document that he or she explored the HPI in more detail,” Palmetto explains.

Other payers have expanded on Palmetto’s announcement, letting physicians know that they cannot simply initial the nurse’s documentation. For example, Noridian Medicare publishes a policy that states, “Reviewing information obtained by ancillary staff and writing a declarative sentence does not suffice for the history of present illness (HPI). An example of unacceptable HPI documentation would be ‘I have reviewed the HPI and agree with above.’”

Good news: Thanks to this clarification, your doctor won’t have to repeat the triage nurse’s work. Right now, if the nurse writes “knee pain x 4 days,” at the top of the note, some auditors might insist that your doctor needs to write “knee pain x 4 days” in his/her own handwriting underneath. But that requirement is a thing of the past if your carrier echoes Palmetto’s requirement.

Bad news: Now this carrier has made it...

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Place-of-Service Codes Caused $13 Million in Overpayments

Double check POS 11 shouldn’t be 22 — or 24. Entering your place-of-service (POS) number on your claim form may seem routine, but a recent OIG audit found that practices are not giving POS numbers the care they deserve. Based on a r...

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Diagnosis Coding: Here’s How To Decode Your Physician’s Notes

If the doctor does not circle a diagnosis, it may be up to you to find one.

Don’t let an incomplete superbill damage your chances of submitting an accurate claim. If the doctor in your office fails to indicate the ICD-9 code for the condition that he treated, you should read through his documentation to find which diagnoses you should report.

Open the Notes When You Have to — and Even When You Don’t

Suppose your physician hands you a superbill with the procedures circled and the diagnosis left blank.

You could ask the physician which diagnosis to report, or you could examine the documentation yourself. If your office has a policy that includes “coding by abstraction” by certified/qualified coders, then submitting charges based on what is supported (documented) in the note is appropriate, says Barbara J. Cobuzzi, MBA, CPC, CPCH,CPC-P, CENTC, CHCC, with CRN Healthcare Solutions in Tinton Falls, N.J. The physician should be signing off on these charges as part of your internal policy.

Some practices choose to review the documentation and compare it against any diagnoses recorded on the superbill, even when they aren’t required to. This ensures that the documentation matches the code selection every time.

When in Doubt, Confirm With the Physician

If you are new at coding diagnoses from the physician’s notes, you should doublecheck your code selections with the practitioners before submitting your claims.

“Until a coder feels comfortable with the ICD-9 books and the codes used more often in their office, it’s a good idea to run the choices by a clinician,” says Suzan Berman, CPC, CEMC, CEDC, senior manager of coding and compliance with the Physician Services Division of UPMC in Pittsburgh. “You never want to give a patient a disease or symptom they don’t have  ” or one more...

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CMS Speaks: Weigh Your 2-Payer Consult Coding Options

In MSP cases, non-consult code for both payers may be best.

If you have payers who didn’t play follow-the-leader with Medicare in cutting out consult codes, you have a dilemma on your hands. You have to decide what to do...

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