Evaluation and Management

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Evaluation and Management
Evaluation and Management
Evaluation and Management
My Background
• My connection to coding and documentation

• My connection to clinical processes

• My connection to ICD-10

• My connection to YOU

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Evaluation and Management
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).

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Evaluation and Management
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

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Evaluation and Management
Updates

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Evaluation and Management
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.

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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.

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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.

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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.

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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?

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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

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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.

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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.

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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.

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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.

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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.

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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.

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AMA
• Minimal Problem

• Self-limited or minor problem

• Stable Chronic Illness

• Chronic illness with exacerbation,
  progression, or side effects of treatment

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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
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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

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Examples
These are just examples to think about

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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

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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

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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

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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

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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

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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.

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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.

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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.
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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

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ICD-10

• How does ICD-10 affect Medical
  Necessity and complexity or does it?

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Implementing the Changes

• What steps do you need to take?

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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.

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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.”

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Medicare Preventive
     Services
Medicare Benefits Policy Manual – Chapter 13

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Qualifying Codes for G0468 (IPPE
or AWV)

• G0402   Initial preventive exam

• G0438   AWV, initial visit

• G0439   AWV, subsequent visit

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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

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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

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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

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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

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Preventive Services

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Preventive Services

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Preventive Services

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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

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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..

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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

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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.
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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
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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)

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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

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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).

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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

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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

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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

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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.

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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

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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.

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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.

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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

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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

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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

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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.
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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

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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

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AWV and IPPE Strategies

• Combine templates

• Train staff – double book providers schedule

• Run reports to see who is due for their wellness
  visit

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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.

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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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