Here are the facts: Medicare is one of the largest insurance programs in the United States, and every year it helps insure more than 49 million seniors and other beneficiaries. And,…
The OIG has called on CMS to strengthen activities to prevent improper Medicare payments, including enhancements to the Recovery Audit Contractor (RAC) program. For instance, the OIG notes that RACs…
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CMS has updated its comprehensive ICD-10 end-to-end testing checklists, according to an email update. Testing is a critical component of the ICD-10 transition, and is essential to ensure technical compliance…
In an effort to reduce administrative burdens on hospitals and other providers, CMS has reduced the minimum medical record requests from Medicare Recovery Auditors — formerly known as Recovery Audit…
The Centers for Medicare & Medicaid Services (CMS) Transmittal 1058, Change Request (CR) 7767 confirms a zero percent update for payments under the Medicare Physician Fee Schedule (MPFS) through year’s end.
Posted on 07. Jul, 2011 by rpandit in Hot Coding Topics, Provider News Check whether your group might fall into one of four new categories. The push toward e-prescribing is in full swing, with physicians possibly being subjected to a one percent paym...
Question: In the CMS DRG datasheet, what is the difference between the column titled “Geometric Mean LOS” and the one labeled “Arithmetic Mean LOS”? Answer: The geometric mean length of stay or (GMLOS) is the national mean length of stay for ea...
Check whether your group might fall into one of four new categories.
The push toward e-prescribing is in full swing, with physicians possibly being subjected to a one percent payment hit on CMS claims in 2012 if you don’t successfully participate in e-prescribing this year (and larger hits in 2013 and 2014). If your physicians haven’t yet met e-prescribing criteria, take hope: CMS has proposed four additional ways that eligible professionals (EPs) can potentially avoid the adjustment in 2012.
The imminent penalty for physicians who don’t e-prescribe “has created quite a bit of concern about circumstances where doctors will potentially be penalized, not necessarily because of failure to electronically prescribe, but more so because of some complexities with regard to the measurement,” said Michael Rapp, MD, JD, director of the quality measurement and health assessment group at CMS, during a May 26 CMS Open Door Forum.
Previously, physicians could apply for a hardship exemption only if they could prove a lack of access to the internet in their area or limited access to pharmacies that accepted electronic prescribing. Under the new proposal, EPs would be eligible to request a hardship exemption that CMS would determine on a case-by-case basis if they meet one of the following additional four criteria, Rapp said.
1. Registering With Intent to Adopt EHR Technology
Practitioners who intend to start participating in the HER (Electronic Health Record) Incentive Program might still be getting their technology in place, so they may not have e-prescribed ten times within the first six months of 2011, as is required to avoid the penalty. The new proposal aims to offer those practices a potential exemption.
2. Prescribing Meds That Legally Cannot Be Electronically Transmitted
Many state, local, or...
Beware of CPT® and Medicare differences when counting HPI elements.
Not accurately accounting for the history of presentillness (HPI) documented by your oncologist could result in missing appropriate opportunities to report level 4 or 5 E/M visits. Ensure you’re not missing higher paying possibilities by reviewing this guide to capturing HPI elements.
Brush Up on What Qualifies as an HPI Element
HPI is one of the three parts comprising an outpatient E/M history. It describes the patient’s present illness or problem, from the first sign/symptom to the current status, and typically drives a provider’s decisions about the physical examination and treatment. “The information gathered during the physical exam (PE) portion of a patient’s evaluation often only shows a very limited picture of the patient’s problem. However, speaking with a patient and gathering the history of the patient’s problem” can help fill out the picture, explains Amanda S. Stoltman, CCS-P, compliance coder at Urology Associates in Muncie, Ind.
Start counting:
HPI also will often determine the level of service you’ll report. You’ll count the HPI elements to help you determine which level of service you can report. There are seven or eight HPI elements, depending on which source you are following. For Medicare, the eight elements are as follows:
Medicare includes the above list in both the 1995 and 1997 E/M Documentation Guidelines, available at www.cms.gov/MLNEdWebGuide/25_EMDOC.asp.
In contrast: CPT® lists only seven HPI elements in the E/M Services Guidelines, with duration not making the list. Therefore, for Medicare and payers following its guidelines, you should consider duration and timing separately. With payers that follow AMA rules, however, be aware that they don’t consider duration and timing to be two separate elements. Rumor has it...
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...
You’re not only losing revenue—you’re also coding improperly.
CMS data from previous years shows that medical practices undercodè E/M claims to the tune of over $1 billion annually—that’s money that physiciáns could have collected based on their documentation, but forfeited because they reported a lower-level codè than they should have. But remember that your responsibility as someone who submits claims to Medicarè is to codè based on the documentation—anything else is incorrect coding.
If you’re one of the practices that’s downcoding claims, take note of the following reasons that you should codè based on your documentation rather than undercoding.
Could You Be Triggering an Audit?
The number one reason that many practices undercodè is because they don’t want to “trigger an audit.” However, coding all low-level E/M codès is sure to get a payer’s attention, because the claims reviewers will be wondering why you never offer high-level evaluations to your patients.
When claims reviewers review “bell curves” to determine whether a practice is coding outside the norm, they aren’t just looking for upcoding—they are looking at trends across the board. This means that a practice with all 99212s and 99213s will be vulnerable, because nearly every practice sees more complex patients requiring high-level E/Ms at least once in a while. If an auditor reviews your rècords and determines that you’re deliberately downcoding claims, they’ll conclude that you’ve been coding improperly.
Consider Compliance Implications
If you’re deliberately undercoding your claims to stay under the radar, you’re technically violating the False Claims Act because you are knowingly submitting a false claim. “It’s a violation just as much as deliberate upcoding is a violation, but the government most likely isn’t going to pursue it because ultimately it savès the Medicarè program money,” says John B. Reiss, PhD, JD, a health care attorney...
Boost your bottom line by reporting new annual wellness visits correctly. If you want your annual visit claims to be picture perfect in 2011, then follow these five tips to avoid future denials and keep your physician’s claim on the fast track to success.
Background: The Affordable Care Act (ACA) extended preventive coverage to more than 88 million patients covered by health insurance, and Medicare has codified that benefit in the form of an annual wellness visit. Medicare valued the new annual wellness codes based on a level 4, problem-oriented new and established E/M service.
The two new codes are:
G0438 — Annual wellness visit; includes a personalized prevention plan of service (PPPS), first visit
G0439 — Annual wellness visit; includes a personalized prevention plan of service (PPPS), subsequent visit.
Tip 1: Apply G0438 to Second Year of Coverage
Be wary of applying these codes to new Medicare patients coming in to your physician’s practice in 2011. The reason is that Medicare will only reimburse the initial visit (G0438) during the second year the patient is eligible for Medicare Part B. In other words, during the first year of the patient’s coverage, Medicare will only cover the Initial Preventive Physical Exam (IPPE), also known as the Welcome to Medicare exam.
Tip 2: CMS Limits G0438 to One Physician
If your FP sees the patient for the initial visit (G0438) and the patient sees a different physician for the next annual wellness visit, that second physician will only receive reimbursement for the subsequent visit (G0439), despite having never seen the patient before.
Here’s why: CMS has indicated that when a patient returns to the same or new physician in a third year, they might only pay for the subsequent visit, says Melanie Witt, RN, COBGC, MA, an...
Question: My doctors stand by for the cardiologists during a pacemaker placement in case they need to place epicardial leads. They want to report their time, and I have found 99360 for this. Do they need to dictate something in order for me to charge f...
Q: Since April 1, our clearinghouse has been rejecting claims with NTIOL Q1003. We understand that no additional reimbursement was to be received after the expiration date of Feb. 26,…
Even if you don’t have prescribing privileges, you can rest assured now as CMS will not cut your pay as a penalty for failing to comply with the new e-prescribing incentive program.
As you are probably aware, starting in 2012, you may be subject to a one percent payment adjustment on your Part B pay if you don’t successfully participate in e-prescribing this year. In 2013, that payment adjustment will go up to 1.5 percent, and in 2014 it will rise to two percent, CMS’s Daniel Green, MD noted on a Feb. 15 CMS-sponsored call.
“To earn an incentive in 2011, an eligible professional must e-prescribe 25 times during the year, ten of which must be in the first six months,” Green said. “If they are a successful e-prescriber during the calendar year, they not only would avoid the 2012 payment adjustment, they would get a one percent 2011 payment incentive, and they would be exempt from the 2013 payment adjustment,” he explained.
“Earning an incentive in 2011 does not necessarily exempt the eligible professional or group practice from a payment adjustment in 2012,” Green explained.
How to Avoid the Adjustment
CMS reps said that they’ve been flooded with calls about the 2012 payment adjustment, and described ways that you can avoid the adjustment if you qualify.
Not eligible to prescribe: If you are not a physician, nurse practitioner, or physician assistant between Jan. 1 and June 30, 2011, you can avoid the e-prescribing penalty. In addition, if you don’t have prescribing privileges at least once on a claim between Jan. 1 and June 30, 2011, you should append G8644 (Eligible professional does not have prescribing privileges) at least once before June 30 to ensure that your MAC knows you are not subject to the penalty, said CMS’s Michelle...