Evaluation and Management
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My Background • My connection to coding and documentation • My connection to clinical processes • My connection to ICD-10 • My connection to YOU Coding & Compliance Initiatives, Inc. 2
Disclaimer The information provided within this presentation is for educational purposes only and is not intended to be considered legal advice. Opinions and commentary are solely the opinion of the speaker. Many variables affect coding decisions and any response to the limited information provided in a question is intended to provide general information only. All coding must be considered on a case-by-case basis and must be supported by appropriate documentation, medical necessity, hospital bylaws, state regulations, etc. The CPT codes that are utilized in coding are produced and copyrighted by the American Medical Association (AMA). Coding & Compliance Initiatives, Inc. 3
Agenda • We will discuss some updates from 2019 • We will discuss the up coming E/M changes for coding and documentation • We will discuss Medicare preventive services Coding & Compliance Initiatives, Inc. 4
2019 Updates • HPI elements as well as the ROS elements can be obtained by someone other than the billing provider. • Train you Medical Assistants on how to obtain and document an HPI, PERTINENT ROS and PFSH • Check with your private contracted payers to see if they will follow the same changes. Coding & Compliance Initiatives, Inc. 6
2019 Updates • Documentation guidelines for teaching physicians • CMS eliminated its requirement that teaching physicians personally document the extent of their participation in the review and direction of services furnished to each patient. The participation of teaching physicians in the provision of E/M services and procedures may be demonstrated by notes that residents, nurses, or other ancillary staff make in the medical record. Teaching physicians still will be responsible for verifying the accuracy of such notes, along with further documenting their participation in the medical record if the notes that other health care professionals make inaccurately demonstrate the physician’s involvement in the provision of the service. Coding & Compliance Initiatives, Inc. 7
Student Documentation • Students may document services in the medical record. The teaching physician must verify in the medical record all student documentation or findings, including history, physical exam and/or medical decision making. • The teaching physician must personally perform (or re- perform) the physical exam and medical decision- making activities of the E/M service being billed, but may verify any student documentation of them in the medical record, rather than re-documenting this work. Coding & Compliance Initiatives, Inc. 8
2019 Updates • Effective January 1, 2019, FQHCs can receive payment for Virtual Communication services when at least 5 minutes of communication technology-based or remote evaluation services are furnished by an FQHC practitioner to a patient who has had an FQHC billable visit within the previous year, and both of the following requirements are met: • The medical discussion or remote evaluation is for a condition not related to an FQHC service provided within the previous 7 days, and • The medical discussion or remote evaluation does not lead to an FQHC visit within the next 24 hours or at the soonest available appointment. • To receive payment for Virtual Communication services, FQHCs must submit an FQHC claim with HCPCS code G0071 (Virtual Communication Services) either alone or with other payable services. • RHC face-to-face requirements are waived when these services are furnished to an FQHC patient, and coinsurance applies. Coding & Compliance Initiatives, Inc. 9
2021 Changes • Providers will have the flexibility on documentation for the visits – current framework, medical decision-making or time. • For levels 2 through 5, when using the MDM or current framework CMS will apply a minimum supporting documentation standard associated with level 2 visits. • What about private payors or secondary insurance? Coding & Compliance Initiatives, Inc. 10
2021 Changes Summary - AMA • Removing history and exam as key components • Must have a medically appropriate history and/or exam • Making the basis for code selection either the level of medical decision-making performed OR the total time spent performing the service on the day of the encounter • Changing the definition of the time element associated with codes 99202-99215 from typical face-to-face time to total time spent on the day of the encounter, and changing the amount of time associated with each code Coding & Compliance Initiatives, Inc. 11
AMA Summary of History and/or Exam • Office or other outpatient services include a medically appropriate history and/or physical examination, when performed. • The nature and extent of the history and/or physical examination is determined by the treating physician or other qualified health care professional reporting the service. Coding & Compliance Initiatives, Inc. 12
AMA Summary of History and/or Exam • The care team may collect information and the patient or caregiver may supply information directly (eg, by portal or questionnaire) that is reviewed by the reporting physician or other qualified health care professional. • The extent of history and physical examination is not an element in selection of office or other outpatient services. Coding & Compliance Initiatives, Inc. 13
AMA Summary of Assessment and Plan • One element in the level of code selection for an office or other outpatient service is the number and complexity of the problems that are addressed at an encounter. • Multiple new or established conditions may be addressed at the same time and may affect medical decision making. • Symptoms may cluster around a specific diagnosis and each symptom is not necessarily a unique condition. Coding & Compliance Initiatives, Inc. 14
AMA Summary of Assessment and Plan • Comorbidities/underlying diseases, in and of themselves, are not considered in selecting a level of E/M services unless they are addressed, and their presence increases the amount and/or complexity of data to be reviewed and analyzed or the risk of complications and/or morbidity or mortality of patient management. Coding & Compliance Initiatives, Inc. 15
AMA Summary of Assessment and Plan • The final diagnosis for a condition does not in itself determine the complexity or risk, as extensive evaluation may be required to reach the conclusion that the signs or symptoms do not represent a highly morbid condition. • So, in other words – you get paid for the work (this statement is not from the AMA) • Multiple problems of a lower severity may, in the aggregate, create higher risk due to interaction. Coding & Compliance Initiatives, Inc. 16
AMA • Problem addressed: A problem is addressed or managed when it is evaluated or treated at the encounter by the physician or other qualified health care professional reporting the service. • This includes consideration of further testing or treatment that may not be elected by virtue of risk/benefit analysis or patient/parent/guardian/surrogate choice. • Notation in the patient’s medical record that another professional is managing the problem without additional assessment or care coordination documented does not qualify as being ‘addressed’ or managed by the physician or other qualified health care professional reporting the service. • Referral without evaluation (by history, exam, or diagnostic study[ies]) or consideration of treatment does not qualify as being addressed or managed by the physician or other qualified health care professional reporting the service. Coding & Compliance Initiatives, Inc. 17
AMA • Minimal Problem • Self-limited or minor problem • Stable Chronic Illness • Chronic illness with exacerbation, progression, or side effects of treatment Coding & Compliance Initiatives, Inc. 18
AMA • Acute, uncomplicated illness or injury • Acute, complicated injury • Undiagnosed new problem with uncertain prognosis: • Acute or chronic illness or injury that poses a threat to life or bodily function Coding & Compliance Initiatives, Inc. 19
Medical Decision-Making Table 2020 2021 Number and Complexity of Number of Diagnoses or Problems Addressed at the Management Options Encounter Amount and/or Complexity of Amount and/or Complexity of Data to be Reviewed and Data to be Reviewed Analyzed Risk of Complications and/or Risk of Complications and/or Morbidity or Mortality of Patient Morbidity or Mortality Management Coding & Compliance Initiatives, Inc. 20
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Examples These are just examples to think about Coding & Compliance Initiatives, Inc. 22
Straightforward Medical Decision- Making • Patient presents after being on antibiotic for otitis – doing well and infection is gone • Patient presents with “feared” complaint • Patient presents skin redness – you determine it is a “sunburn” • Patient presents with ankle pain – rest and elevate Coding & Compliance Initiatives, Inc. 23
Low Medical Decision-Making • Patient presents with well controlled hypertension- refilled meds • Patient presents with sinusitis – treated with antibiotic • Patient presents with elbow pain – evaluated and treated with NSAID Coding & Compliance Initiatives, Inc. 24
Moderate Medical Decision- Making • Patient presents to follow-up on HTN, DM and Hyperlipidemia – refilled meds for all 3 • Patient presents with right lower quadrant pain working up for appendicitis • Patient presents with moderate to severe headaches and your working up • Diabetic patient presents with vision difficulties and noncompliance Coding & Compliance Initiatives, Inc. 25
High Medical Decision-Making • Patient presents with fatigue, weight loss, intermittent fever, and presenting with diffuse adenopathy and splenomegaly • Patient presents with history of increasing confusion, agitation and short-term memory loss • Patient presents who is status post-transplant, with new onset of peripheral edema, increased blood pressure, and progressive fatigue Coding & Compliance Initiatives, Inc. 26
2021 - Coding on Time E/M Code Current “Typical” Time 2021 Time 99201 10 minutes Deleted Code 99202 20 minutes 15-29 minutes 99203 30 minutes 30-44 minutes 99204 45 minutes 45-59 minutes 99205 60 minutes 60-74 minutes 99211 5 minutes No time listed 99212 10 minutes 10-19 minutes 99213 15 minutes 20-29 minutes 99214 25 minutes 30-39 minutes 99215 40 minutes 40-54 minutes Coding & Compliance Initiatives, Inc. 27
Category Definition 2019 2021 CC/Reason for The reason for the Required Required visit encounter History of Present Symptoms describing the Staff may Document pertinent HPI as Illness nature and severity of the document, medically indicated. This will no patient’s presenting however, provider longer be counted for coding problem(s) is responsible for purposes. The documentation verifying and must support the necessity of updating if the encounter. needed. Review of Systems Describes how pertinent Staff or patients Pertinent ROS should be systems are impacted by may document documented to describe the the presenting problem this information. complexity of the condition(s). Provider must This will no longer be counted review and verify. for coding purposes. Past, Family, and Indicates areas of Staff or patients PFSH should be documented to Social History concern within the may document describe any pertinent patients PFSH that could this information. information that impacts care impact the current Provider must and decision-making. This will problem. review and verify. no longer be counted for coding purposes. Coding & Compliance Initiatives, Inc. 28
Category Definition 2019 2021 Exam Quantifies the hands-on Providers are only Medically appropriate exam as work performed by the required to determined by the provider. provider. document interval This will no longer be counted changes. Must for coding purposes. This could meet the required still impact the level of service elements for supposed based upon the coding. necessity of the exam documented. Assessment (i.e. Credits the provider for Providers must Only diagnoses documented as diagnosis and/or each diagnosis being document a final active treatment during the sign(s)/symptom(s) treated during the diagnosis or encounter will be given credit. current encounter. It also sign(s)/symptom(s) Additional work-up Is not listed provides credit for in the table of risk. It will be underlying conditions important to describe in detail that impact the decision- the symptoms, differentials, making. etc. Data and The amount of work Providers receive Most of the elements are now Complexity performed to obtain “points” based incorporated in the risk table. and/or analyze data (i.e. upon the data “points” will no longer be diagnostic results). ordered, reviewed, counted for coding purposes. etc. Coding & Compliance Initiatives, Inc. 29
Category Definition 2019 2021 Table of Risk The highest level of risk The medical The table of risk has been of mortality and/or decision-making revised. For the purposes of morbidity posed by the component is medical decision making, level presenting problem(s), based upon the of risk is based upon ordered tests or diagnoses, data consequences of the interventions. ordered/reviewed problem(s) addressed at the and overall risk. encounter when appropriately treated. Risk also includes medical decision making related to the need to initiate or forego further testing, treatment and/or hospitalization. Time The use of face time When the majority There is not a requirement that spent with the patient as of a face-to-face the majority of the visit must the determining factor in visit (in the clinic) is be counseling and coordination selecting an E/M level. spent in counseling of care. Also, the time spent and coordination of will include the rendering care provider can providers TOTAL time spent on report the E/M the DAY of the encounter, service on time in including NON face-to-fact time lieu of the key spent on the specific encounter components. for the patient. Coding & Compliance Initiatives, Inc. 30
AMA • Medical decision-making table: • https://www.ama-assn.org/system/files/2019-06/cpt- revised-mdm-grid.pdf • E/M Code and Guideline Changes • https://www.ama-assn.org/system/files/2019-06/cpt- office-prolonged-svs-code-changes.pdf Coding & Compliance Initiatives, Inc. 31
ICD-10 • How does ICD-10 affect Medical Necessity and complexity or does it? Coding & Compliance Initiatives, Inc. 32
Implementing the Changes • What steps do you need to take? Coding & Compliance Initiatives, Inc. 33
Summary • Clinicians may use either time or medical decision making to select a code. • There will be no required level of history or exam for visits 99202—99215. • Time will be defined as total time spent, including non-face- to-face work done on that day, and will no longer require time to be dominated by counseling. The time will be a range of time. Coding & Compliance Initiatives, Inc. 34
Summary • There will be new definitions within MDM. • The MDM calculation will be similar, but not identical to, the current MDM calculation. • CPT® is providing numerous definitions to clarify terms in the current guidelines, such as “chronic illness with exacerbation, progression or side effects of treatment,” and “drug therapy requiring intensive monitoring for toxicity.” Coding & Compliance Initiatives, Inc. 35
Medicare Preventive Services Medicare Benefits Policy Manual – Chapter 13 Coding & Compliance Initiatives, Inc. 36
Qualifying Codes for G0468 (IPPE or AWV) • G0402 Initial preventive exam • G0438 AWV, initial visit • G0439 AWV, subsequent visit Coding & Compliance Initiatives, Inc. 37
New Patient - Payment Adjustment • New Patient, Annual Wellness Visit (AWV) and Initial Preventive Physical Exam (IPPE) Adjustments • Payment rate will be increased by 1.3416 (i.e. 34%) for new patients, IPPE, initial and subsequent AWVs • New patient –someone who has not received any Medicare covered services from any site or any provider within the FQHC organization Coding & Compliance Initiatives, Inc. 38
Preventive Services • FQHCs must provide preventive health services on site or by arrangement with another provider. • These services must be furnished by or under the direct supervision of a physician, NP, PA, CNM, CP, or CSW. • Section 330(b)(1)(A)(i)(III) of the Public Health Service (PHS) Act required preventive health services can be found at http://bphc.hrsa.gov/policiesregulations/legislation /index.html Coding & Compliance Initiatives, Inc. 39
Preventive Services • Examples: • prenatal and perinatal services; • appropriate cancer screening; • well-child services; • immunizations against vaccine-preventable diseases; • screenings for elevated blood lead levels, communicable diseases, and cholesterol; • pediatric eye, ear, and dental screenings to determine the need for vision and hearing correction and dental care; • voluntary family planning services; and • preventive dental services Coding & Compliance Initiatives, Inc. 40
Preventive Services • Examples: • Cardiovascular screening blood test • Diabetes screening test • Screening mammography • Screening pap smears • Screening pelvic exam (can include clinical breast exam) • Prostate cancer screening • Colorectal cancer screening tests Coding & Compliance Initiatives, Inc. 41
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Preventive Services Coding & Compliance Initiatives, Inc. 43
Preventive Services Coding & Compliance Initiatives, Inc. 44
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IPPE/Welcome to Medicare • Beneficiary has no more than 12 months from effective Part B coverage for exam • Co-insurance is waived • Revenue code 0521 • HCPCS code G0402 Coding & Compliance Initiatives, Inc. 48
IPPE/Welcome to Medicare • Services include: • Patient history (height, weight, and blood pressure at a minimum) • Visual acuity screen – this is one we see missed • Measurement of body mass index • Other factors deemed appropriate based on the individual’s medical and social history and current clinical standards • Depression risk assessment – • To obtain current or past experiences with depression or other mood disorders, use any appropriate screening instrument for beneficiaries without a current diagnosis of depression from various available standardized screening tests recognized by national professional medical organizations.. Coding & Compliance Initiatives, Inc. 49
IPPE/Welcome to Medicare • Review the beneficiary’s functional ability and level of safety • Use appropriate screening questions or standardized questionnaires recognized by national professional medical organizations to review, at a minimum, the following areas: • Activities of daily living • Fall risk • Hearing impairment • Home safety Coding & Compliance Initiatives, Inc. 50
IPPE/Welcome to Medicare • End-of-life planning (verbal or written information provided to the beneficiary about): • The beneficiary’s ability to prepare an advance directive in case an injury or illness causes the beneficiary to be unable to make health care decisions • Whether or not you are willing to follow the beneficiary’s wishes as expressed in an advance directive • Based on the results of the review and evaluation services in the previous components, provide education, counseling, and referral as appropriate. Coding & Compliance Initiatives, Inc. 51
IPPE/Welcome to Medicare • Educate, counsel, and refer for other preventive services • Includes a brief written plan, such as a checklist, for the beneficiary to obtain: • A once-in-a-lifetime screening electrocardiogram (EKG/ECG), as appropriate • The appropriate screenings and other preventive services that Medicare covers • Performed by doctor of medicine, or osteopathy, PA, NP, or CNS Coding & Compliance Initiatives, Inc. 52
IPPE/Welcome to Medicare • Revenue code 521 • HCPCS code G0402 (Welcome to Medicare) • EKG Services • HCPCS code G0404 (tracing only) • HCPCS code G0405 (interpretation and report only) – this is included in G0402 and should NOT be separately reported. This does not have a waived co-insurance. • Technical Billed to carrier • CMS-1500 claim form or 837P • Use Practitioners National Provider Identifier (NPI) Coding & Compliance Initiatives, Inc. 53
IPPE Summary of Requirements • Review of the individual’s medical and social history with attention to modifiable risk factors for disease detection • Review of the individual’s potential (risk factors) for depression or other mood disorders • Review of the individual’s functional ability and level of safety • An examination to include measurement of the individual’s height, weight, BMI, blood pressure, a visual acuity screen, and other factors as deemed appropriate, based on the beneficiary’s medical and social history • End-of-life planning, upon agreement of the individual Coding & Compliance Initiatives, Inc. 54
IPPE Summary of Requirements • Education, counseling, and referral, as deemed appropriate, based on the results of the review and evaluation services described in the previous elements • Education, counseling, and referral including a brief written plan (e.g., a checklist or alternative) provided to the individual for obtaining the appropriate screening and other preventive services, which are separately covered under Medicare Part B (that is, pneumococcal, influenza and hepatitis B vaccines and their administration, screening mammography, screening pap smear and screening pelvic examinations, prostate cancer screening tests, colorectal cancer screening tests, diabetes outpatient self- management training services, bone mass measurements, glaucoma screening, medical nutrition therapy for individuals with diabetes or renal disease, cardiovascular screening blood tests, diabetes screening tests, screening ultrasound for abdominal aortic aneurysms, an electrocardiogram, and additional preventive services covered under Medicare Part B through the Medicare national coverage determinations process). Coding & Compliance Initiatives, Inc. 55
Annual Wellness Visit (AWV) • G0438: Annual wellness visit, includes PPPS, first visit (annual wellness first) • G0439: Annual wellness visit, includes PPPS, subsequent visit (subsequent) • Revenue code from 052X series Coding & Compliance Initiatives, Inc. 56
Annual Wellness Visit (AWV) • Personalized prevention plan or “wellness visit” • Includes but is not limited to • Health risk assessment, and may contain: • Establishment or updated individual medical and family history • List of current providers and suppliers that are regularly involved in providing medical care (list prescribed drugs) • Measurement of height, weight, body mass index (or waist circumference, if appropriate), blood pressure, and other routine measurements • Detection of cognitive impairment Coding & Compliance Initiatives, Inc. 57
Health Risk Assessment • Demographic Data: • Behavioral Risk: • Age • Tobacco use • Physical activity • Gender • Nutrition and oral health • Race • Alcohol consumption • Ethnicity • Sexual health • Motor vehicle safety (seatbelt) and Home safety • Self Assessment of: • • Health Status Activities of daily living • Dressing • Frailty • Feeding • Physical Functioning • Toileting • • Psychosocial Risks: • Bathing and Grooming Physical ambulation (balance, fall risk, etc.) • Depression/life satisfaction • Instrumental activities of daily living • Stress • Shopping • Anger • Food preparation • Loneliness/social isolation • Using the telephone • Pain • Housekeeping and Laundry • • Fatigue • Mode of transportation Responsibility of medications • Ability to handle finance Coding & Compliance Initiatives, Inc. 58
AWV – Medical and Family History • At a minimum, document the following: • Medical events of the beneficiary’s parents, siblings, and children, including conditions that may be hereditary or place the beneficiary at increased risk • Past medical and surgical history, including experiences with illnesses, hospital stays, operations, allergies, injuries, and treatments • Use of, or exposure to, medications and supplements, including calcium and vitamins • We encourage providers to pay close attention to opioid use during this part of the AWV, which includes opioid use disorders (OUD). If a patient is using opioids, assess the benefit for other, non-opioid pain therapies instead, even if the patient does not have OUD but is possibly at risk. Coding & Compliance Initiatives, Inc. 59
AWV - Summary • Establish a list of current providers and suppliers • Include current providers and suppliers that regularly provide medical care to the beneficiary • Obtain the following: • Height, weight, body mass index (BMI; or waist circumference, if appropriate), and blood pressure • Other routine measurements deemed appropriate based on medical and family history Coding & Compliance Initiatives, Inc. 60
AWV - Summary • Detect any Cognitive Impairment: • Assess the beneficiary’s cognitive function by direct observation, while considering information from beneficiary reports and concerns raised by family members, friends, caregivers, and others. If appropriate, use a brief validated structured cognitive assessment tool. For more information, refer to the National Institute on Aging’s Alzheimer’s and Dementia Resources for Professionals website. Coding & Compliance Initiatives, Inc. 61
AWV - Summary • Potential risk factors for depression, including current or past experiences with depression or other mood disorders: • Use any appropriate screening instrument. You may select from various available standardized screening tests designed for this purpose. For more information, refer to the Depression section on the Substance Abuse and Mental Health Services Administration–Health Resources and Services Administration’s Screening Tools website. Coding & Compliance Initiatives, Inc. 62
AWV - Summary • Functional ability and level of safety: • Use direct observation of the beneficiary or select appropriate questions from various available screening questionnaires, or use standardized questionnaires recognized by national professional medical organizations to assess, at a minimum, the following topics: • Ability to successfully perform ADLs • Fall risk • Hearing impairment • Home safety Coding & Compliance Initiatives, Inc. 63
AWV - Summary • Establish an appropriate written screening schedule for the beneficiary, such as a checklist for the next 5 to 10 years • Base written screening schedule on: • Recommendations from the United States Preventive Services Task Force (USPSTF) and the Advisory Committee on Immunization Practices (ACIP) • The beneficiary’s HRA, health status and screening history, and age-appropriate preventive services Medicare covers Coding & Compliance Initiatives, Inc. 64
AWV - Summary • Establish a list of beneficiary risk factors and conditions for which primary, secondary, or tertiary interventions are recommended or underway • Include the following: • Mental health conditions including depression, substance use disorder, and cognitive impairment • Risk factors or conditions identified through an IPPE • Treatment options and their associated risks and benefits Coding & Compliance Initiatives, Inc. 65
AWV - Summary • Furnishing of personalized health advice to the individual and a referral, as appropriate, to health education or preventive counseling services or programs aimed at reducing identified risk factors and improving self- management, or community-based lifestyle interventions to reduce health risks and promote self-management and wellness, including weight loss, physical activity, smoking cessation, fall prevention, and nutrition. Coding & Compliance Initiatives, Inc. 66
AWV - Summary • Furnish, at the beneficiary’s discretion, advance care planning services. Include discussion about: • Future care decisions that may need to be made • How the beneficiary can let others know about care preferences • Caregiver identification • Explanation of advance directives, which may involve the completion of standard forms Coding & Compliance Initiatives, Inc. 67
AWV Initial versus Subsequent G0438 - Annual wellness visit; includes a personalized prevention plan of service (PPS), initial visit G0439 - Annual wellness visit; includes a personalized prevention plan of service (PPS),subsequent visit Coding & Compliance Initiatives, Inc. 68
INITIAL AWV SUBSEQUENT AWV Administer Health Risk Assessment (HRA) Update Health Risk Assessment Establish medical/family history Update to medical/family history Establish list of current providers & suppliers involved in Update list of providers & suppliers medical care Measurement of height, weight, BMI, BP and other Measurement of height, weight, BMI, BP and other routine routine measurements deemed appropriate based on measurements deemed appropriate based on history history Detection of any cognitive impairments Detection of any cognitive impairments Review potential (risk factors) and conditions for which Update to list of risk factors and conditions interventions are recommended or already underway Establish a written screening schedule Update to written screening schedule Review of functional ability and level of safety based on direction observation or use of appropriate screening questions or questionnaire recognized by national professional medical organizations Furnish personalized health advise and refer as Furnish personalized health advise and refer as appropriate appropriate to health education, preventive counseling to health education, preventive counseling services or services or programs aimed at reducing identified risk programs aimed at reducing identified risk factors factors Any other element determined by HHS Any other element determine by HHS Coding & Compliance Initiatives, Inc. 69
IPPE/Welcome to Medicare and AWV • When IPPE or AWV is rendered on same day as another billable visit, only the preventive is reimbursed, however, we should report all services rendered that are appropriate and medically necessary. • Co-insurance waived Coding & Compliance Initiatives, Inc. 70
AWV and IPPE Strategies • Combine templates • Train staff – double book providers schedule • Run reports to see who is due for their wellness visit Coding & Compliance Initiatives, Inc. 71
EKG • FQHCs are instructed to bill the technical component of the EKG to the carrier when applicable • CMS-1500 claim form or 837P • Use practitioner’s NPI • As noted in the CMS IOM Publication 100-04, Chapter 9, the professional component is included in the all-inclusive rate for FQHCs Coding & Compliance Initiatives, Inc. 72
EKG Documentation • As far back as 1992, the CPT® codebook has included language stating, “a written report, signed by the interpreting physician, should be considered an integral part of a radiologic procedure or interpretation.” • CMS does not require the provider to document an ECG interpretation on a separate piece of paper, but instead allows for a complete written interpretation to be recorded within the medical record (check with your local carrier for further guidance). CMS further requires a report to be complete, documented similarly to that of a specialist in the field (radiology), and consistent with the treatment rendered. CPT® states there must be a “separate, signed, written, and retrievable report.” Coding & Compliance Initiatives, Inc. 73
Screening Pelvic and Breast Exam • Screening Pelvic and Clinical Breast Examination (G0101) • Screening Pap Smear (Q0091) • Billable if this is the only service rendered for date of service or with other services on the same day • Co-insurance waived Coding & Compliance Initiatives, Inc. 74
Screening Pelvic and Breast Exam • She has not had such a test during the preceding two years or is a woman of childbearing age (§1861(nn) of the Social Security Act (the Act). • There is evidence (on the basis of her medical history or other findings) that she is at high risk of developing cervical cancer and her physician (or authorized practitioner) recommends that she have the test performed more frequently than every two years. • High risk factors for cervical and vaginal cancer are: • Early onset of sexual activity (under 16 years of age) • Multiple sexual partners (five or more in a lifetime) • History of sexually transmitted disease (including HIV infection) • Fewer than three negative or any pap smears within the previous seven years; and • DES (diethylstilbestrol) - exposed daughters of women who took DES during pregnancy. Coding & Compliance Initiatives, Inc. 75
Screening Pelvic and Breast Exam • COUNTING: To determine the 11- and 23- month periods, start counts beginning with the month after the month in which a previous test/procedure was performed. • COUNTING EXAMPLE: A beneficiary identified as being at high risk for developing cervical cancer received a screening Pap smear in January 2000. Start counts beginning with February 2000. The beneficiary is eligible to receive another screening Pap smear in January 2001 (the month after 11 full months have passed). Coding & Compliance Initiatives, Inc. 76
Documentation Requirements for Screening Pelvic and Breast Exam 1. Inspection and palpation of breasts for masses or lumps, tenderness, symmetry, or nipple discharge 2. Digital rectal examination including sphincter tone, presence of hemorrhoids, and rectal masses 3. External genitalia (for example, general appearance, hair distribution, or lesions) 4. Urethral meatus (for example, size, location, lesions, or prolapse) 5. Urethra (for example, masses, tenderness, or scarring) 6. Bladder (for example, fullness, masses, or tenderness) Coding & Compliance Initiatives, Inc. 77
Documentation Requirements for Screening Pelvic and Breast Exam 7. Vagina (for example, general appearance, estrogen effect, discharge, lesions, pelvic support, cystocele, or rectocele) 8. Cervix (for example, general appearance, lesions or discharge) 9. Uterus (for example, size, contour, position, mobility, tenderness, consistency, descent, or support) 10. Adnexa/parametria (for example, masses, tenderness, organomegaly, or nodularity) 11. Anus and perineum Coding & Compliance Initiatives, Inc. 78
Coding & Compliance Initiatives, 79 Inc.
Contact • Shellie Sulzberger, LPN, CPC, ICDCT-CM • 913-768-1212 • ssulzberger@ccipro.net • www.ccipro.net Coding & Compliance Initiatives, Inc. 80
About CCI • CCI assists our clients improve their documentation quality, coding and billing accuracy, and compliance with health care regulations www.ccipro.net Coding & Compliance Initiatives, 81 Inc.
Shellie Sulzberger, LPN, CPC, ICDCT-CM Ms. Sulzberger is a Licensed Practical Nurse, Certified Professional Coder and ICD-10 Trainer. She received her Bachelors of Science degree in Business Administration from Mid America Nazarene University. Ms. Sulzberger received her nursing license in 1994 and was a practicing clinician at Saint Luke’s Health System for several years before transferring to the internal compliance/audit area. She became credentialed as a Certified Professional Coder in 1996 and assisted the Saint Luke’s Health System with performing medical record chart audits to verify the accuracy of the internal coding and claims processing. Ms. Sulzberger spent approximately six years as a coding/billing consultant with National accounting and consulting firms (BKD, Grant Contact Info: Thornton) before becoming the President of Coding & Compliance Tel: 913-768-1212 Initiatives, Inc. (CCI) in April 2003. Ms. Sulzberger assists her clients with improving their operational performance in a variety of critical Or email outcome areas, including coding/billing, corporate compliance, ssulzberger@ccipro.net charge capture processes, etc. Ms. Sulzberger works with a variety of www.ccipro.com health care providers including hospitals, physician practices, and rural health clinics in their daily compliance and operational activities. Ms. Sulzberger presents locally and nationally on coding topics as well as developing specialized training programs to meet the needs of her clients. Shellie recently was credentialed through American Institute of Healthcare Compliance as a Certified ICD-10 Trainer. Coding & Compliance Initiatives, Inc. 82
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