Common Misunderstandings & Mistakes in Dosimetry Coding & Documentation

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1 Common Misunderstandings & Mistakes in Dosimetry Coding & Documentation AAMD Annual Meeting San Antonio, Texas June 2013

2 Presenters Kelli Weiss, RT(R)(T) Executive Director Adam Brown, BSRT(T), CMD Consultant

3 Disclaimer This presentation was prepared as a tool to assist attendees in learning about documentation, charge capture and billing processes. It is not intended to affect clinical treatment patterns. While reasonable efforts have been made to assure the accuracy of the information within these pages, the responsibility for correct documentation and correct submission of claims and response to remittance advice lies with the provider of the services. The material provided is for informational purposes only. Efforts have been made to ensure the information within this document was accurate on the date of presentation. Reimbursement policies vary from insurer to insurer and the policies of the same payer may vary within different U.S. regions. All policies should be verified to ensure compliance. CPT codes, descriptions and other data are copyright 2013 American Medical Association (or such other date of publication of CPT ). All Rights Reserved. CPT is a registered trademark of the American Medical Association. Code descriptions and billing scenarios are references from the AMA, CMS local and national coverage determinations (LCD/NCD), the ASTRO/ACR Guide Copyright to 2012 Radiation RCI All Rights Reserved. Oncology Do Not Duplicate. Coding, Presented on the June 2013 ACRO at AAMD Annual Practice Conference, Management San Antonio Texas Guide and common practice standards nationwide

4 Apology Mistakes may be a harsh word For clarification: A misunderstanding of our specialty by payors How payor rules designed for all providers in all specialties may not fit into the process of care for Radiation Oncology But.we are required to follow

5 Objectives Understand what types of mistakes or misunderstandings of the rules are commonly seen Discuss how to avoid these types of errors Identify potential ramifications

6 Common Errors Physician Orders & Medical Necessity Not Located Incomplete &/or Missing documentation Incorrect Dates of Service Utilized for Billing Incorrect CPT Codes Missing and/or Late signatures Billing Under the Incorrect Physician Billing Under the Incorrect Location

7 Physician Orders & Medical Necessity All services must have a formal written order by the MD & be supported by medical necessity Contrary to Opinions, This Concept Does Apply to Radiation Oncology Payor guidelines clearly state the requirement Medicare manuals state the requirement Recovery audits currently underway in which this area is a concern

8 Quotes WPS LCD ID Number L30316, Titled Radiation Oncology Including Intensity Modulated Radiation Therapy (IMRT) Indications and Limitations of Coverage and/or Medical Necessity Radiation oncology services are considered medically reasonable and necessary when the following conditions are indicated and documented in the patient's medical records.

9 Recovery Audit Detail - IMRT

10 Recovery Audit Detail SRS & SBRT

11 Missing or Incomplete Documentation Physician clinical treatment plan Need specific documentation Detailing specific treatment technique Orders Medical necessity For 3D IMRT Brachytherapy and SRS/SBRT Additional CT for boost or tumor response, additional IMRT and 3D simulations

12 Missing Documentation For IMRT Goals and dose constraints for IMRT Required for all IMRT plans Documented prior to planning While this seems difficult, it is possible using various methods Within an Electronic Medical Record (EMR) document Using software for different reports example: ROR s new product

13 Incorrect Dates of Service Dosimetry processes Treatment plans, calculations and devices IMRT secondary calculations IMRT MLC device What is the correct date?

14 Professional versus Technical Difference Between Professional Charges and Technical Charges? Same charges billed on different dates Should the dates be the same???

15 Incorrect CPT Codes or Units Treatment devices Incorrect complexity Incorrect quantity Dosimetry procedure codes Conventional isodose plans Electron isodose plans 3D simulations SRS/SBRT planning Brachytherapy isodose plans

16 Physician Signatures Late Approving documentation after the date performed Incomplete Must contain signature, credentials, date and time Design Missing EMR template design can result in unacceptable signatures Only front page of treatment plan, therefore, many items not approved Not present on QA, i.e. secondary calcs for IMRT On What? Misunderstanding on what needs signatures

17 Late Signatures Signatures provided on a day other than when the work was performed Dosimetry IMRT QA Secondary calculations Results in difficulty supporting the professional work or supervision as required

18 Inappropriate Signature Practices Signatures lacking time and date stamp EMR not utilized properly Not present on handwritten signatures Illegible signatures Often only a symbol rather than a signature Missing signature log Missing signatures would require a separate attestation page for each service provided

19 As Stated by Medicare All entries in the medical record must be dated, timed, and authenticated, in written or electronic form, by the person responsible for providing or evaluating the service provided. When State law and/or hospital policy requires that entries in the medical record made by residents or non-physicians be countersigned by supervisory or attending medical staff members, then the medical staff rules and regulations must address counter-signature requirements and processes.

20 Signature Guidelines Updated June 2010 Written Signatures Full name or first initial and last name Legible or accompanied by signature log Date and time Electronic Signatures Provided via secure login and password Printed statement Name, credentials, date and time Medicare example: Electronically Signed By: John Doe, M.D. 03:25pm

21 Billing Under the Incorrect Physician Services performed by one physician but billed under another Example: Dr. Duck simulates the patient and contours structures and provides guidance to dosimetrist. When the plan is completed, printed or imported into EMR, Dr. Goose signs it. Who do you bill the dosimetry charges under? Technical services can vary depending on type of facility Locum Physicians

22 Answer The physician who signs the dosimetry should be the same physician appearing on the professional claim form i.e. Dr. Goose. The attending physician i.e. Dr. Duck would remain the physician on the hospital claim What if this were IMRT and everything was completed except the IMRT fluence maps? Answer those could very well be completed on a separate day and the physician signing those could be Dr. Doolittle, therefore, billed under Doolittle

23 Billed Under Incorrect Location Issue Dosimetry services are performed at a centralized location, however, exported to a different location for use. Question What address goes on the claim form? Answer Depends on many factors.

24 Location 1. Hospital A performs dosimetry for Hospital B. Plan is finalized and printed at Hospital A. Billing is completed by Hospital A, not Hospital B 2. Hospital A performs dosimetry for Hospital B. Plan is exported to Hospital B and finalized and printed at Hospital B. Billing is completed by Hospital B 3. Hospital B purchases remote dosimetry services from Company X. Company X performs dosimetry, finalizes plan and sends to Hospital B. Billing is completed by Hospital B No matter which scenario, the MD signing the plan would be the physician at the location completing the plan and it would be billed under that MD s name. And..supervision would also be occurring at the location where services are performed.

25 Consequences Claim denial Payor audit Commercial payors Governmental agencies Medicare RAC OIG Many more

26 Why Does This Matter?

27 The Obama Administration In 2010 the proposed budget requested $1.7 billion to fight health care fraud. The Administration estimated for every dollar spent by the Department of Health & Human Services to fight health care fraud & reduce improper payments, about $1.55 is saved or averted. Projects this would generate $9.9 billion in savings over 10 years Presidential Memorandum states: The Obama Administration is committed to reducing payment errors and eliminating waste, fraud, and abuse in Federal programs. On March 10, 2010, the Administration expanded the use of Payment Recapture Audits, a process of identifying improper payments where highly skilled accounting specialists and fraud examiners use state-of-the-art tools and technology to examine payment records and uncover problems such as duplicate payments, payments for services not rendered, overpayments, and fictitious vendors.

28 Ways to Avoid Mistakes Development of an internal compliance plan Daily charge and documentation review Charges are only exported or submitted when documentation is present and complete Opportunity to correct errors prior to submission to payor Daily interface verification audits Ensure charges exported over the interface are received on the other end

29 More Ways to Avoid Mistakes Internal audits against claim forms to identify problems Identifies scrubber issues Verifies correct quantities are submitted Verifies correct isodose planning Identify interface concerns Opportunity for staff training and corrective actions

30 Compliance Plan Recommendations From OIG Development of a compliance program including: Conduct internal monitoring and auditing Implement compliance and practice standards Designate a compliance officer or contact Conduct appropriate training and education Respond appropriately to detected offenses and develop corrective action Develop open lines of communication with employees Enforce disciplinary standards through well-publicized guidelines

31 Also Include Your processes to ensure compliance Documentation processes Charge capture Charge review Chart audits & findings Correction of errors Staff education Resources

32 Revenue Cycle Inc W. Braker Lane Bldg. F, Suite 200 Austin, Texas (512)

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