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TRANSCRIPT
5/9/2014
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Reaching Full Potential:
Quality Assurance and Improvement with Visit Documentation
Beatriz ReyesTraining Manager, Cardea-Oakland, CA
Karen Shiu, MPHData/Training Manager, Cardea-Oakland, CA
Ann FinnOwner/Healthcare Consultant, Ann Finn Consulting-Niskayuna, NY
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Cardea
Our Services
Training – Organizational Development – Research and Evaluation
Our Mission
Improve organizations’ abilities to deliver accessible, high quality, culturally proficient, and compassionate services to their clients.
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STD-related Reproductive Health
Training & Technical Assistance Center
Funded by a cooperative agreement by the Office of Population Affairs, within the Office of the Assistant Secretary for Health in collaboration with the Division of STD Prevention within the Centers for Disease Control and Prevention,
National Center for HIV/AIDS, Viral Hepatitis, STD and TB Prevention.
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5/9/2014
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Setting Up for Success: Integrating Revenue Cycle Management
Tuesday, February 25, 2014 Recording available now!
Reaching Full Potential: Quality Assurance and Improvement with Visit Documentation
Wednesday, April 30, 2014
Bringing It All Together: Sustaining and Enhancing Billing and Reimbursement Efforts
Thursday, June 26, 2014
Billing & Sustainability Series:Implementation and Improvement Strategies
for STD and Other Public Health Programs
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Disclaimer
The content provided in this presentation is intended for educational purposes only. It is not intended to serve as medical, health, legal or financial advice, or as a substitute for professional advice of a medical coding professional, health care consultant, physician or medical professional, legal counsel, accountant or financial advisor.
Cardea encourages providers to contact third-party payors for specific information on their coding, coverage, and payment policies.
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Learning Objectives
By the end of this webinar, participants will be able to:
• Discuss the importance of QI/QA in billing forSTI and other related services.
• Identify strategies for improving and assuring the quality of billing-related activities such as client visit documentation.
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Revenue Cycle Management Continuum
Cardea adapted the Transtheoretical Model of behavior change, or Stages of Change, developed by Drs. Prochaska and DiClemente, to identify benchmarks of organizational capacity building for revenue cycle management.
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What is the Revenue Cycle?
A. The billing of third-party payors to collect patient service revenues.
B. The administrative and clinical functions that contribute to the capturing, management, and collection of patient service revenues.
C. The managing of claims and payments to/from third-party payors for patient services.
Participant Poll
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What is the Revenue Cycle?
A. The billing of third-party payors to collect patient service revenues.
B. Administrative and clinical functions that contribute to the capturing, management, and collection of patient service revenues.
C. The managing of claims and payments to/from third-party payors for patient services.
Participant Poll
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Revenue Cycle
Front End
Pre-Visit
Intermediate
Visit
Back End
Post-Visit
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Revenue Cycle
Front End
Pre-Visit
Intermediate
Visit
Back End
Post-Visit
Front EndPre-Visit
Steps to collect client info, determine fees, and communicate payment policies prior to the provision of services.
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Revenue Cycle
Front End
Pre-Visit
Intermediate
Visit
Back End
Post-Visit
IntermediateVisit
Documentation and coding of services provided
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Revenue Cycle
Front End
Pre-Visit
Intermediate
Visit
Back End
Post-Visit
Back EndPost-Visit
Steps to bill, collect, and track payments for services
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Quality Improvement v. Assurance
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Quality Improvement v. Assurance
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Quality Improvement
• A philosophy or approach• Focuses on systems and processes
• Assumes the system, and not the individual, is the root of most problems
• Driven by staff and clients
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Quality Improvement v. Assurance
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Quality Improvement
• A philosophy or approach• Focuses on systems and processes
• Assumes the system, and not the individual, is the root of most problems
• Driven by staff and clients
Quality Assurance
• A specific activity• Focuses on policies, procedures, tasks, and compliance checks
• Seeks to identify problems and make corrections
• Driven by management
This Webinar Will Cover…
• Compliance in documenting and coding for STIs and other related services
• Integrating QI/QA
• Review of codes, functions, and resources
• Review of the most common errors and best practices
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Revenue Cycle
Front End
Pre-Visit
Intermediate
Visit
Back End
Post-Visit
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Intermediate Processes
Adapted from the Elements for Successful Immunization Billing Practice at New York State’s Local Health Departments, June 2012
Data Capture
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Intermediate Processes
Adapted from the Elements for Successful Immunization Billing Practice at New York State’s Local Health Departments, June 2012
Data Capture
ProvidersProviders, Back office staff-coders, Billing
agency, etc.
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Intermediate Processes
Adapted from the Elements for Successful Immunization Billing Practice at New York State’s Local Health Departments, June 2012
Documentation of Medical Services
(Charge Data Capture)
Medical services recorded
Data Capture
ProvidersProviders, Back office staff-coders, Billing
agency, etc.
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Intermediate Processes
Adapted from the Elements for Successful Immunization Billing Practice at New York State’s Local Health Departments, June 2012
Documentation of Medical Services
(Charge Data Capture)
Medical Service Coding
(Charge Data Entry)
Medical services recorded
Services translated to diagnosis and procedures codes
Data Capture
ProvidersProviders, Back office staff-coders, Billing
agency, etc.
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KEY PIECES TO ENSURE COMPLIANCEQA/QI
Teamwork
Forms & data capture
Documentation & appropriate coding
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Compliance and QI/QA
Compliance Requirements
Quality Improvement
Quality Assurance
Changes
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Ex: Performance Evaluation
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Who is the OIG?
Office of Inspector General (OIG)
• Mission to protect the integrity of Department of Health & Human Services.
• At the forefront of the Nation's efforts to fight waste, fraud, and abuse; and to promote economy, efficiency, and effectiveness in Medicare, Medicaid, CDC, NIH, and the FDA.
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What is a Compliance Program?
Why Should I Create One?
A set of internal policies and procedures that you put in place to help your organization comply with the law.
- Office of Inspector General
An effective compliance program:• Enhances an organization's operations• Improves quality of care• Reduces overall costs• Helps identify and address problems before they become
systemic and costly
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1. Foster a culture of compliance:• Support with sufficient resources and commitment
o Bring up compliance issues in staff meetingso Reward staff that have brought up compliance issueso Create a compliance team or hire a compliance officer
8 Tips For Implementing Effective
Compliance Programs
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8 Tips For Implementing Effective
Compliance Programs
2. Create written policies, procedures and standards of conduct:
• Policies should be specific to each job type• Policies should be current and updates – USE THEM!• Send policies via email, or leave in common areas• Create a policy on the query process
o A query is a question posed to a provider to obtain additional, clarifying documentation to improve the specificity and completeness of the data used to assign diagnosis and procedure codes in the patient’s health record1
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2. http://library.ahima.org/xpedio/groups/public/documents/ahima/bok1_040394.hcsp?dDocName-bok1_040394
8 Tips For Implementing Effective
Compliance Programs
3. Conduct effective training and education• Stay current• Be creative on how trainings are delivered• Learn from your mistakes
4. Promote Communication• Be visible• Be approachable
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8 Tips For Implementing Effective
Compliance Programs
5. Take appropriate corrective actions; investigate promptly
• Involve staff that understands the issues at hand
6. Track resolutions of complaints• What were the corrective actions taken?• What were the outcomes?
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8 Tips For Implementing Effective
Compliance Programs
7. Conduct regular internal audits (QA)• Identify risk areas to pay attention to during audits
o For example: coding
• Define the scope of the audit, whether it’s scheduled or a surprise
8. Review compliance program (QA)• Are benchmarks and goals being met?
o Are benchmarks and goals updated to reflect changes in payment reforms and quality standards?
• Are corrective actions sufficient?
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Staff must be able to communicate in order to ensure complete and compliant billing…but how?
Articulate connections across job functions
Billing is a Team Effort
Adapted from Kern County Department of Public Health Services
Provider Provide servicesRecord services
provided: Documentation
Cashier Charge captureCollect fees, copays
BillerBill third-party
payorsMonitor receivables, follow-up on denials
Make corrections,resubmit bills
Bill Paid
Coder
Apply codes to the services in the medical
record
Apply codes to the services documented in the medical record
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Billing is a Team Effort
Adapted from Kern County Department of Public Health Services
Provider Provide servicesRecord services
provided: Documentation
Cashier Charge captureCollect fees, copays
BillerBill third-party
payorsMonitor receivables, follow-up on denials
Make corrections,resubmit bills
Bill Paid
Coder
Apply codes to the services in the medical
record
Apply codes to the services documented in the medical record
Questions about documentation
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Billing is a Team Effort
Adapted from Kern County Department of Public Health Services
Provider Provide servicesRecord services
provided: Documentation
Cashier Charge captureCollect fees, copays
BillerBill third-party
payorsMonitor receivables, follow-up on denials
Make corrections,resubmit bills
Bill PaidCoder
Apply codes to the services in the medical
record
Apply codes to the services documented in the medical record
Questions about codes; Additional Information
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Billing is a Team Effort
Adapted from Kern County Department of Public Health Services
Provider Provide servicesRecord services
provided: Documentation
Cashier Charge captureCollect fees, copays
BillerBill third-party
payorsMonitor receivables, follow-up on denials
Make corrections,resubmit bills
Bill PaidCoder
Apply codes to the services in the medical
record
Apply codes to the services documented in the medical record
Questions about codes; Additional Information
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Questions
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Participant Poll
Does your agency have a compliance plan for client visit documentation?
A. Yes, we have a compliance plan specifically on client visit documentation.
B. Kind of, we have a compliance plan for billing that includes client visit documentation.
C. No, we do not have a compliance plan on client visit documentation.
D. I don’t know.
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FORMS, DOCUMENTATION, AND
CODINGForms and data collection
Documentation
Types of Codes
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Encounter Form
Encounter Forms, Super bills, or Charge Slips serve as a method of communication between providers, office staff, and payors.
Encounter form components:• Time of appointment• Reason for visit• Findings, diagnosis• Treatment, diagnostic tests, counseling• Resources and Referrals • Supplies• Drugs and injections (with lot # and units)• Interpreter/language lines
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Forms, Forms, Forms
Encounter forms should be:• User friendly – clinical and billing • Comprehensive• Easy to prioritize diagnoses• Accurate American Medical Association(AMA) code
descriptions• Space for modifiers, quantity & special instructions
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Electronic Medical Record
Concerns:
• Copying and pasting documentation• Auto assigned codes• Drop down list edits• Over-clicking of check boxes• Missing documentation • Electronic signature and authentication• Vendor response to updates
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Methods for Documentation
and Their Definitions
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Why is Proper Documentation
Important?
Proper Documentation…• Improves compliance • Improves patient care • Improves clinical data for research and education • Protects the legal interest of the patient, facility and
clinician• Enables proper reimbursement for services performed
Providers fill out the encounter form, coders/billers shouldn’t change the encounter form!
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ICD-9-CM Diagnosis Codes – “Why”
• International Classification of Diseases, 9th edition, Clinical Modifications (ICD-9 CM)
• Set of codes defining diseases, signs, symptoms, abnormal findings, complaints, social circumstances, and external causes of injury or disease
• Supports medical necessity of services/procedures provided
• Supported by documentation in patient’s medical record
• Only the licensed provider determines the diagnosis
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Procedure Codes – “What”
Current Procedural Terminology (CPT) 4th edition is a set of codes, descriptions, and guidelines intended to describe procedures and services performed by physicians and other health care professionals, or entities.
• Maintained by the American Medical Association (AMA)• Each procedure or service is identified with a five-digit
code• Every service provided relates to a CPT code including
E/M’s, device implants, lesion removals, lab tests, immunizations, etc.
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Procedure Codes – “What” Continued
Healthcare Common Procedural Code System (HCPCS)
• All CPT codes are HCPCs codes, but not all HCPCS codes are CPT codes….say what?o Level 1 HCPCS – Based on and identical to CPT codeso Level II HCPCS – Identify products, supplies, materials and
services which are not included in CPT-4 codes� Devices, drugs
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Modifiers
Two digit codes that accompany a CPT code in order to further describe a situation that may impact or modify reporting and reimbursement of services
• Some modifiers are assigned by the clinician during thevisit and some may be added during billing
• Only certain modifiers impact payment • Payers may treat modifiers differently
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Our Codes Tell The Story
• To establish medical necessity, for every what there must be a why.
• Unusual circumstances explained with modifier.
Encounter Content Code Book
Why • Diagnoses • ICD-CM
What • Services Performed• Drugs, Supplies
provided
• CPT• HCPCS
o level I – Serviceso level II - Drugs/Supplies
AdditionalExplanation
• Modifiers • CPT
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Evalua<on and Management―E/M
• E/M is when provider evaluates a client’s condition and decides on a course of treatment to manage it
• Requires selection of CPT code that best represents:o Patient typeo Setting of service
(Office, Outpatient, Inpatient, Emergency department)o Level of service
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Patient Type
New Patient• “One who has not received any professional services from
the physician, or other qualified healthcare professionals or another physician of the exact same specialty and sub-specialty who belongs to the same group practice, within the past 3 years”
Established Patient• Within 3 years
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Types of E/M Visits
• Preventive Medicine Services• Consultations• Preventive Medicine Counseling• Problem-Focused Visits
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E/M: Problem-Focused Visits
Services to evaluate patients with a problem or chief
complaint in the outpatient clinic setting• New patients 99201-99205
• Established patients 99211-99215
• Examples: Routine contraceptive surveillance, family
planning counseling and education, contraceptive problems,
suspicion of pregnancy, STI testing and treatment, and
evaluation of other reproductive system symptoms
Lisa, a return patient, meets with the NP to be
evaluated and tested for STIs including an exam
and counseling. Her visit might be reported as
99213…
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Documenting Problem-Focused
Medical Visits
• Composite of Three Key Components Method
• Time Counseling
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“Composite of 3 Key Components” Method
History
• Chief Complaint• History of the present illness (HPI) – e.g., severity, duration, etc.• Review of body systems (ROS) – e.g., respiratory, constitutional• Past, family, social history (PFSH) – e.g., previous illness, hereditary diseases, and physical activities, alcohol and drug use
Physical Exam
• Multiple organ system examination
Medical Decision Making
• Number of possible diagnosis and management options• Amount and complexity of medical record, lab work/diagnostic tests, etc.• Amount and complexity of disease(s)
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About the Chief Complaint…
Concise statement describing the symptom, problem, condition, diagnosis, or other factor that is the reason for the patient encounter, usually stated in the patient’s own words
• Should be clearly reflected in the medical record• Front desk should not be filling this in prior to visit
Required for problem-focused visits!
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“Time Counseling” Method
Time can be used when:
• At least 50% of clinician’s total Face-to-Face (FTF) time with patient is spent on counseling / coordination of care
• Criteria of an E/M must still be met
MUST document in the Medical Record:
• Total duration of encounter
• At least 50% of time is spent counseling
• Nature and extent of the issues discussed, client questions and physician response, and recommendations or next steps
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Summary: Problem-Focused E/M
• Choose E/M based on scores of 3 key componentso History, Physical exam, MDM
• Compute counseling time as a percentage of total
FTF timeo If >50%, find E/M based on documented time factor
• Select the E/M code that is greater: 3 key
components or face-to-face time
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KEY POINTS FOR ACCURATE
DOCUMENTATION AND CODING
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Common Errors
1) Missed charges / inaccurate and outdated codes2) E/M code not supported in documentation –
template driven3) Documentation specificity lacking4) Improper modifier usage5) Time not captured for related codes6) Diagnosis coding – specificity and sequencing7) Medical necessity not supported8) Patient need vs. Provider level not matched9) Team work – accountability not fostered
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1 – Missed Charges / Inaccurate Codes
Missing, inaccurate and outdated codes reduce reimbursement
QI/QA:
• Ensure every service is matched to a CPT code• Correct codes to describe acuity and site• Descriptions should be accurate and not abbreviated and
misleading• Internal chart to bill audits
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QI/QA: Outdated Codes
• Assign updates - Review committee or staff role
• Periodically review client encounter forms/templates to ensure ICD/CPT codes are up-to-date and complete to reflect all services provided
• ICD updated (Oct 1 by WHO), CPT (Jan 1 by AMA)
o Summaries of updates in Appendix B of the CPT manual and at the front of the ICD manual
• Delete the clutter
• Have space for clinicians to write in additional codes as needed
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QI/QA: Missed Charges
• Capture all services in addition to the main service:o Ancillary Lab Tests / Radiology – In-house vs. Send-out
o Expanded Hours Access – Nights and Weekends
o Interpreter Services
o Smoking Cessation Counseling
o Screening, Brief Intervention, and Referral to Treatment (SBIRT)
o Vaccines / Immunizations
• Understand services provided and what payors will reimburse
• Negotiate payment for relevant services when setting up contracts
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QI/QA: Code Specificity
• Procedures have different CPT codes than E/M services
• Lesion removals - document location and intensity
• An E/M is not always billed when performing a procedure – only if separate and distinct
CPT Description – Partial listing
17110 / 17111 Molluscum Destruction 1-14 / 15+
46900 / 46924 Destruction of anal lesion(s); Simple / Extensive
54050 / 54065 Destruction of penis lesion(s); Simple / Extensive
56501 / 56515 Destruction of lesion(s), vulva; Simple / Extensive
57061 / 57065 Destruction of vaginal lesion(s); Simple / Extensive
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2 – E/M Coding Not Supported
• E/M level billed is not supported in the medical record documentation
• Clinician does not fully grasp E/M coding guidelines and assignment
• Multiple distinct issues addressed but not documented or billed – “oh by the way…”
• Templates drive E/M assignment vs. documentation
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QI/QA: E/M Coding
• Can an outside reviewer get to the same E/M code by following your documentation?
o Risk for audit is higher when distribution of codes within a practice doesn't look reasonable
o If a single code is predominant in a clinician’s profile, assumption may be clinician isn't really coding for individual encounters
• Review templates-ensure key components and time are addressed
• Internal audits on regular basis
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QI/QA: E/M Profiling
• Compare clinician / service type coding and volumes internally and with relevant benchmarks to identify vulnerabilities and potential revenue leakage
• Discuss findings with team
• Reinforce with education
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3 – Documentation Specificity Lacking
Documentation drives compliant coding
If it isn’t documented (and readable) – it can’t be coded and billed
QI/QA:
• ALWAYS follow coding guidelines
• Revise forms to ensure key documentation elements of services are included and in sequential order of the visit
• Look for cut and paste trends
• Internal audits - education
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QI/QA: Documentation
• AutomateAllows clinicians to quickly capture all charges, promoting timely, accurate reimbursement
• Speech Recognition Software Allows clinicians to dictate directly into patients’ charts, enabling them to include all pertinent information while it is fresh
• Rules-based EditsAlert staff of where errors may exist, allowing organizations to audit all accounts and avoid inaccurate or missed charges
• Late ChargesTrack by department - resolve root causes
• Clinical Documentation SpecialistsEmploy to serve as liaisons to coders and clinical staff, improving communication, completeness and specificity of documentation
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10 Principles of Documentation
1) Medical record (MR) should be complete and legible
2) Documentation of each patient encounter should include:
• Date
• Reason for encounter
• Appropriate history and physical exam in relationship to the patient’s chief complaint
• Review of lab, x-ray data and other ancillary services, where appropriate; assessment
• Plan for care
3) Past and present diagnoses should be accessible to the treating and/or consulting physician
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10 Principles of Documentation con’t
4) Reasons for and results of x-rays, lab tests and other ancillary services should be documented or included in the MR
5) Relevant health risk factors should be identified
6) Patient’s progress, including response to treatment, change in treatment, change in diagnosis, and patient non-compliance, should be documented
7) Written plan for care should include, when appropriate:
• Treatments and medications, specifying frequency and dosage;
• Any referrals and consultations;
• Patient/family education; and
• Specific instructions for follow-up
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10 Principles of Documentation con’t
8) Documentation should support the intensity of the patient evaluation and/or the treatment, including through processes and the complexity of medical decision-making as it relates to the patient’s chief complaint for the encounter
9) All entries to the medical record should be dated and authenticated
10) CPT/ICD codes billed should reflect the MR documentation
http://www.cms.gov/Outreach-and-Education/Medicare-Learning-Network-MLN/MLNProducts/downloads/eval_mgmt_serv_guide-ICN006764.pdf
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4 – Improper Modifier Usage
Modifiers can mean the difference between full
reimbursement and reduced reimbursement – or denial
QI/QA:
• Anytime you provide more than one service at a single
encounter, you must consider whether a modifier is needed
• Update forms / templates to prompt for modifiers
• Review NCCI edits and codes that require modifiers
• Review modifiers and applicable usages as a team
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5 – Time Not Captured
Certain CPT codes require time to be documented
• Problem-focused E/M level
• Preventive / behavior change counseling (99401-99409) (i.e. Smoking cessation, HIV counseling)
• Interpreter, evening hours
QI/QA:
• Review forms and ensure an easy method to capture elements needed – form should prompt clinician
• Should be part of the notes; encounter form/ superbill may not be included during audits
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6 – Diagnosis Coding
Specificity and Sequencing
• Is the primary reason for the visit your first-listed (primary) diagnosis code billed?
• Coding HIV and other STD diagnoses that have not been not confirmed by a screening test
• High risk sexual behavior with / without risk factors noted
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QI/QA: Diagnosis Coding
• Only the licensed Provider determines the diagnosis
• Ensure forms allow clinicians to sequence and mark diagnosis codes are co-equal – no circling!
• Ask site of exposure and document
• Hire certified or trained coders and billing staff
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QI/QA: Diagnosis Coding con’t
• Code is invalid if it has not been coded to the full
number of digits required for that code (5th digit if
possible)
• If diagnosis is not established, code the symptom
• Don’t code for:
o “Rule-out” diagnoses
o Conditions that were treated and no longer exist
o Diagnosis that doesn’t apply to the visit
• AIDS / HIV coding have specific ICD guideline rules
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Be Careful Assigning Codes …
Codes follow the patient long after the visit
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7 - Medical Necessity Not Supported
• Payors increasingly concerned about medicalnecessity
• Coding for services not provided is considered fraud
• Site of exposure not asked / documented for ordering appropriate screening tests – medical necessity
• May cause denials or future financial recoupment
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QI/QA: Medical Necessity
• Match each CPT code to a corresponding diagnosis before submitting
• Order ancillary tests keeping in mind risk factors and current guidelines
• Query clinician for incomplete codes – team work
• Billers should not be changing MR, need review process
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8 – Patient Need vs. Provider Level
Do your patients meet with the correct level of
provider to ensure clinic efficiency and accurate
reimbursement?
Nurse visits inappropriately billed
Lab tests for new patient with no FTF encounter
QI/QA:• Review services / provider type – staff assessment
• Reassign tasks where possible
• Scheduling and clinic flow analysis
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Nurse Visits – Often Overbilled
E/M 99211 if state and payor allow for it
• Documentation supports medical necessity
• Must be an established patient
• Must be a face-to-face encounter
• Nature of presenting problem with diagnosis from prior MD visit
• Brief history of the problem
• Documentation of vital signs (sole reason for visit should not be Blood Pressure check or Blood Draw)
• Plan of care
• Date/signature of the nurse or other provider
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9 - Team work & Accountability
Successful organizations work together as a team
All roles from front end staff to billing are essential part of the revenue cycle
QI/QA:• If questions on documentation of services billed, coders
and billers should be encouraged to query the clinician• Clinician must be accessible to answer questions timely• Encourage meetings and opportunities to explore
questions and potential issues together• Encourage mentoring• Time and space to do your job well
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QI/QA Best Practices
Documentation:
• Complete and accurate
• Orders dated and signed?
• Required times captured?
• Charts reviewed on a regular basis?
• Clinicians available to clarify / answer questions?
• Easy access to valid codes which reflect actual services provided
Coding:
• Patient new or established?
• Type of E/M provided?
• Any surgical procedures?
• Labs and image studies ordered?
• Drugs administered or ordered?
• Supplies or devices used?
• Any modifiers needed?
• Appropriate diagnosis assigned and prioritized?
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QI/QA Best Practices
• Current coding guides• In-service training • Job aides or other
reference guides • “Lunch and Learn” sessions• External courses and
seminars, if available • Department meetings• Accessible bulletin board • Peer–to-peer learning• Job shadowing
• Use your data - create helpful reports
• Monitor / periodic reviews• Review / update internal
compliance plans• Provide feedback • Improve communication
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Questions?
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Resources by Cardea
• Billing and coding guide• Case studies on public health programs’ experiences
with third-party billing • Webinar recordings• Online learning tools• Request custom training and technical assistance
Visit our STDRHTTAC page: www.cardeaservices.org/ourwork/projects/stdrhttac
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Online Learning Community
Building Sustainability for Public Health ProgramsA project of Cardea’s STD-Related Reproductive Health Training & Technical Assistance Centers
www.cardeastdrh.groupsite.com
Community Foundation• Shared interest in strengthening revenue management
strategies and billing practices• Open to agencies at all stages of billing implementation• Sharing of experience, knowledge, and resources
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Online Learning Community Features
• Resource Library• Peer-to-peer discussion• Continued / follow-up learning from training and
technical assistance activities, including webinars• Access to exclusive training and learning
opportunities
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Setting Up for Success: Integrating Revenue Cycle Management
Tuesday, February 25, 2014
Reaching Full Potential: Quality Assurance and Improvement with Visit Documentation
Wednesday, April 30, 2014
Bringing It All Together: Sustaining and Enhancing Billing and Reimbursement Efforts
Thursday, June 26, 2014
Billing & Sustainability Series:Implementation and Improvement Strategies
for STD and Other Public Health Programs
Thank you!
Thank you!
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Contact Information
Beatriz ReyesTraining Manager, Cardea – OaklandEmail: [email protected]: 510-835-3700
Ann FinnOwner/Healthcare Consultant, Ann Finn Consulting LLCEmail: [email protected]: 518-522-8159
Karen Shiu, MPHData/Training Manager, Cardea – OaklandEmail: [email protected]: 510-835-3700
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Resource Page
Cardea Resources
• An online learning community to help you connect with peers and access resources
https://cardeastdrh.groupsite.com/login
• Webinars and other online learning tools (STDRH webpage) http://www.cardeaservices.org/ourwork/projects/stdrhttac
ICD- 10 Resources
• National Center for Health Statistics (NCHS)
http://www.cdc.gov/nchs/icd/icd10cm.htm
• Center for Medicare and Medicaid Services (CMS)
http://www.cms.hhs.gov/ICD10/01_overview.asp
• World Health Organization (WHO)
http://www.who.int/classifications/icd/en/
Office of Inspector General Resources
• Short and informative Podcasts
http://oig.hhs.gov/newsroom/video/2011/heat_modules.asp
• A variety of useful compliance tools and resources
http://oig.hhs.gov/compliance/
Topics include:
• RAT-STATS- a free statistical software package that providers can download to assist in a
claims review. The package, created by OIG in the late 1970s, is also the primary
statistical tool for OIG's Office of Audit Services. Among other tasks, the software assists
the user in selecting random samples and estimating improper payments.
• Compliance 101 and Provider Education
• Compliance Guidance
Centers for Medicare and Medicaid Services (CMS) Resources
• HCPCS general information
http://www.cms.gov/Medicare/Coding/MedHCPCSGenInfo/index.html?redirect=/MedHCPCS
Geninfo/
• Clinical Laboratory Improvement Amendments (CLIA)
http://www.cms.gov/Regulations-and-Guidance/Legislation/CLIA/index.html
• The Medicare Learning Network® (MLN) Educational Web Guides Documentation Guidelines for
Evaluation and Management (E/M) Services page offers health care professionals E/M services
information and resources.
http://www.cms.gov/Outreach-and-Education/Medicare-Learning-Network-
MLN/MLNEdWebGuide/EMDOC.html
• Medicare Coverage Center
http://www.cms.gov/center/coverage.asp
American Health Information Management Association (AHIMA)
• Best Practices for EHR Documentation
http://library.ahima.org/xpedio/groups/public/documents/ahima/bok1_050286.hcsp?dDocN
ame=bok1_050286
• Health Information Management (HIM) Trends and Topics
http://www.ahima.org/resources/default.aspx
Food and Drug Administration (FDA)
• Clinical Laboratory Improvement Amendments (CLIA)
http://www.fda.gov/MedicalDevices/DeviceRegulationandGuidance/IVDRegulatoryAssistanc
e/ucm124105.htm
American Medical Association (AMA)
• Current Procedural Terminology (CPT)
http://www.ama-assn.org/ama/pub/physician-resources/solutions-managing-your-
practice/coding-billing-insurance/cpt.page
Centers for Disease Control (CDC) • STD-related Reproductive Health, Prevention, Training, and Technical Assistance Centers
(STDRHPTTACs) overview
http://www.cdc.gov/std/stdrhpttac/default.htm
American Academy of Professional Coders (AAPC)
• Resource page from AAPC
http://www.aapc.com/resources/index.aspx
The American Academy of Family Physicians (AAFP)
• Information on Coding from the AAFP
www.aafp.org/online/en/home/practicemgt/codingresources.html
American Hospital Association (AHA)
• Coding Advice and Resources
http://www.aha.org/advocacy-issues/medicare/ipps/coding.shtml
National Association of County & City Health Officials (NACCHO) Toolbox
• Searchable, free, online collection of local public health tools produced by members of the
public health community on billing issues. http://www.naccho.org/toolbox/index.cfm?v=4&id=243&topicname=Billing
Other Resources • http://journals.lww.com/stdjournal/Abstract/2014/04000/Insurance_Among_Patients_Seeki
ng_Care_at_a.2.aspx
• HealthHIV's National Center for Healthcare Capacity Building is conducting a four part webinar
series for the enhancement of third-party billing systems to maximize revenues. This series is
intended for administrators and medical billing specialists.
http://www.healthhiv.org/modules/info/maximizing_third_party_reimbursement.html
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The questions listed below were submitted by participants during the February 25, 2014, webinar Setting Up for Success: Integrating Revenue Cycle Management. Time constraints prevented our team from addressing these questions during the event. The answers below were provided by the Multnomah County Health Department’s STD Clinic. They reflect the experience of that clinic and are not intended as medical, health, legal or financial advice.
Policies and Procedures Q: If a DIS client is brought back for retesting 3 months later (or even later than that), do you charge
the $20 flat fee again during that visit?
A: If the client returns for only a three month retest, then there is no charge. However, most clients end up receiving a full screen, and then are charged on the sliding fee scale.
Q: How do you manage fee collection with clients using Family Planning services through Title X if
they slide to $0?
A: The Multnomah County STD Clinic does not receive Title X funding. Q: How is it that you can decide to eliminate part of services based on ability to pay and risk level?
A: The process that we went through to allow us to require payment for low risk clients was to read the relevant Program Element (programmatic/ service deliverable) and interpret the Local Public Health Agreements (LPHA), review local epidemiology and CDC guidelines, review costs, and reach an understanding both within the county and with the State of what we will charge per client. We also continue to review expenditures and revenue to assess the ongoing impact of client charges. In Oregon, in consultation with the State, we were allowed to bill insurance and charge clients a nominal fee that does not cover all of our costs without changing the Program Element/LPHA. In some states, local health departments may need to change the LPHA prior to implementation.
Q: Why wouldn't you be billing the $20 charge to clients who have private insurance as well? What
happens if the insurance does not reimburse you?
A: Clients that agree to bill their private insurance will receive an explanation of benefits from their insurer. If the claim is denied or only partial payment is received, then the client will be charged on a sliding fee scale based on their Federal Poverty Level (FPL).
Q: Would a DIS client be the same as an STD client? Can you please share what is involved in a DIS
visit, for both the positive CT/NG/SPH, and for a contact?
A: A DIS client is defined as a case or contact to chlamydia, gonorrhea, syphilis, and/or HIV. DIS clients are charged a flat fee of $20, which includes the office visit, screening for CT/GC, RPR, and HIV, and treatment. DIS clients are not refused testing and treatment due to inability to pay. For more information on DIS, see the CDC website http://www.learnpartnerservices.org/.
Q: What are the qualifications of a DIS? Is a DIS a public health nurse, or an epi, or a hybrid of the
two? Are they MAs or Health Educators…?
A: Multnomah County employs five Disease Investigation Specialists (DIS) that receive training from the CDC. The majority of our DIS have a Bachelor’s degree, however that is not a requirement. For more information on DIS, see the CDC website http://www.learnpartnerservices.org/.
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Clinic Flow and Systems Q: How much more time does the expanded scheduling take? Have you experienced patients being
upset or resistant to process?
A: The average phone call takes 2‐5 minutes. We have options for non‐priority populations, such as our “Just Checking” (asymptomatic STD screening) or non‐priority clients can come in as a “stand‐by” to wait for someone to no‐show his or her scheduled appointment. Since there are options for all clients we have not had upset clients.
Q: Is the Epic system unique to Oregon?
A: No, EPIC is not unique to Oregon. For more information on EPIC Practice Management and EHR see http://www.epic.com/. Multnomah County participates in a collaborative called OCHIN which allows us to share in the cost of EPIC with other Local Health Departments and other safety net clinics. For more information on the collaborative see their website: https://ochin.org/.
Third‐Party Payer Relationships Q: Are you billing Medicaid and are there any circumstances that you would not bill Medicaid for
eligible clients?
A: Yes, we bill Medicaid. If a client does not want us to bill Medicaid then we ask that the client sign an Advance Beneficiary Notice informing the client that he or she will be charged on the sliding fee scale.
Q: Medicare does not reimburse for STD screens, only by the PCP. How do you bill and do you get
reimbursed by Medicare?
A: We bill Medicare and we receive some payment from them. I do not have a breakdown of what they have covered.
Q: Are you an in‐network provider when you bill the private insurance companies?
A: Our Mid‐Level Providers (NPs and PA‐Cs) are credentialed with Regence Blue Cross/Blue Shield and Pacific Source. We bill all other private insurances even if we are not listed as “in‐network.”
Q: Are you contracted with any insurances? If yes, how does that work with your DIS visits? My
understanding is that if you are contracted, you must bill the insurance for any visit.
A: Our Mid‐Level Providers (NPs and PA‐Cs) are credentialed with Regence Blue Cross/Blue Shield and Pacific Source. We bill all other private insurances even if we are not listed as “in‐network.” We will bill insurance for a DIS visit, if the client agrees.
Q: What are some of the major commercial payers available for pre‐verification on PH Tech?
A: For more information on PH Tech, see their website http://www.phtech.com/.
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Cost‐Effectiveness Q: It seems like you are billing $20 for every client. How is that cost effective?
A: Multnomah County STD Clinic benefits from being part of a larger infrastructure, within Multnomah County Health Department (MCHD). MCHD provides medical billing staff and supports EPIC Practice Management.
Clients seen at the STD Clinic by a Mid‐Level Provider (MLP) are charged on a sliding fee scale based on the Federal Poverty Level, so not all clients will be charged the minimum fee of $20. We bill insurance if a client agrees and is seen by a MLP. MLP priority populations are:
Symptomatic, e.g. abnormal discharge, dysuria, abdominal pain, etc.
Cases and contacts to CT, GC, syphilis, and HIV (DIS referrals)
Men who have sex with men (MSM)
Men and women under 25 years of age
DIS clients, cases or contacts to chlamydia, gonorrhea, syphilis, and/or HIV are charged the flat fee of $20 (no one is refused service due to inability to pay).
Our “Just Checking” visits (asymptomatic STD screening) completed by a Community Health Worker or DIS, are a flat fee of $20 for priority populations (MSM and men and women under 25 years of age) and $40 for non‐priority clients.