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Archive for January, 2010

The Perfect Time For Documentation Review

Posted by Paul Spencer, CPC, CPC-H in Coding and Compliance, Hot Topics, Industry Updates, Paul Spencer CPC CPC-H

The last seven days have brought forth an interesting mix of stimuli to me.

I attended a coding seminar in Las Vegas, flying out last Saturday and returning on a night flight on Tuesday. As the conference industry has expanded in Las Vegas, I’m always struck by the juxtaposition of professional conference attendees and degenerate gamblers on display in any casino in the city at any given time. After absorbing three days of industry knowledge in this environment, it slowly became harder to decide whether the constant ringing in my head was coming from the inundation of sudden knowledge or from the cornucopia of slot machines.

The cab ride home from the airport was interesting Tuesday night. Apparently, the addition of GPS in modern taxis has not increased the sense of direction of cab drivers at nearly a comparable level to skyrocketing cab fares. I had $12 in my pocket, and thanks to the circuitous route taken by the cab driver, the fare was up to $16 and I was still ten blocks from my house. Thankfully, ten blocks from my house is where my bank’s ATM is located. I took some money out, paid the driver begrudgingly for her impeccable navigational skills, and walked the last 10 blocks in 14-degree weather without a coat while carrying my bag. To all the muggers of the world, this is my way of telling you that you missed your chance for an easy mark. After 4 blocks of sub-Arctic marching, I could have been knocked out with a bouquet of Gerber daisies.

Over the last few days upon my arrival at home, I have been reading a biography of the band XTC, whose lead singer suffered a nervous breakdown from excessive touring. I briefly felt his pain in the hours after the walk home. As I read this story, my 3-year-old was pretending to be Batman, complete with cape. He does this by running back and forth between the kitchen and living room of my house. To finish out my week, I arrived at my desk this morning and was told it was time to relocate within the office, along with about 15 of my coworkers. I have gone from the spacious cubicle enjoyed while creating previous posts here to a work area that faces a blank wall. All I can think is “At last the bells finally stop ringing; where are my crayons?”.

In this week of over-stimulation, it seems a good time to look at the equally chaotic reimbursement landscape now that Medicare has ceased payment on consultation codes. Rather than panic, I’d like to suggest an alternate route for specialty physicians who now face a decline in revenue due to the elimination of these codes for Medicare billing. Rather than pining for payment opportunities that have disappeared for good, now is the perfect time to give a second look at the documentation you create for the E/M services that still exist.

I ask the physician who may be reading this to pull out one piece of documentation from a random patient they have seen today and look it over. Does the documentation give a useful, reimbursable and defensible narrative centered around the patient’s chief complaint? Is it a collection of sentences telling a story, or a morass of acronyms like “C/O”, “WNL” and “Ox3″? Could this documentation be better based on the code chosen? Conversely, could it have been reimbursed at a higher level had you correctly documented the service performed on behalf of the patient?

If physicians can look at the documentation for their E/M services and come to the conclusion that to the best of their ability, they have accurately captured the services performed in a narrative format, and that the clinical language of the chart has a direct correlation to the billing language chosen (the reported CPT code), the perception of the amount lost as a result of a consultation code not being available suddenly changes. While medical necessity remains the main driver in the selection of a CPT code, an opportunity may exist for financial stability with a simple review of a medical record. With consultations billed to Medicare now a thing of the past, there’s no time like like the present to take another look.

WE DO MAKE A DIFFERENCE

Posted by Karla Brown in Community Involvement

I got a call yesterday morning and on the other end of the phone was my 22yr daughter, screaming at the top of her lungs. I of course instantly thought something was wrong. After a minute of saying “I can’t understand you”, she slowed down and explained she had just received her letter of acceptance for the Graduate program at the University of Missouri. My heart rate began to slow to its normal pace and I gave her all my congratulations and of course, “I told you so”.

Later on in the day, I received a text message from that same daughter, thanking me for raising her up to become such a focused and determined women. She said because of that, it helped her to get where she is now and where she will be going in the future. I though to myself wow, I did that? Now, I also have a 20yr old son who is a junior in college. I was very surprised he went on to college as much as he disliked high school, but things have really changed for him and he too is excelling at his goals. I started thinking about my kids growing up and trying to remember exactly what I did or said to wind up so very blessed. Sure, I can remember some of the easy things we parents teach our kids like, “eat your vegetables”, “do your homework”, “respect your elders” and “don’t run with scissors in your hands. But I can truly say I don’t remember what I did or said to get them to the point where they are ready to take on this complicated and ever changing world we live in now, but it’s obvious, they remember and for that, I am truly grateful.

So, I guess what I am getting at is, for all of you parents, soon to be parents, and even grandparents that may not already know this, our children really do listen to us! They get it, they got it, even if we don’t remember exactly what we said or how we said it, they eventually do get it and one day if they haven’t all ready, they will remind you that you do make a difference in their lives and they are better for it. So be proud of yourselves and keep up the good work. And to think, it wasn’t even Mother’s Day!

Meaningful Use Defined: When Good Ideas Go Bad

Posted by Paul Spencer, CPC, CPC-H in Coding and Compliance, Fi-Med Services, Hot Topics, Industry Updates, Paul Spencer CPC CPC-H

Had she been alive today, today would have been the 101st birthday of actress Ann Sothern. A quick glance at her acting credits includes appearances in dozens of movies and her own situation comedy that ran for three seasons across an acting career that spanned nearly six decades.

You may ask why I’ve opened a blog that deals with medical billing, coding, compliance and health information with a short biography of an old actress. Please bear with me for a few paragraphs.

There is one credit on Ann Sothern’s resume that sticks out in my mind and is relevant to today’s dissertation. In 1965, Ms. Sothern played the voice of a dead woman in a television show that most critics now point to as one of the worst shows in the history of television. That show was My Mother, The Car. The show followed the exploits of a young man who one day buys an antique automobile from a used car lot. When he turns on the radio in the car, who should be on the radio but his dead mother offering life advice from beyond the grave. Mercifully, this show only lasted one season and to my great glee is not available on DVD.

As we stand back and look at this plot line, we begin to wonder not only why such an atrocious idea ever made it to air, but what person, when this idea was pitched to them, thought that something like this would appeal to the viewing public. Worse yet, the young man in the show was played by Jerry Van Dyke, whose entrance onto the American entertainment landscape acts as the ultimate symbol of what happens when we let a talented person’s less gifted siblings share a piece of the spotlight.

I brought forward the example of My Mother, The Car to illustrate that no matter what the quality, all any idea really needs is a benefactor; someone who hears an idea and states “I think that’s great! Let’s run with it”.

Which brings me to the proposed rule defining “meaningful use” of electronic health records (EHR) that was released on December 31st by CMS. In early 2009,when it was announced that physicians would receive incentive payments for the meaningful use of EHR in mid-2011, there was much excitement that a new day was dawning in the way our health care infrastructure managed and shared patient medical information.  Before meaningful use was defined, the Certification Commission for Healthcare Information Technology (CCHIT) created a certification for EHR systems that would meet the standard. Some systems gained CCHIT certification prior to the release of the proposed rule, which I pointed to in an earlier post as premature. 

Since the proposed rule listing 24 specific requirements needed to meet meaningful use was released on the last day of 2009, many practices who took the plunge and purchased an EHR prior to a clear definition of what was needed to meet the standard are experiencing buyer’s remorse, realizing that a large investment has been made for systems that may not meet the standards if the proposed rule is implemented as written.

The requirements demonstrate high ideals of treatment and public health. An example of this is the idea of EHR’s being able to share important patient condition information with immunization registries and public health agencies. Under this proposed requirement, at least one test must be performed to assess the EHR’s ability to provide electronic lab results to a public health agency. We heard a lot about interoperability when the discussion of meaningful use began in earnest last year, but a requirement such as this can only work if the relevant public health agencies have the ability to receive the information electronically.

Also put forth is the proposal that any certified EHR system be able to provide patients with an electronic copy of their health information upon request. The key word in that phrase is “electronic”. While some more sophisticated EHR systems and larger health care institutions now have this capability, this requirement places a large privacy and security burden on smaller practices that lack the IT infrastructure support to create a secure electronic pathway from the office to the patient.  

It is the intersection of high ideals and the execution of the same that presents itself as a formidable challenge to any idea. Between now and the release of the final rule, which is expected sometime after March of this year. I encourage those that have yet to purchase an EHR system, and even those who have implemented an EHR in their practice believing it would meet any standard, to review the proposed rule. If these requirements outlast scrutiny and become final, this may someday be seen as an idea that slowly took on a life of its own, consuming everything in its path until it was too late. This would be similar to the thought all those years ago that a dead mother talking to her son through a car radio would be appealing to a wide audience.

The Dream Must Go On

Posted by Karla Brown in Community Involvement

Today we celebrate the birthday of the late Dr. Martin Luther King, Jr. We all know the story of Dr. King, or at least we should. We know he was a minister, a pioneer for civil rights, a husband and father. Remember, he gave that memorable speech. You know the one where he talks about having a “dream” in front of the Lincoln Memorial in 1963. Some of us were not born at that time, but we have heard the speech or even seen it replayed on our televisions. We also heard the stories of his assassination in April of 1968 and the riots that followed. He was taken away too soon like another famous American in our history, President John F. Kennedy.

Today, we must continue to work on keeping his hopes and dreams alive. His visions for equal rights were not just for African Americans. They were for people of all races, young and the old. He wanted our children, no matter what color, to be able to play, laugh and learn together. He wanted men and women of all races to earn equal pay if they performed the same job and worked the same amount of hours. He wanted economic justice for the poor and disadvantaged no matter the color of their skin. He was a man of peace and love.

I believe if Dr. King was here today, he would be encouraged by how much has been accomplished. Our children are educated together and happily play side by side. Minorities, male and female are earning their rightful salaries. We have hundreds of programs and agency’s working to help the poor and less fortunate get back on their feet instead of just giving them enough to survive. We have seen our first Hispanic Supreme Court Justice and our first African American President of the United States.

He would be proud. We should be proud. After all, his dreams were meant for everyone.

Billing For Consults After “The Apocalypse”

Posted by Paul Spencer, CPC, CPC-H in Coding and Compliance, Fi-Med Services, Hot Topics, Industry Updates, Paul Spencer CPC CPC-H

“Orchestral music rises as the first glimmers of an ominous sunrise brings light to a dusty and desolate landscape, where once-plentiful streams of revenue have been vaporized by statute. Small bits of paper with numbers such as “99254″ and “99241″ blow across the feet of our stethoscope-clad hero, as he faces a future full of financial uncertainty and unwanted adventure…”.

We are now two weeks into a world where Medicare has eliminated reimbursement for inpatient and outpatient consultation codes. To many specialists for whom consultations have become a way of life, it is tempting to see themselves as a manufactured post-apocalyptic film character similar to the one above. It is my duty, as a compliance officer, certified coder and budding writer of screenplays to inform you that it doesn’t have to be that way.

In a previous post on this blog, I demonstrated one way to navigate the imperfect crosswalk that exists between inpatient consultations and the CPT codes for initial inpatient encounters (99221 through 99223) that are now to be used in its place. In the past weeks, the Medicare administrative carriers have released their own guidance about what should be billed in place of a consultation code if the documentation does not meet the requirements of CPT code 99221.

For Palmetto GBA, First Coast and WPS, the suggestion is that CPT code 99499 (Unlisted evaluation and management service) be utilized for services formerly billed as 99251 or 99252. When using this code, be aware that it lacks a set payment. The reimbursement of this code is driven on a case-by-case basis and is determined by carrier review of documentation for the service. When billing 99499 to a carrier that accepts it, always be certain to include the documentation for the service.

National Government Services, as well as other carriers, is suggesting that the appropriate inpatient follow-up code (99231 through 99233) be billed in place of a low-level consultation. The choice of code would depend on the depth of the documentation for the service.

The second challenge that has been brought forth is the question of consultations when Medicare is the secondary payer (MSP). In the final revision of the new consultation policy in MedLearn Matters article MM6740,  there are two solutions that can be used. You can either choose not to bill consultations at all to a commercial payer and be reimbursed for E/M services by both commercial and MSP, or you can bill the consultation to the commercial payer, then report the amount paid and bill an equivalent E/M code to Medicare to determine whether additional reimbursement is due.

The first solution is the path of least resistance, as this eliminates consultation billing from your practice immediately and entirely. Financially, this may not be the most advantageous approach. While commercial payers are expected to eventually follow CMS’ lead and eliminate reimbursement for consultations, these codes are still active with commercial payers at reimbursement rates that are typically larger than equivalent E/M codes based on documentation.  Contractually, if you are still receiving healthy reimbursements from commercial payers for consultations, the second approach may be more to your advantage.

The reimbursement landscape has changed, but it has not been irrevocably altered for the worse. The road to reimbursement commensurate with services performed now has a few more detours than it did a month ago, but water recedes and bridges can be rebuilt. With increased attention to documentation detail and increased awareness of the new rules of the road, providers can successfully navigate a world without consultation reimbursement.

Paul Spencer CPC, CPC-H

Haiti Earthquake Relief

Posted by Karla Brown in Community Involvement, In the Press

I am sure by now you have all heard and seen the devastation that occurred in Haiti this week. A country of people who already have so little, now have even less. The loss of life is expected to be in the thousands and even more are injured or unaccounted for. Even though some relief has reached Haiti by planes, helicopters and Navy ships, efforts to get supplies to the people are being hampered by trees and other debris blocking roads. I have been to this place a few times, located in the beautiful Caribbean. Some cruise lines stop there so we can relax on the beaches, listen to the music and see what the locals have to offer. They are always happy to see visitors and eager to show us their goods they have made to sell in order to make a living. I must say I have left there a few times with a bag of goodies and a hope I have helped someone with the few dollars I gave.

Now, we all have a chance to help in some way, big or small. They truly need or prayers, but monetary donations are also urgently needed. They need this funding for food, water, shelter and medicine. The doctors there are saying they cannot even provide simple things such as aspirin because all was lost in the quake. You can find information on how and where you can donate on internet sites such as CNN or your local and world news networks. The Red Cross has information on their website and former President Bill Clinton has a relief site at www.clintonfoundation.org/haitiearthquake. I got a text number last night while I was watching ABC World News that I used to make a donation. You text the word HAITI to 20222 and $10.00 will be added to your cell phone bill. It may seem minimal, but honestly they are pleading for whatever people can give.

So pass the word on to your family and friends and give whatever you can. And please don’t stop praying for the people of Haiti.

Meet the New Fee Schedule, AKA 2009 2.0

Posted by Paul Spencer, CPC, CPC-H in Coding and Compliance, Fi-Med Services, Hot Topics, Industry Updates, Paul Spencer CPC CPC-H

Welcome to the first post for 2010 on the Fi-Med blog. Knowing some of you the way I do, I gave you 8 days to sober up from your New Year’s celebrations, and I bid you welcome. For some of my more hardcore partying compatriots in the writing community who are reading this while catching up on what you’ve missed, I hope you had a pleasant Valentine’s Day.

I myself spent the early morning hours here in Milwaukee recreating the famous road-building scene in the classic film “Cool Hand Luke”, with the exceptions being that  the dirt and gravel on my shovel was replaced by snow, and George Kennedy was nowhere around to help me finish shoveling.

We’re now in 2010, and while we were celebrating, a few changes occurred to the proposed 2010 Physician Fee Schedule that I thought I’d share with you to bring you up to date.

Perhaps it is better to begin this explanation by reintroducing you to the 2009 Physician Fee Schedule, now held over for two more months. As the journey towards final health care legislation continues in Congress, a temporary pay fix was signed on December 19th by President Obama, which will continue the 2009 fee schedule until February 28th. This halted the planned 21.29% payment cut that was scheduled to go into effect on January 1st.

There are a few changes to note. The current conversion factor increased slightly from $36.0666 to 36.0846. While the assumption would be that this would lead to a temporary nominal increase in reimbursement for the two-month period, this actually depends on your locality.

While the 2009 Fee Schedule was being held in place, planned changes to geographic practice cost indices (GPCI’s) went into effect that are modified based on the area of the country in which you practice. High-cost areas of the country now have a GPCI above the former minimum of 1.000, while lower-cost parts of the country have fallen below 1.000. In all, 54 out of 89 localities are seeing a decrease in their GPCI to a level below 1.000, so while the conversion factor is temporarily raised, most low-cost area providers will in fact see a fee decrease for the first two months of 2010. This is expected to be corrected in the pending legislation, which would extend the GPCI minimum of 1.000 until 2011.

This same pending legislation, which to date has been beaten and battered worse than Lenten cod, is also slated to increase the conversion factor by half of a percentage point for 2010. With the seemingly endless bickering and posturing that has characterized the process for this particular bill, it is best to tell the reader to stay tuned for further developments as the legislation nears completion.

Paul Spencer CPC, CPC-H