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Claims Based Outcomes Reporting “CBOR” Michael Stevenson, MBA, PT Director, Product Management

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Claims Based Outcomes Reporting“CBOR”

Michael Stevenson, MBA, PTDirector, Product Management

Section 3005(g) of the MCTRJCA requires CMS to implement, beginning on January 1, 2013,

“. . . a claims-based data collection strategy that is designed to assist in reforming the Medicare payment system for outpatient therapy services subject to the limitations of section 1833(g) of the Act. Such strategy shall be designed to provide for the collection of data on patient function during the course of therapy services in order to better understand patient condition and outcomes.”

The Other Shoe Has Dropped

WHO

Medicare Part B (p. 227)

All areas of outpatient therapy services including hospitals, CAH, CORF, private practice, home health (after A benefit), SNF, etc.

WHEN

Time Line (p. 277)

Test Period: January 1 – July 1

Payment Rejection after July 1

CBOR

HOW

Must use Outcomes Measures that map to a 7 point scale

AM-PAC, FOTO, OPTIMAL, NOMS recommended by CMS in IOM

IOM provision of the Benefits Policy Manual, Chapter 15, Section 220.3C “Documentation Requirements for Therapy Services.”

14 new G-codes sets

11 Functional G-codes (7 of those SLP)

3 ‘other’, one for each discipline

7 Impairment Limitation Restriction Modifiers

CBOR

Eval/Re-eval Goal Discharge

PT/OT

Mobility: Walking & Moving Around G8978 G8979 G8980

Changing & Maintaining Body Position G8981 G8982 G8983

Carrying, Moving & Handling Objects G8984 G8985 G8986

Self Care G8987 G8988 G8989

Other PT/OT Primary Functional Limitation G8990 G8991 G8992

Other PT/ OT Subsequent Functional Limitation G8993 G8994 G8995

SLP

Swallowing G8996 G8997 G8998

Motor Speech G8999 G9157 G9158

Spoken Language Comprehension G9159 G9160 G9161

Spoken Language Expression G9162 G9163 G9164

Attention G9165 G9166 G9167

Memory G9168 G9169 G9170

Voice G9171 G9172 G9173

Other SLP Functional Limitation G9174 G9175 G9176

G-codes and ModifiersImpaired Limitation

Restriction (% Impaired)

CH 0%CI 20 ≤ 1%

CJ 40≤ 20%CK 60≤ 40%

CL 80≤ 60%CM 100≤ 80%

CN 100%

0% Impaired

20% Impaired

40% Impaired

60% Impaired

80% Impaired

100% Impaired

Mo

dif

ier

Scal

e

Functional G-codes

Only code the primary functional deficit. (p. 246)

If you resolve primary and move to a secondary functional deficit, new G codes must be applied. (p. 246)

If using a composite score instrument, code as ‘other functional impairment’ (FOTO, AM-PAC) (p. 244)

Goal G-Code Modifiers

Intended to be Long Term, Episodic, or Discharge Goal, not short term goal (p. 261)

If you switch to subsequent functional area, you must reset goal codes

Coding Details

In summary, we maintain that claims-based reporting should occur at the outset of therapy episode, on or before every 10 treatment days throughout the course of therapy, and at the time of discharge from therapy. Additionally, functional reporting is also required at the time the beneficiary’s condition changes significantly enough to clinically warrant a re-evaluation such that a HCPCS/CPT code for a re-evaluation or a repeat evaluation is billed.

(Page 273)

Reporting Frequency

• Current G-code w/ modifier

• Goal G-code w/ modifierEval

• Current G-code w/ updated modifier

• Goal G-code w/ modifier (updated)Every 10th Visit

• Discharge G-code w/ modifier

• Goal G-code w/modifierFinal Visit

• New Current G-code w/ modifier

• New Goal G-code w/modifierChanging Primary

Condition

G-code Steps

“We are finalizing the proposed requirement that the G-codes and related modifiers must be documented in the beneficiary’s medical record.” p. 275

This includes functional status, goal, and discharge G codes according to the schedule published in earlier slides.

Documentation

For each line on the institutional claim submitted by hospitals, SNFs, rehabilitation agencies, CORFs and HHAs, a charge of one penny, $0.01, can be added.

For each line on the professional claim submitted by private practice therapists and physician/NPPs, a charge of $0.00 can be added.

A Penny For Your Trouble

To continue market leadership, MediServe developed the web-based data collection tool for the DOTPA program.

MedPAC suggested that “CMS consider developing an instrument that collects the necessary information that would allow Medicare to categorize beneficiaries by condition and severity in order to pay appropriately” and pointed to the “Reason for Therapy” form used in the DOTPA study as a starting point, noting that it is “concise, easy to assess and document for clinicians, and collects information on function and limitations across three therapy disciplines.” (p. 259)

A Look Ahead

SOLUTION IDEAS

PLEASE MUTE YOUR PHONEI WILL BE TURNING ON ALL

THE MICROPHONES

1. Map / update ICF-based functional problem list to CMS list.

2. Modify Problem List / Goal branch 1. Ask ‘level of impairment after choice of functional area,’

(Selection list of modifiers)

2. Allow free text goal description

3. Prompt for goal setting. (Selection List of modifiers)

3. Create 294 charge code definitions (one for each combination of G-code and modifier.)

4. In this configuration, the PRIMARY FUNCTIONAL IMPAIRMENT MUST BE DOCUMENTED FIRST. When branch loops on itself, the alternative problems will not be mapped to charge codes w/ modifiers.

How To Handle This In MediLinks

MCCS: MediLinks Content Configuration Services

Identifying outcomes measures with scales than can be mapped to the 7 points scale

What would we do with this in ML?

How would we know which scales mapped to which functional area?

What if more than one scale was used?

Developing conversions to 7 point scales

Update website with mappings and coding guidance

Secondary Projects

Pick a standardized assessment for all patients (AM-PAC)

AM-PAC score and converted modifier scale can be auto-populated in to problem / goals branch.

Branch can use conditional response to map to proper charge code choice with proper modifier to remove therapist error.

This solution can only tolerate a predetermined use of one outcomes scale.

Alternate Configuration

Evaluation Branch Workflow

Select Primary Impairment

Select Primary Impairment

ModifierEnter Goal

Select Goal Modifier

Go to Additional Problem / Goals

Branches

Progress Summary Branch Workflow

Do you want to Update or DC Primary

Impairment

Select Primary

Impairment

Select Primary Impairment

Updated Modifier

Confirm / Update

Goal

Select Goal

Modifier

Enter Problem Update

Select Primary

Impairment

Enter Problem Update

Select Primary Impairment

Discharge Modifier

Confirm / Update

Goal

Select Goal

Modifier

Select whether Subsequent Functional Limitation needs

to be set

Update

Discharge

Subsequent

Select Subsequent Impairment

Select Subsequent Impairment

Modifier

Enter Goal

Select Goal

Modifier

Go to Additional Problem / Goals

Branches

Discharge Summary Branch Workflow

Select Primary or Subsequent

Impairment

Enter Problem Update

Select Primary Impairment

Discharge Modifier

Confirm / Update Goal

Select Goal Modifier

Go to Additional Problem / Goals

Branches

Operational Challenges?

Identify patients missing G-codes (How do we know they need them? How is Medicare defined?)

Identify when Subsequent impairments are created without Discharge scores for Primary impairment

Identify patients with impairment G-codes, but missing Goal Codes

Patients show are on their 10th visit today and needing G-codes. Report initially, future Task List or Appointment Alert?

Discharged Patients missing Discharge G-codes / Discharge Goal codes

Reports

Charge master by locationIs anyone configuring ‘duplicate’ charge definitions based on location?

Considerations

Final selection on solution proposals

Another webinar to demonstrate final content

Establish delivery timeframes

Next Steps

Project Email: [email protected]

Michael Stevenson

[email protected]

800-279-8456

Contact Information

Thank You