coding 101: getting paid for what you do jeannine z. p. engel, md assistant professor of medicine...
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Coding 101:Getting Paid for What You Do
Jeannine Z. P. Engel, MDAssistant Professor of Medicine
Vanderbilt University Medical Center
Background
HCFA, now CMS (Center for Medicare and Medicaid Services) issued guidelines for documentation of different service codes in 1995. They were revised in 1997. Either can be used.
In general, the 1995 guidelines are more favorable for General Internists.
This presentation will focus on 1995 guidelines.
Why should we care? Individual Benefits
•Thought vs. Action: General IM reimbursement traditionally lower than procedure-based specialties
•Getting paid for what we do - reimbursement for practice groups and individuals can increase
•“Playing the game” vs. “Changing the game”
Disclaimer
This presentation will provide basic information regarding documentation and coding. Before applying this information at your institution or practice site, YOU MUST CHECK WITH YOUR COMPLIANCE OFFICE or LOCAL MEDICARE CARRIER to be sure these general principles are appropriate for your practice situation.
Learning Objectives Review documentation requirements
for basic outpatient office visits, including Annual Exams
Learn efficient documentation of Medical Decision Making
Discuss appropriate use of Office Consultation by General Internist
Gain comfort in coding levels 3, 4, 5 return office visits
Basic CodingRules and Regulations
New vs. Return
A new patient has not received professional services from you or a member of your group in any service location (e.g. hospital) in the past 3 years
Multi-specialty groups: variable
If established patient has not been seen in 3 years, bill them as New
Elements for E&M visits History
• Chief Complaint (CC)• History of Present Illness (HPI)• Review of Systems (ROS)• Past, family, and social history (PFSH)
Exam• Number of organ systems (1995
guidelines) Medical Decision Making (MDM)
• # diagnoses or management options• Amount of data/complexity• Risk level to patient
New Patient- outpatient visit3/3 needed
CPT 99201 99202 99203 99204 99205HPI
ROS
PFSH
1 1
1
4
2
1
4
10
3
4
10
3
Exam 1 2 5 8 8
MDM Straight-forward
Straight-forward
Low Moderate
High
Time
(min)
10 20 30 45 60
New Outpatient Visit
Need 3 of 3
99201 99202
99203
99204 99205
History (need all) HPI ROS PFSH
1 11
421
4103
4103
Exam 1 2 5 8 8
MDM (2/3) #Dx Data Risk
10No meds
10No meds
221 stable prob
1new no w/uor 3 stable 3Prescription medOr 2 stable pr.
1new w W/U or 2 worse4Life threaten
Time if counseling is >50%
10 min 20 30 45 60
Elements for E&M visits History
• Chief Complaint
• History of Present Illness (7)
Location
Quality
Severity
Duration
Timing
Modifying Factors
Associated signs and symptoms
Elements for E&M visits History
• Chief Complaint
• History of Present Illness
• Review of Systems (14) Constitutional-fever/wt
Eyes
Ears/nose/mouth/throat
CV
Respiratory
GI
GU
Musculoskeletal
Skin
Neurologic
Psychiatric
Endocrine
Heme/lymphatic
Allergic/immunologic
Elements for E&M visits History
• Chief Complaint
• History of Present Illness
• Review of Systems
• Past, Family, and Social History
−Past Medical History
−Family history
−Social history
Pearls for documenting History
Can refer to previously documented elements: “Problem list updated as part of today’s visit”
“All other systems reviewed and negative” may be used in most cases to document negatives.
Taking history from someone other than the patient increases level of medical decision making.
Single bullets satisfy PFSH requirements - does not need to be exhaustive
Elements for E&M visits History
Exam
• # of organ systems (12) Constitutional-VS,
general appearance Eyes Ears, nose, mouth,
throat Cardiovascular (inc
edema) Respiratory GI
GU Musculoskeletal Skin Neurologic Psychiatric Heme/lymph/
immuno-logic
Physical Exam
How many organ systems can you document before you lay a stethoscope on your patient??
Physical Exam SEVEN!!
• General appearance
• Eyes - sclera anicteric/injected
• HENT - hearing intact (hard of hearing)
• MSK - normal gait/limping
• Psych - normal (depressed/flat) affect
• Skin - no rash on face, arms
• Immunologic - NKDA (use for PMH or PE)
Coding New Patient Visits
Need 3 of 3 elements documented (history, exam, decision making)
MDM and MEDICAL NECESSITY SHOULD DRIVE CODING
MDM and MEDICAL NECESSITY SHOULD
DRIVE CODING
Coding Return Patient Visits Only need 2 of 3 elements
documented to meet level of service coded (History, PE, MDM)
MDM and MEDICAL NECESSITY STILL DRIVE CODING
Return Patient- outpatient visit2/3 needed
CPT 99211 99212 99213 99214 99215HPI
ROS
PFSH Non-physician visit
1-3
None
None
1-3
1
none
4+
2-9
1
4+
10+
2
Exam
1 system
2-4 systems
5-7 systems
8+ systems
MDM
Straight-forward
Low Moderate
High
Time
10 min 15 min 25 min 40 min
Return Outpatient Visit
Element(Need 2 of 3)
99212 99213 99214 99215
History HPI ROS PFSH
1 11
4 (or 3 chronic)21
4 (or 3 chronic)10 (“o/w neg”)2
Exam (# systems)
0 2 5 8
Complexity(need 2 of 3)
Dx Data
Risk
1 prob
0
No meds
2 est prob-stable or1 est prob-worse2
1 stable prob
3 stable est prob or1 new, no w/u
3Prescriptn med or 2 stable prob
2 prob-worse or 1 new, w/u 4Severe side effects, DNR
Time if counseling is >50%
10 min 20 30 45
DocumentingMedical Decision
MakingThe Real Meat of Internal
Medicine
Medical Decision Making
Diagnoses
Data
Risk
Medical Decision Making Number of diagnoses
• Number and type of presenting problems
Amount/complexity of data reviewed• Ordering tests and reviewing of tests
• Obtaining records or history from others
Overall risk of complications to patient before seeing another medical professional• See “Table of Risk”
Number of Diagnoses Self-limited or minor: 1 point each (2 max)
Established problem, stable: 1 point
Established problem, worsening: 2 points
New problem, no addt’l workup: 3 points
New problem, with further workup: 4 points
Complexity (and thus level of service)
• Straight-forward=1; Low=2, Moderate=3, High=4
Amount and Complexity of Data Review and/or order of clinical test: 1 point
• Basically all labs
Review and/or order of radiology: 1 point Review and/or order of medical test: 1 point
• Includes vaccines, ECG, echo, PFTs
Discussion of test with performing MD: 1 point
Independent review of test: 2 points Old records or hx from another person
• Decision to do this: 1 point
• Doing it and summarizing: 2 points
Overall Risk Table
Learn and Love the overall risk table
3 categories: presenting problem, dx procedures, management options
Highest level of risk in ANY of the 3 categories is the overall risk level for that patient
Overall Risk Table
Pearls:
•Prescription drug management: moderate
•2+ stable chronic illnesses: moderate
•Abrupt mental status change: high
•1 chronic illness w/ severe exacerbation: high
Overall Decision Making TableNeed 2 of 3 elements to qualify for given levelType of MDM
Straight-forward99201/02
99212
Low9920399213
Moderate9920499214
High9920599215
# dx 1 2 3 4+
Amt data
0 or 1 2 3 4+
Overall Risk
minimal low moderate high
Counseling, Annual Exams
and Office Consultation
Counseling When time spent counseling >50% of total
visit, then TIME becomes the deciding factor for coding
Total billing physician face to face time
• 99213: 15 min
• 99214: 25 min
• 99215: 40 min
Must document time spent and reason for counseling
Counseling is:• “A discussion with the patient and/or family
concerning one or more of the following areas” CPT book
• Recommended tests, diagnostic results, impressions
• Prognosis• Risks/benefits of treatment (management)
options• Instructions for treatment (management) options
and follow up• Importance of compliance with treatment
(management) options• Risk factor reduction• Patient and family education
Preventative Service Visits NO Chief complaint or HPI
MUST HAVE• Comprehensive ROS (10 organ systems)• Comprehensive or interval PFSH• Comprehensive assessment of risk factors
appropriate to age• Multi-system physical exam appropriate to
age and risk factors (RF)• Assessment/Plan which includes
counseling, anticipatory guidance and RF reduction
Preventative Service Visits
New vs. Return rules are the same
Coding based on age of patient
NO specific guidelines for what to include with each age group
Documentation of anticipatory guidance/risk factor reduction is the common missing element
Can refer to previous ROS, PMH, FH, etc.
Outpatient Consultation
Consultations require:
•A request from another provider•The provision of a consultation evaluation
service•A report of the service to the requesting
provider
Simply put, one provider asks a question, and the consultant answers it.
Consultation Requirements
New CMS requirements as of Jan 2006:
The written request for a consultation must be included in the requesting provider’s plan of care.
A consultation request may be written on an order form in a shared medical record.
The consultant must also document the reason for the consultation.
The “Question” must be documented in 2 medical records
Consultation Requirements
The written report may be part of a common medical record or in a separate letter to the requesting provider and must be readily available.
The written report must include the findings and recommendations (the “answer” to the original provider’s question.)
The consultant is expected to have expertise beyond that of the requesting provider.
Coding Outpatient Consultations CPT codes 99241-99245
Documentation requirements are identical to New Patient visit codes
Outpatient Consult F/U codes were deleted in Jan 2006
Pre-Operative Consultations
This is the most common scenario for a General Internist
You CAN bill Consultation on an established patient, as long as all the criteria are met
CMS rules state: “a pre-operative consultation at the request of a surgeon is payable if the service is medically necessary and not routine screening.”
Pre-Operative Consultations Following a pre-operative consultation,
if the same MD/NPP assumes responsibility for management of all or part of the patient’s care postoperatively, the subsequent visit codes must be used.
• Example – IM performs preop consult for patient prior to surgery; surgery occurs and surgeon requests IM inpatient MD to provide post operative care, in this scenario the inpatient IM MD cannot bill a second consult.
Second Opinions - Outpatient
For 2nd opinion evaluations in the outpatient or office setting, report the appropriate Office or other outpatient codes (new or established patient) for the level of service performed.
Confirmatory Consultation codes were deleted in Jan 2006
Consults Within a Group
Payment will continue to be made for a consultation if a provider in a group practice requests a consultation from another MD in the same group practice when the consulting MD has expertise in a specific medical area beyond the requesting professional’s knowledge.
You have the Basics
Let’s apply them to some real cases!
Case #1
CC: 55 yo woman (known to you) presents with back pain
Level 3, 4, or 5?
Depends on:•medical necessity•what is done•what is documented
Case #1
CC: 55 yo woman (known to you) presents with back pain
HPI• Patient awoke 1 week ago with constant,
sharp, moderately-severe LBP assoc w/ intermittent spasms. Improves w/ ibuprophen. Remote history of similar sx. No trauma, fevers, weakness, bowel or bladder sx.
Case #1 (cont’d)
Exam • Gen: BP 110/60 • Back: lumbar paraspinous tenderness
Assessment• LBP, probably muscular
Plan• Continue ibuprofen• Begin cyclobenzaprine 10mg TID prn• Return in 2 weeks if not better, sooner
prn
Outpatient Established PatientElement
(need 2 of 3)99211
99212 99213 99214 99215
History HPI ROS PFSH
Min. prob. may
1 11
4 (or 3 chronic)21
4 (or 3 chronic)102
Exam* # systems
not 0 2 5 8
Complexity (2/3) Dx Data Risk
needMD
10No meds
221 stable prob
3 (1 new no w/u)3Prescription medOr 2 stable pr.
4 (1 new w/ W/U)4Life threaten
Time (≥50%counsel’g)
5 10 15 25 40Hx: location, quality, severity, duration, timing, modifying factors (or status of 3)
*Exam: ’95 audit tool definitions (’97: 6 bullet points 99214 and 12 bullet points 99215)
Dx: est prob-stable 1; est. prob-worse 2; new-no W/U 3(max3); new prob W/U 4
Data: lab 1; xray 1; other 1; disc w/testing MD 1; decision to review records/hx 1; review old records/hx from non-pt 2; discuss w/ another provider 2; independent review test 2
Outpatient Established PatientElement
(need 2 of 3)99211
99212 99213 99214 99215
History HPI ROS PFSH
Min. prob. may
1 11
4 (or 3 chronic)21
4 (or 3 chronic)102
Exam* # systems
not 0 2 5 8
Complexity (2/3) Dx Data Risk
needMD 1
0No meds
221 stable prob
3 3Prescription medOr 2 stable pr.
4 (1 new w/ W/U)4Life threaten
Time (≥50%counsel’g)
5 10 15 25 40Hx: location, quality, severity, duration, timing, modifying factors (or status of 3)
*Exam: ’95 audit tool definitions (’97: 6 bullet points 99214 and 12 bullet points 99215)
Dx: est prob-stable 1; est. prob-worse 2; new-no W/U 3(max3); new prob W/U 4
Data: lab 1; xray 1; other 1; disc w/testing MD 1; decision to review records/hx 1; review old records/hx from non-pt 2; discuss w/ another provider 2; independent review test 2
Case #1 - Modification AMore Documentation
Add reference to PFSH (PMH, FH, or SH)
• “Problem list and medications reviewed, see summary page” OR
• 50 yo woman with HTN OR
• 50 yo non-smoker OR
• Patient with NKDA OR
• Meds-Premarin
Outpatient Established Patient
Element(need 2 of 3)
99211
99212 99213 99214 99215
History HPI ROS PFSH
Min. prob. may
1 11
4 (or 3 chronic)21
4 (or 3 chronic)102
Exam # systems
not 0 2 5 (or Detailed)
8
Complexity (2/3) Dx Data Risk
needMD 1
0No meds
221 stable prob
3 3Prescription medOr 2 stable pr.
4 (1 new w/ W/U)4Life threaten
Time (≥50%counsel’g)
5 10 15 25 40
Hx: location, quality, severity, duration, timing, modifying factors (or status of 3 chronic)
Exam: Check with compliance or local Medicare intermediary for their rules re: detailed
Dx: est prob-stable 1; est. prob-worse 2; new-no W/U 3(max3); new prob W/U 4
Data: lab 1; xray 1; other 1; disc w/testing MD 1; decision to review records/hx 1; review old records/hx from non-pt 2; discuss w/ another provider 2; independent review test 2
Case #1 - Modification BMore Complexity
Now consider if the patient has a T:102.1 Additional history:
• PFSH: “non-smoker”
• ROS: “complete 10 organ ROS o/w negative”
No change in exam Additional workup:
• Will order CBC, urgent MRI lumbar spine, discuss with spine surgeon
• “Concern for epidural abscess”
Outpatient Established PatientElement
(need 2 of 3)99211
99212 99213 99214 99215
History HPI ROS PFSH
Min. prob. may
1 11
4 (or 3 chronic)21
4 (or 3 chronic)102
Exam # systems not 0 2 5 8
Complexity (2/3) Dx Data Risk
needMD 1
0No meds
221 stable prob
3 3Prescription medOr 2 stable pr.
44Life threaten
Time (≥50%counsel’g)
5 10 15 25 40Hx: location, quality, severity, duration, timing, modifying factors (or status of 3 chronic)
Exam: Check with compliance or local Medicare intermediary for their rules re: detailed
Dx: est prob-stable 1; est. prob-worse 2; new-no W/U 3(max3); new prob W/U 4
Data: lab 1; xray 1; other 1; disc w/testing MD 1; decision to review records/hx 1; review old records/hx from non-pt 2; discuss w/ another provider 2; independent review test 2
Case #2 60 yo male presents for 3 month f/u visit
for HTN, AODM. Also reports mild fatigue and some leg cramps, occurring 2-3 times per week. BP better since addition of HCTZ at last visit. Sugars running <160. Pt denies CP, SOB, LE edema.
Meds updated in problem list PE: BP:138/80 HR:75 RR:16 Gen: looks well CV: RRR, no m,r,g Lungs: Clear Ext: no edema, no calf tenderness to
palpation
Case #2 (cont’d)
A/P: 1. HTN, well controlled, continue same meds
2. AODM, well controlled, continue meds/diet, exercise, check HgA1c
3. Leg cramps- possible low K, check BMP, Mg.
F/U in 3 months
Case #2 (cont’d) 60 yo male presents for 3 month f/u visit for HTN,
AODM. Also reports mild fatigue and some leg cramps, occurring 2-3 times per week. BP better since addition of HCTZ at last visit. Sugars running < 160. Pt denies CP, SOB, LE edema. 2 chronic problems, stable and 1 new; 5 HPI 3ROS
Meds updated in problem list 1 PFSH level 4 Hx PE: BP:138/80 HR:75 RR:16 Gen: looks well CV: RRR, no m, r, g Lungs: Clear 4PE level 3 Exam Ext: no edema, no calf tenderness to palpation
Case #2 (cont’d) A/P: 1. HTN, well controlled, continue
same meds
2. AODM, well controlled, continue meds/diet, exercise, check HgA1c
3. Leg cramps, fatigue - possible low K, check BMP, Mg. F/U in 3 months
Moderate MDM: diagnoses-high; data-low; risk- moderate
99214 (count History and MDM)
Final thoughts
The coding rules initially appear complex but can be mastered.
It takes some practice.
Use these tools to “self-audit.”
It is your responsibility to select the right code for the work that you do.