E/M / modifier GY / Oig / Provider News

E/M Coding Makes OIG 2011 Work Plan

Make sure your postop office visit documentation measures up.

The OIG has once again set its sights on several new targets to go with the upcoming new year, and this time the feds will be double- and triple-checking your E/M documentation.

On Oct. 1, the OIG published its 2011 Work Plan, which outlines the areas that the Office of Audit Services, Office of Evaluations and Inspections, Office of Investigations, Office of Counsel to the Inspector General, Office of Management  and Policy, and Immediate Office of the Inspector General will address during the 2011 fiscal year. When the OIG targets an issue in its Work Plan, you can expect the agency to carefully review and audit sample claims of those services.

The Work Plan “describes the specific audits and evaluations that we have underway or plan to initiate in the year ahead considering our discretionary and statutorily mandated resources,” the document indicates.

On the agenda for next year, the OIG has indicated that its investigators will “review the extent of potentially inappropriate payments for E/M services and the consistency of E/M medical review determinations.” The OIG also plans to hone in on whether payments for E/M services performed during the global periods of other procedures were appropriate.

In addition, the OIG will scrutinize Medicare payments for Part B imaging services, outpatient physical therapy services, sleep testing, diagnostic tests, and claims with modifier GY on them (Item or service statutorily excluded, does not meet the definition of any Medicare benefit or, for non-Medicare insurers, it is not a contract benefit).

The OIG also intends to “review Medicare payments for observation services provided during outpatient visits in hospitals” to assess whether hospitals’ use of observation services affects Medicare beneficiaries’ care.

Keep your compliance plan up to date with tips from Part B Insider,...

Comments Off on E/M Coding Makes OIG 2011 Work Plan
October 21, 2010
Coding Challenge

A4556 Urodynamics Supply Advice Needs to Be in Writing

 Question: We have always reported A4556 for the electrodes our urologist uses during urodynamics procedures. This year, however, DMERC has refused reimbursement, stating we should instead be using code A4595 or A4557. Those two “replacement” code...

Comments Off on A4556 Urodynamics Supply Advice Needs to Be in Writing
September 20, 2010
Hot Coding Topics

73090 Bundles Will Cost You $26 Unless You Correctly Apply Global Package

Depending on how many x-rays you write off, you could be losing thousands.

Myth: X-rays that you shoot or interpret during the global period are not billable to Medicare because payers include these charges in the surgical package.

Reality: Bill Those Follow-Up X-Rays

The challenge: You should report fracture care (25600, Closed treatment of distal radial fracture [e.g., Colles or Smith type] or epiphyseal separation, includes closed treatment of fracture of ulnar styloid, when performed; without manipulation) and any x-rays performed for the initial visit. But can you report the follow-up x-rays? The solution:

X-rays determine the patient’s condition and the course of care, so they are not included in global packages. You can also report any follow-up x-rays separately. If you don’t separately report the x-rays, you risk losing significant reimbursement.

Because Medicare payers will reimburse about $26 each time you report 73090, failing to report the x-rays could be an expensive mistake over the course of a year.

When a fracture care code is selected, this only includes the initial casting and all follow-up visits within the 90 day global period. All x-rays, subsequent castings and supplies are not included in the fracture care code. These services and supplies are not considered as edits or mutually exclusive codes by NCCI.

Billing x-rays outside of the global period doesn’t apply only to fracture care claims. In fact, diagnostic services are not considered part of the global package in general, and may be billed separately.

“Per the American Academy of Orthopaedic Surgery’s Global service data guidelines and CCI, the only x-rays that are included in a procedure are those that are intra-operative, such as checking the placement if a manipulation was performed before the cast was placed,” Williams advises. “X-rays that are taken pre- and post-reduction , i.e. before...

Comments Off on 73090 Bundles Will Cost You $26 Unless You Correctly Apply Global Package
September 16, 2010
Audit / E/M / Provider News

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...

Comments Off on History of Present Illness Must Be Taken by MD, NPP
September 16, 2010
Hot Coding Topics / Oig

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...

Comments Off on Place-of-Service Codes Caused $13 Million in Overpayments
August 31, 2010
CMS / Provider News

CPT 99406, 99407 Coverage Extended to All Smokers

CMS announcement is triumph for physicians who haven’t collected in the past. If you’ve been writing off tobacco cessation counseling as non-payable, it’s time to change your tune. In the past, CMS only covered 99406-99407 (Smoking and tobacco us...

Comments Off on CPT 99406, 99407 Coverage Extended to All Smokers
August 31, 2010
Coding Challenge

Medicare Repeat Pap Smears: Find Out If 99000 Is OK

Hint: Abnormal versus insufficient cells mean different diagnosis codes.

When a patient returns to your office for a repeat Pap smear, you’ve got to weigh your options of E/M and specimen handling codes, as well as diagnosis codes. Take this challenge to see how you fare and prevent payment from slipping through your fingers.

Question 1: When a patient comes in for a second Pap smear, what CPT code(s) should you apply and why?
 
Question 2: Will you receive reimbursement for handling the repeat Pap smear? Why or why not?

Question 3: If the patient comes back in for a Pap smear due to abnormal results, what ICD-9 code(s) should you use and why?

Question 4: If the patient has a repeat Pap because the lab did not have enough cells in the specimen to interpret the results, what ICD-9 code(s) should you use and why?

Answer 1: Here’s What CPT Codes
 
When the patient comes in for a second Pap smear, submit the appropriate E/M office visit code (99211-99215). You will probably be able to report 99212 (Office or other outpatient visit for the evaluation and management of an established patient …) for this visit becausethe patient likely will come in only for the Pap smear and CPT does not include a specific code for taking the Pap. Code 99212 carries 1.08 relative value units (RVUs), unadjusted for geography. That translates to about $31 for this visit (using the new conversion factor of 28.3868).
Answer 2: Handling the Specimen Depends on Payer


Some private payers will reimburse for handling the repeat Pap smear specimen (99000, Handling and/or conveyance of specimen for transfer from the physician’s office to a laboratory). But Medicare carriers consider the collection and handling part of a problem E/M...

Comments Off on Medicare Repeat Pap Smears: Find Out If 99000 Is OK
August 12, 2010
CMS / Hot Coding Topics / ICD-10

Watch for Denials If You Take Shortcuts on Form 5010

Say goodbye to form 4010A1 for ICD codes as well, starting in 2012.

Dig into your claim forms now to ensure that the beneficiary’s information is accurate to the letter, or you’ll face scores of denied claims on the new HIPAA 5010 forms.

Why it matters: CMS will deny claims on which the beneficiary’s name doesn’t perfectly match how it’s listed on his Medicare I.D. card when you begin using HIPAA 5010 form — the new Medicare universal claim form starting in 2012.

Include Jr. or Sr. Suffixes

“Whenever there is a name suffix, such as ‘Jr.’ or ‘Sr.’ abbreviations, etc., it must be included with the last name,” said Veronica Harshman of CMS’s Division of Medicare Billing Procedures during an April 28 Open Door Forum regarding the eligibility component of the HIPAA 5010 form.

You can include the suffix either with the patient’s last name or in the suffix field, specified CMS’s Chris Stahlecker during the call.

“The date of birth must also match exactly to what the Social Security Administration has on file,” Harshman said. CMS will use several new error codes on claims once the 5010 form goes into effect. “If you communicate with CMS through a third-party vendor (clearinghouse), it is strongly recommended that you discuss with them how these errors will be communicated to you and how these changes will impact you and your business,” Harshman advised.

Look for Production Systems Next Year

According to the HIPAA 5010 Final Rule, CMS will have a production 5010 system available as of Jan. 1, 2011, Harshman said.

The last day CMS will accept a 4010A1 form will be Dec. 31, 2011. As of Jan. 1, 2012, if you aren’t using the 5010 form, you’ll “lose the ability to receive eligibility data from Medicare,” Harshman said. In...

Comments Off on Watch for Denials If You Take Shortcuts on Form 5010
August 12, 2010
Provider News

CMS Clarifies How to Report Audiology Services

Look for a physician order for diagnostic audiology tests. If you thought CMS’s May transmittal on coding for audiology services was the last word on the subject, think again. On July 23, the agency rescinded the May directive and issued new guidance...

Comments Off on CMS Clarifies How to Report Audiology Services
August 12, 2010
Coding Challenge

Medical Coders: Accepting a PFFS Plan is Your Choice

auditorHere are the pros and cons to help guide your decision.

Question: Our practice is considering accepting patients with PFFS plans. We’re heard that some patients are starting to have them, but we’re not sure whether we’re going to accept them or not. Are PFFS plans beneficial for us?

Answer: PFFS are Private Fee-for-Service plans, which are non-network plans. These plans let members receive care from any doctor or hospital that accepts the plan’s payment terms and conditions.

If your practice decides to accept these terms, you would become a “deemed” provider. Plan members can receive covered services from any deemed provider in the U.S. However, member patients must confirm that the provider is deemed every time a service is provided.

PFFS plans are different from Medicare Advantage plans because they do not require a doctor or hospital to contract with a health plan to provide services. This means that doctors or hospitals that do not agree to the PFFS plans’ terms and conditions may choose not to provide health care services to a plan member, except in emergencies.

Coming soon: Starting in 2011, PFFS plans will have to measure and report on their providers’ quality of care. But the catch is that they’ll also have to form provider networks with contracts.

In counties where there are two or more non-PFFS plans, PFFS plans will no longer be able to simply “deem” providers into the plan without a contract. Under current law, PFFS plans don’t have to prove they can meet access standards if they allow any willing qualified Medicare provider to participate, and they pay as traditional Medicare would pay.

One argument is that the network requirement would provide better access to care because there would be contracts between the providers of services and the plan. On the...

Comments Off on Medical Coders: Accepting a PFFS Plan is Your Choice
June 18, 2010
Provider News

Part B Payment: Expect Claims To Be Released Today

MACs won’t process June claims until today, in hopes that Congress will act.

The Senate’s delays could mean serious payment crunches for your practice.

Last month, the freeze that has been keeping the Medicare conversion factor at 2009 levels expired, meaning that Part B practices were due to face a 21-percent cut effective for dates of service June 1 and thereafter. Because Congress had not yet intervened to stop those cuts, CMS initially instructed MACs to hold claims for the first 10 business days of June while lawmakers could deliberate whether to eliminate the looming cuts.

When the Senate reconvened on June 7, many analysts expected its members to vote on H.R. 4213, “The American Jobs and Closing Tax Loopholes Act of 2010,” which was expected to increase your payments through the end of this year, according to the text listed on the House Ways and Means Committee Web site. However, the bill has not passed, leading CMS to extend the MACs’ claims hold through June 17.

According to a June 14 CMS notification, the agency directed its contractors “to continue holding June 1 and later claims through Thursday, June 17, lifting the hold on Friday, June 18.”

CMS acknowledged in its June 14 notification that the lengthened claims hold period “may present cash flow problems for some Medicare providers. However, we expect that the delay, if any, beyond the normal processing period will be only a few days.”

The impact of the 17-day claims hold will vary, depending on the practice and how many Medicare patients it sees, says Quinten A. Buechner, MS, MDiv, CPC, ACSFP/GI/PEDS, PCS, CCP, CMSCS, president of ProActive Consultants in Cumberland, Wis.

Those practices with large Medicare populations could face a cash flow crisis, says Barbara J. Cobuzzi, MBA, CPC, CENTC, CPC-H, CPC-P, CPC-I,...

Comments Off on Part B Payment: Expect Claims To Be Released Today
June 18, 2010
Coding Challenge

Medical Coding: Ease Counseling Codes Acceptance With Distinct Dxs

Study frequency guidelines before you bill for counseling services.

Question: A 60-year-old established Medicare patient with a confirmed diagnosis of vanishing lung (emphysema) reports to the family physician (FP) for a medication check and blood work; the patient is a moderate smoker. During the medication check and blood work, which took about 5 minutes, the patient tells the practice’s non-physician practitioner (NPP) “I think I’m ready to quit smoking; can you help?” The NPP spends the next 7 minutes providing smoking cessation counseling for the patient. Can I report a cessation code and an E/M?

Answer: Provided the patient meets Medicare’s requirements for cessation counseling, you can report the following:

  • 99211 (Office or other outpatient visit for the evaluation and management of an established patient, that may not require the presence of a physician. Usually, the presenting problem[s] are minimal. Typically, 5 minutes or less are spent performing or supervising these services.) for the E/M
  • 492.0 (Emphysema; emphysematous bleb) appended to
  • 99211 to represent the patient’s emphysema
  • 99406 (Smoking and tobacco use cessation counseling visit; intermediate, greater than 3 minutes up to 10 minutes) for the smoking cessation counseling
  • 305.1 (Tobacco use disorder) appended to 99406 to represent the patient’s tobacco dependency.

Know the rules: According to Medicare, its patients are entitled to smoking and tobacco use cessation counseling provided the patient is either:

  • a tobacco user who has an illness caused or complicated by tobacco use or
  • taking a therapeutic agent whose metabolism or dosing is affected by tobacco use as based on Food and Drug Administration-approved information.

Additionally, note these two frequency guidelines for spot-on 99406 and 99407 (… intensive, greater than 10 minutes) claims:

  • Medicare will

...

Comments Off on Medical Coding: Ease Counseling Codes Acceptance With Distinct Dxs
June 13, 2010
Medicare / Toolkit

Chiropractic Coding: Avoid This Common Documentation Mistake

Treatment plans are a must, experts say.

You’ve treated your chiropractic patient, you’ve selected the correct codes, and you’ve submitted your claim. All set, right? Not quite. Check out this common mistake that chiropractors make.

“Many chiropractors do not create written chiropractic treatment plans for every new patient,” says Marty Kotlar, DC, CHCC, CBCS, president of Target Coding, a chiropractic coding and billing consulting firm. Use this checklist to ensure you send Medicare the information CMS most wants to see included “with every new patient plan of care,” Kotlar says:

__ The history
__ Present illness
__ Family history
__ The past health history
__ The physical examination
__ The diagnosis
__ The plan — This should include:

  • Therapeutic modalities to effect cure or relief (patient education and exercise training)
  • The level of care that is recommended (the duration and frequency of visits)
  • Specific goals that are to be achieved with treatment
  • The objective measures that will be used to evaluate the effectiveness of treatment
  • Date of initial treatment.

__ Signature/initials to authenticate the records.

@ Part B Insider (Editor: Torrey Kim, CPC).

Sign up for the upcoming live audio conference, Risk Management Strategies for Healthcare Providers, or order the CD/transcripts.

Be a hero. Sign up for Supercoder.com, and join the coding community at the Supercoder.com Facebook Fan Page.

Comments Off on Chiropractic Coding: Avoid This Common Documentation Mistake
June 8, 2010
Provider News

Medicare: 21% Cut Continues to Loom, With May 31 Deadline Nearing

CMS instructs MACs to hold claims for ten business days while Congress mulls bill.

Impending cuts to your Medicare pay have been a familiar story this year, but hopefully you won’t face a 21-percent payment drop while you’re trying to enjoy your summer.

Last month, Congress voted to extend freezing the conversion factor at 2009 levels so Part B practices wouldn’t have to face a 21 percent cut to the conversion factor, which was supposed to go into effect on April 1. Once the president signed the extension into law, it meant that practices didn’t have to worry about the Medicare cuts until June 1, in hopes that the government would find a more permanent solution to the pay cut crisis before the conversion factor freeze expires on May 31.

New Bill Could Put Off Cuts

The House Ways and Means Committee published the text of H.R. 4213, “The American Jobs and Closing Tax Loopholes Act of 2010,” on its website on May 20. The bill would increase your payments through the end of this year, according to the text listed on the Committee’s Web site, which states, “In lieu of the update to the single conversion factor … that would otherwise apply for 2010 for the period beginning on June 1, 2010, and ending on December 31, 2010, the update to the single conversion factor shall be 1.3 percent.” The bill also includes provisions that would ensure that additional cuts don’t take place through 2013.

The American College of Physicians posted support for the bill on its website, but the AMA expressed disappointment. “An intervention to delay a looming Medicare physician payment cut will provide temporary stability for seniors and their physicians, but the AMA is deeply disappointed that Congress will once again fail to permanently correct the...

Comments Off on Medicare: 21% Cut Continues to Loom, With May 31 Deadline Nearing
June 3, 2010
Cardiology / CMS / MAC / Provider News

MACs Differ on Response to CMS’s Cardiology Payment Adjustments

Don’t look for a raise just yet, in most cases.

CMS may talk, but MACs don’t always listen — at least not quickly.

As we told you in last week’s Insider, CMS recently corrected several “technical errors” published in the 2010 Fee Schedule, and thanks to these corrections, Medicare will increase payment for several cardiology-related testing codes, including codes 75571-75574 (Heart CT) and 78451-78454 (Heart muscle SPECT imaging).

Although many practices are eager to see the payment boosts in their next Medicare payments, that may be an overly ambitious goal at this point.

“I inquired with a few MAC carriers such as Trailblazer, Noridian, and Palmetto, and was told different things by different Medicare payers,” says Terry Fletcher, BS, CPC, CCS-P, CCS, CMSCS, CCC, CEMS, CMS, CEO of Terry Fletcher Consulting Inc.

“One did not even know there was a change,” she says. “Next, Noridian said that they will be making the adjustments when they get the directive from CMS. And Palmetto said they would need the provider to contact them and then batch retroactive to January the myocardial perfusion imaging claims and send a letter to request the increase,” she says.

Bottom line: Until CMS provides a clear answer to the MACs regarding when they must implement the changes, you may not see your pay increases, but keep an eye on your carrier’s Web site for information on when it intends to reprocess claims using the new rates.

@ Part B Insider. Editor: Torrey Kim, CPC

Sign up for the upcoming live Webinar, You Can Use the Appeals Process Like a Pro, or order the CD/transcripts.

Be a hero. Sign up for Supercoder.com, and join the coding community at the Supercoder.com Facebook Fan Page.

Comments Off on MACs Differ on Response to CMS’s Cardiology Payment Adjustments
May 27, 2010