Allen Frady, RN-BSN, CCDS, CCS, CRC, says that defending code assignment against denials requires more than reviewing the denial to determine if the condition was coded and reported according to the coding guidelines; it requires an understanding of payer requirements as well.
A nine-month audit conducted by a CDI specialist at a family practice and internal medicine clinic revealed 1,353 coding errors on physician-coded claims for outpatient office visits. Tammy Trombley, RHIT, CDIP, CCDS , reviews findings from this 2017 audit and discusses implications for risk-adjustment coding.
Continuing with numerous requests for comment in last year’s OPPS proposed rule, CMS is once again asking stakeholders for feedback on a variety of issues for potential future rulemaking. Review OPPS proposals for quality measure changes and policies aimed at improving interoperability and the electronic exchange of information between providers.
Chris Simons, MS, RHIA, details way to improve querying across health information management (HIM), coding, and CDI departments since querying providers is a key strategy for improving documentation. Note : To access this free article, make sure you first register here if you do not have a paid subscription.
CMS’ 2019 OPPS proposed rule, released in late July, continues the agency’s efforts to enforce site-neutral payments and reduce drug payments by introducing policies to reduce reimbursement for hospital outpatient clinic visits at off-campus, provider-based departments.
Continuing with numerous specific requests for comment in last year’s OPPS proposed rule, CMS is once again asking stakeholders for feedback on a variety of issues for the 2019 OPPS proposed rule for future potential rulemaking. You may submit comments to the agency until September 24, 2018.
Back in January, I wrote an article regarding E/M codes and the need for changes to the 1995 and 1997 E/M documentation guidelines. In that article, I suggested making E/M codes for office visits solely time-based to simplify the reporting of these very subjective codes. Little did I know that this is what CMS would propose months later.
Along with quality measure removals in the 2018 OPPS and MPFS final rules, CMS has continued to propose additional removals in the 2019 proposed rules. In addition, the agency is proposing to add to its ability to remove quality measures in the future.
A common error and audit finding affecting providers is the lack of a physician order or physician signatures on medical documentation. Kimberly A. H. Baker, JD, CPC , reviews CMS guidance for physician signatures on medical documentation.
To succeed in a modern health information management (HIM) environment, coding departments need efficient coding specialists and knowledgeable management to monitor coder performance and provide feedback. Review expert guidance on hiring staff and determining work flow to improve the organizational structure of your coding department.
Rose T. Dunn, MBA, RHIA, CPA/CGMA, FACHE, FHFMA, CHPS , writes that beyond auditing for code assignment, coding reviews also provide an opportunity for you to conduct a thorough compliance evaluation that not only addresses other components of the coding process but also the integrity of the patient’s record. Note : To access this free article, make sure you first register here if you do not have a paid subscription.
A July 2018 update to the OPPS clarifies that coders can report HCPCS code C9749 for an inherently bilateral procedure with modifiers -73 or -74 to indicate that the procedure was unilateral. Debbie Mackaman, RHIA, CPCO, CCDS, unpacks this seemingly contradictory guidance and addresses implications for coding and billing professionals.
Many HIM directors find that managing the coding team requires a different type of focus than other functions within the department. This may be true because coding professionals have advanced education, prefer a quiet work environment, and require less direction.
Provider documentation must meet required standards to support the level of care provided. Rose Dunn, MBA, RHIA, CPA/CGMA, FACHE, FHFMA, CHPS , reviews payer guidelines and medical necessity requirements under Medicare for services performed in the outpatient setting.
Hospital systems need to be watchful for CMS proposals that will impact payment for drugs and drug therapies in 2019 and beyond. Jugna Shah, MPH, reviews the potential implications of recent CMS actions, such as the publication of the 2019 IPPS proposed rule and the overhaul of 340B drug payment program.
Healthcare providers are often confused about what a commercial or managed care payer would want in order to approve the claim. Much of this confusion comes from the timing of requirements to ensure reimbursement.
Predicting CMS policies can be a foolhardy exercise, especially with a relatively new administration and frequent turnover at the highest levels of HHS over the last year. But it’s safe to say drug payment policy has been and will continue to be a focus of the current regime.
Coders are on the front lines of claim submission and in a good position to foster compliance. Learn strategies to prevent fraud and abuse and encourage accurate documentation and billing within your outpatient facility. Note : To access this free article, make sure you first register here if you do not have a paid subscription.
When planning to implement a coding auditing program, the type of reviews, focus areas, and review frequency must all be taken into consideration. Rose T. Dunn, MBA, RHIA, CPA/CGMA, FACHE, FHFMA, CHPS , details how to conduct an effective coding audit and ensure compliance with documentation requirements.
Do you question how your compensation and work responsibilities compare to those reported by coders across the country? To see how you stack up, review results from JustCoding’s 2017 Coder Salary Survey . Note : To access this free article, make sure you first register here if you do not have a paid subscription.
CMS recently released MLN Matters SE18001 to provide healthcare practitioners with instructions and coding guidance for specimen validity when performed and billed in combination with drug testing. The article was issued to remind laboratories and other providers performing urine drug testing that specimen validity testing (SVT) is not separately billable.
A coding audit may be conducted by internal staff or external entities, typically representing the insurers paying for the care. When planning to implement a coding auditing program, the type of reviews, focus areas, and review frequency must all be taken into consideration.
Telehealth services continue to expand and claims for these services may already be under scrutiny by Medicare contractors. Debbie Mackaman, RHIA, CPCO, CCDS, writes about the differences between originating site and distant site services in addition to coding, billing, and reimbursement for telehealth services.
Danielle Richmond says that while inpatient coder shortages are nowhere near what they were with ICD-9-CM, new challenges have emerged. This article shares important advice for any managers trying to improve their coder recruitment and hiring process.
The shift from fee-for-service to value-based programs for outpatient payment systems has increased the need for outpatient CDI staff to review documentation for pertinent clinical factors.
The fiscal year (FY) 2018 ICD-10-CM changes have now been active for several months. Though the volume of new codes is relatively small compared to previous updates, the impact on reimbursement has the potential to be quite large.
Valerie Rinkle, MPA, writes about CMS’ hospital prohibition of unbundling rules and a new outpatient date of service exception for molecular pathology and advanced diagnostic laboratory tests.
Medical necessity documentation, or lack thereof, is one of the most common reasons for claim denials. This article describes how medical necessity impacts third-party payers and those who work in billing and reimbursement services.
In the 2018 OPPS final rule, CMS finalized a change to the current clinical laboratory date of service policies for outpatient molecular pathology tests and advanced diagnostic laboratory tests.
In the current healthcare climate, the issue of medical necessity documentation, or lack thereof, is one of the most common reasons for claim denials. For a service to be considered medically necessary (by a third-party payer), it must be considered a reasonable and necessary service to diagnose and/or treat a patient’s current and/or chronic medical condition.
Shannon E. McCall, RHIA, CCS, CCS-P, CPC, CPC-I, CEMC, CRC, CCDS , writes about discussions at the AMA CPT Symposium that could impact coders, including the need for updates to CMS’ E/M Documentation Guidelines and how medical decision making is used as a key component for E/M reporting.
Bundled Payments for Care Improvement Advanced, a new voluntary bundled payment model launched by CMS in January, includes 32 clinical episodes encompassing both inpatient admissions and outpatient procedures. Yvette DeVay, MHA, CPC, CPMA, CIC, CPC-I , writes about participation criteria, payment calculations, and quality measures for this program.
In recent years, numerous pieces of legislation have been passed to limit healthcare spending, combat losses due to fraud, and ensure that dollars are being spent on quality care. Adrienne Commeree, CPC, CPMA, CCS, CEMC, CPIP , describes different watchdog programs created to promote billing compliance and quality of care.
Creating a query and knowing when to query can be complicated, and there are a number of training tactics that can prove successful for coders when trying to improve upon physician query practices. For this article, let’s take a look at when coders should query and when it’s appropriate for them to cite clinical evidence. Note : To access this free article, make sure you first register here if you do not have a paid subscription.
CMS' Bundled Payments for Care Improvement Advanced model will qualify as an Advanced Alternative Payment Model under the Quality Payment Program and include outpatient episodes.
The advancement of accurate and compliant coding efforts brings unique challenges. As benevolent as a health information management (HIM) department’s mission may seem to be, for many facilities, the focus of physician queries continues to be “optimizing” information in the medical record to increase reimbursement.
Complying with healthcare regulations within a coding department or physician practice involves promoting a positive attitude toward activities such as self-monitoring and staying up-to-date with healthcare regulations. Follow these steps to adhere to sound business ethics and set expectations for behavior across an organization. Note: To access this free article, make sure you first register here if you do not have a paid subscription.
In this article, Valerie A. Rinkle, MPA, offers guidance regarding the 340B drug discount program. She provides tips for accurate documentation of drug purchases and reviews frequently asked questions about billing for 340B-acquired drugs in 2018.
If ICD-10-CM/PCS is used to its full potential, it will provide greater detail and a more accurate depiction of patient severity. This level of detail is expected to provide more information about the relationship between a provider’s performance and the patient’s condition.
CMS' 340B FAQ reviews modifiers -JG (drug or biological acquired with 340B drug pricing program discount) and -TB (drug or biological acquired with 340B drug pricing program discount, reported for informational purposes) and requires 340B hospitals to report modifiers even on drugs that are not subject to the discount policy.
The improper payment rate for hospital outpatient services was 5.4%, accounting for 7.5% of the Medicare Fee-For-Service improper payment rate, according to 2016 Medicare Fee-for-Service Improper Payments Report.
When faced with a claim denial, providers need to understand what is being denied and when an appeal is appropriate. This article outlines basic steps providers need to take before composing an appeal for a claim denial and helpful tips for successfully navigating through the appeals process.
Creating a query can be complicated, and there are a number of continued training tactics that prove successful for the coder when trying to improve upon physician query practices. This article takes a look at how improving a coder’s knowledge of principal and secondary diagnosis selection can produce a more effective physician query. Note: To access this free article, make sure you first register here if you do not have a paid subscription.
HCCs aren’t new, but for many organizations, their impact hasn’t been apparent until recently. Organizations must educate staff on HCCs to ensure success under reimbursement methodologies such as the Quality Payment Program and Merit-based Incentive Payment System reimbursement.
CMS is moving forward with its plan to drastically cut payments for drugs acquired through the 340B drug discount program, according to the 2018 OPPS final rule, released in November.
CMS’ policy in the 2018 OPPS final rule to cut reimbursement for drugs purchased through the 340B drug discount program by nearly 30%, accounting for the decrease from average sales price plus 6% to minus 22.5%, is getting a lot of attention from the provider community—and with good reason.
Hiring top-notch inpatient coders: Is it good luck, great karma, or the power of prayer? Many coding managers say it takes all three to recruit high-quality, experienced medical record coders post-ICD-10.
While the 2018 OPPS final rule may be controversial for its payment cuts to drugs purchased through the 340B drug discount program, it contains several provisions supported by hospitals and other stakeholders.
A new private payer rate-based Clinical Laboratory Fee Schedule (CLFS) system is estimated to drastically reduce Medicare Part B lab payments in 2018. Valerie A. Rinkle, MPA, details how this revision will impact providers in outpatient settings and payers tied to the Medicare CLFS.
More and more, hospitals are experiencing a shift of services from inpatient to outpatient settings. In this article, Laura Jacquin, RN, MBA , describes common challenges healthcare workers face when providing comprehensive documentation for services across the care continuum.
In July, Utah pain doctor Jahan Imani, MD, and Intermountain Medical Management, P.C., entered into a nearly $400,000 settlement with the OIG to resolve allegations that Imani’s practice submitted false or fraudulent claims due to improper modifier use for payment by improperly using modifier -59 with HCPCS code G0431.
Patient care continues to move from the inpatient setting to outpatient. With this change, the challenge of securing comprehensive documentation that articulates the services rendered and the patient care provided now needs to extend across the care continuum.
Section 216(a) of the Protecting Access to Medicare Act of 2014 (PAMA) added a requirement that will dramatically revise the Medicare Clinical Laboratory Fee Schedule (CLFS) effective January 1, 2018.
Root cause analysis of edits and an understanding of the relationship between the chargemaster and HIM/coding must be supported by overarching principles and best practices for edit management. Processes should be built around the timing of edits, applying edits across payers, and denial management.
In the 2018 OPPS proposed rule, CMS proposed a change to the current clinical laboratory date-of-service policies for molecular pathology tests and for Advanced Diagnostic Laboratory Tests.
The 2018 OPPS proposed rule includes potential changes to 340B drug discount payments, the inpatient-only list, packaging for low-level drug administration services, and more.
CMS wants your thoughts on its 2018 OPPS proposed changes. In various places in the proposed rule, CMS specifically asks providers to comment on the proposals. You may submit comments to the agency until September 11, 2017.
You may find significant changes to E/M reporting in the near future, including a pivot away from two key elements — history and physical exam — that largely determine a given level of service for your most common patient encounters.
It’s that time of year again – when HIM directors, hospital administrators, and coding managers begin to wonder just how they will be affected come October 1.
Rose T. Dunn, MBA, RHIA, CPA, FACHE, FHFMA, CHPS , explains that as a coding manager, whether your inpatient team is on-site, off-site, or remote, creating the appropriate environment and selecting proper locations are key to any successful team. Note: To access this free article, make sure you first register here if you do not have a paid subscription.
As CMS and third-party payers have looked for ways to treat patients in the outpatient setting and reduce inpatient volumes, CMS has used the 2-midnight rule, in addition to other methods, to treat patients as outpatients or in observation whenever possible.
Every now and then, the HCPro Boot Camp instructors are asked similar questions on a specific billing issue from students and clients across the country. The old saying “there must be something in the water” often holds true, and it does in this case, especially regarding recent OIG audits.
In late June, CMS released a major proposed rule that hospitals will need to pay attention to—and no, I don’t mean to say that CMS released the CY 2018 OPPS proposed rule early, though we’ve thought that might happen since it’s been at the Office of Management and Budget (OMB) for several months.
In today’s virtual environment, with its focus on flexible schedules, organizing an inpatient coding team requires consideration of time zones, team member skills, volume of work, and claim-processing schedules. Note: To access this free article, make sure you first register here if you do not have a paid subscription.
There is an extensive list of coverage requirements that must be met to furnish outpatient services to Medicare beneficiaries. Gina M. Reese, RN, JD, CPHRM , discusses some of the trickier issues that facilities will need to audit more carefully while monitoring for compliance in provider-based departments.
The Ochsner Health System in Louisiana revolutionized the way its clinical documentation excellence (CDE) team captures annual hierarchical condition categories for all patients across its vast system. Now, Ochsner can serve as a case study to educate others on how to create an outpatient focus on CDI in an increasingly risk-adjusted world.
When CMS introduced Hierarchical Condition Categories with risk-adjusted scores, Ochsner Health System began efforts to educate providers and improve documentation across its many facilities.
There is an extensive list of coverage requirements that must be met to furnish outpatient services to Medicare beneficiaries. Hospitals may find that certain coverage requirements for therapeutic and diagnostic service are more difficult to meet than others, especially in off-campus provider-based departments.
Coding plays a large role in claims and therefore is a key factor in reimbursement compliance. As such, coders have a responsibility to be as accurate and up-to-date on coding practices as possible. Rose T. Dunn, MBA, RHIA, CPA, FACHE, FHFMA, CHPS , explores some of the organizations and regulatory bodies available to assist coders.
Traditionally, the OPPS rulemaking cycle has been the main vehicle for changes to outpatient coding and billing regulations and policy that hospitals need to pay attention to. But increasingly, CMS has been introducing or discussing changes relevant to outpatient hospitals beyond the scope of the OPPS rules.
HCCs are the basis for risk adjustments for reimbursement models like Medicare Advantage, accountable care organizations, and other value-based purchasing measures such as Medicare Spending Per Beneficiary. Poor understanding and application of HCCs mean that a hospital’s patients may be much sicker in reality than they appear to be on paper, and that will hit reimbursement hard.
Accurate clinical documentation is the bedrock of the legal medical record, billing, and coding. It is also the most complex and vulnerable part of revenue cycle because independent providers must document according to intricate and sometimes vague rules.
Medicare recently published revisions to its appeals process, focusing on the Administrative Law Judge (ALJ) level of appeal. These revisions were published in the Federal Register in the form of final regulations on January 17, 2017, and became effective March 20.
The 2017 calendar year marks the beginning of a new approach to physician payment through the Quality Payment Program (QPP), an initiative created by the Medicare Access and CHIP Reauthorization Act to revise the physician payment system previously updated through the Sustainable Growth Rate.
The intersection of CMS’ packaged payment policy and the increasing volume of Medically Unlikely Edits (MUE) can be likened to a car crash waiting to happen. Hospitals are having valid, medically necessary claim lines denied – including charges and units below MUE limits. Providers can help stop the crash by ensuring their claims, CPT coding, medical necessity, and the units are all correct.
Accurate clinical documentation is the bedrock of the legal medical record, billing, and coding. It is also the most complex and vulnerable part of revenue cycle because independent providers must document according to intricate and sometimes vague rules.
As OPPS packaging has increased, providers may be less likely to appeal claims for certain denied charges based on medically unlikely edits, since it would not increase payments. However, providers should consider appeals when services are medically necessary and appropriate, as CMS bases future payment rates on accepted claims.
With a new year underway, providers likely need to get a handle on some key new modifiers, as well as important changes to an existing modifier and the deletion of a modifier that previously raised a lot of questions and operational concerns.
The focus for clinical documentation improvement (CDI) specialists has historically been on the inpatient hospital stay. Review of the chart for conditions that are not fully documented and/or evidence of conditions not documented at all has been standard practice.
With a new year underway, providers likely need to get a handle on some key new modifiers, as well as important changes to an existing modifier and the deletion of a modifier that previously raised a lot of questions and operational concerns.
Coding managers cannot always monitor every guideline update or coding-related issue targeted by the Office of Inspector General. Rose T. Dunn, MBA, RHIA, CPA, FACHE, FHFMA, CHPS, reviews what a coding manager can do during a coding audit and how to implement a plan.
Lori-Lynne A. Webb, CPC, CCS-P, CCP, CHDA, COBGC, CDIP, writes about the challenges faced in OB hospitalist practices and which procedures and services to focus on for coding, billing, and documentation.
Managers should not assume that they can review every guideline, every item in Coding Clinic , or every coding-related issue targeted by the Office of Inspector General (OIG) or Recovery Audit Contractor (RAC).
The 2017 OPPS final rule brings the end of modifier –L1 for separately reportable laboratory tests, along with changes to CMS’ packaging logic. Jugna Shah, MPH, and Valerie A. Rinkle, MPA, review how these changes will impact providers.
Chronic care management codes were adopted by CMS in 2015, but relatively few providers use them. Lori-Lynne A. Webb, CPC, CCS-P, CCP, CHDA, COBGC, CDIP, writes about the criteria needed to code and bill these services, as well as how coders can work with providers to ensure documentation supports the codes.
Each year, CMS reviews procedures on the inpatient-only list, which consists of services typically provided on inpatients and not payable under the OPPS, to consider whether they are being performed safely and consistently in outpatient departments.
As it does each year, CMS reviewed its packaging policies and proposed numerous modifications for 2017, finalizing a move to conditionally package at the claim level and deleting the controversial modifier used to identify separately reportable laboratory tests.
CMS made certain concessions from its proposed site-neutral payment policies required by Section 603 of the Bipartisan Budget Act, but it is still moving forward with implementation January 1, 2017, according to the 2017 OPPS final rule.
Rose T. Dunn, MBA, RHIA, CPA, FACHE, FHFMA, CHPS, writes about methods coders can use to improve the quality and detail of physician documentation to ensure important information is captured.
Providers need to make sure that electronic order templates include all the necessary information to bill correctly and avoid issues during audits. Valerie A. Rinkle, MPA, writes about what must be contained in the order and ICD-10-specific updates providers should consider.
Orders for services are a vital component of ensuring Medicare coverage. With the advent of computerized provider order entry (CPOE), it is important to review order templates in the electronic medical record (EMR) and the resulting order produced or printed in the formal legal medical record to ensure the templates meet requirements.
With only 60 days between the OPPS final rule's release and the January 1 implementation date, providers will be ahead of the curve by spending time now and thinking about the processes they may need to review, change, or implement based on what CMS finalizes and the sort of financial impact the final rule is likely to have.
