Compliance and Where You Could Be at Risk. How an EMR System Can Help Support Your Practice and Minimize Your Risks

Transcription

1 Compliance and Where You Could Be at Risk How an EMR System Can Help Support Your Practice and Minimize Your Risks

2 Medicare Requirements Medicare has very specifi c requirements about receiving authorization to treat Medicare patients, and strict guidelines for providers on documenting therapy services*. Some of the critical areas that practitioners must take extra care to manage well include: Legibility and Signatures Referrals and Prescriptions Authorized Visits Therapy Caps Evaluations and Treatment Goals Plan of Care and Physician Certifi cations Progress Reporting and Treatment Notes Timed Procedures, Over and Under Billing Exception Justifi cations An increase in usage of various therapy codes has brought more attention on therapy providers to justify that therapy services are medically necessary and compliant with Medicare regulations. As more and more practices are receiving audit probes, it has become more critical than ever that practitioners understand Medicare requirements and abide by regulations. Failure to do so can result in additional audit risks, denial of claims, signifi cant fi nes and in the worst case, loss of your practice. Where Are You at Risk? The risks to physical therapy practices and individual therapists are real and substantial for non-compliance. However, you can ease your worries. To help safeguard your practice it is important to understand Medicare rules and regulations and evaluate areas where your practice is at risk. Once you know your areas of risk, you can develop compliance plans, train your staff and implement systems and controls to enforce compliance and mitigate those risks. These changes will not only support the Manual Medical Review process and other impending changes, but they can help you improve the overall performance in your practice resulting in improved patient care and a healthier bottom line. The following chart outlines risks associated with established Medicare requirements, as well as additional risks associated with the new Manual Medical Review process recently implemented by CMS. * Medicare rules and regulations are updated on a regular basis. It is important to keep up to date with changing Medicare regulations to stay in compliance. For recent CMS requirements on documentation, visit

3 Where are You at Risk? Established Compliance Risks: Producing illegible (handwritten) documentation and signatures Manually tracking authorizations and therapy caps Failing to establish and track functional long term goals with supporting clinical short term goals Failing to capture timed minutes in documentation and follow Medicare billing rules Failing to submit a Plan of Care to referring physician and obtain a signed approval Failing to demonstrate progress towards goal(s) in progress notes Failing to demonstrate medical necessity in documentation Failing to submit Progress Notes every 30 days or 10 visits Failing to identify services provided, total treatment minutes and total timed services Failing to apply KX modifi er correctly after exceeding $1880 cap Failing to notify billing if documentation changes after claim is submitted, failing to submit addendum to claims Submitting claims that do not have supporting documentation Billing a claim before documentation is complete / fi nalized Overbilling / Underbilling Potential Risks with Manual Medical Review Process Failing to identify therapist implementation phase Failing to verify caps for EACH Medicare patient after Oct 1st Manually tracking therapy caps / authorized visits Failing to demonstrate medical necessity in documentation Therapists failing to complete documentation on the day of visit Failing to follow exceptions process after exceeding $3700 cap

4 How an EMR Solution Can Minimize Your Compliance Risks Implementing the right EMR and practice management software can take the worry out of compliance and ease the burdens it places on front desk and billing staff, therapists and practice owners alike. An EMR system can minimize your compliance risk by: bringing together all patient information in a single electronic system eliminating potentially error-prone paper-based processes, including illegible handwriting automating key workfl ow processes and providing tracking tools, alerts, notifi cations and prompts for missing information providing secure access and automated backup of patient information offering reporting and audit support tools to help enforce compliance and respond appropriately to potential audits Five Compliance Features to Look for in an EMR Solution Selecting an EMR solution to support compliance efforts and the overall practice management can seem like a daunting task. However, if you are thorough in your selection process, you will fi nd that the EMR solution you implement will have positive implications for your business that go far beyond compliance. Some important compliance features to look for and questions to ask when selecting an EMR system: True integration Is the system truly integrated with all patient information in a single system? Are scheduling, clinical documentation and billing all in one place? Some EMR providers can be misleading in calling their systems integrated because they can export information to a separte billing system, so a good question to ask is whether separate software is used to manage the billing. There are many risks associated with using separate systems, such as monitoring when changes are made in the documentation that affect changes in submitted claims - exposing a common audit risk of documentation not matching claims. Another risk is manually tracking therapy caps, rather than system automated tracking according to what has been actually paid. Using separate systems will also heavily affect the upcoming changes with the new G-Code requirements. In addition, a truly integrated EMR system will help eliminate workfl ow ineffi ciencies, documentation errors and information gaps that can put your practice at risk. Automated, system-driven compliance controls An EMR system can take the guesswork out of compliance and set your staff up for success by providing automated tracking tools, alerts, triggers and notifi cations. When looking into an EMR solution ask about what kind of system-level compliance support it provides. Does it offer tools to verify and update therapist phasing of the Manual Medical Review? Does it automatically track therapy caps, Manual Medical Review requirements, Plan of Care certifi cations and authorized visits? Can it automate management of the KX modifi er and exception process? Can it help ensure that documentation supports the claim? Is staff alerted automatically when information is missing? All these embedded workfl ow tools help minimize your compliance risks. Despite some confusing claims, Medicare does NOT test or certify EMR systems for these features, so it s up to you to do your research.

5 How an EMR Solution Can Minimize Your Compliance Risks Continued Customizable documentation tools Your documentation is critical for compliance. The right EMR system will integrate information and processes, making it easy for therapists to accurately complete defensible documentation that is legible, accurate and demonstrates that services were reasonable and medically necessary. When looking at how well an EMR system meets your documentation needs there are many considerations. Does it include regularly updated Correct Coding Initiative (CCI) edits? How about automated charge capture / audit? Does it have workfl ow rules, triggers and notifi cations to ensure that all documentation is complete and meets Medicare guidelines? Does it offer Medicare Plan of Care and Progress Notes tracking and alerts? Is it easy to use for therapists? Does it provide customizable charting templates and letter templates that allow you to tailor it according to your local Medicare requirements and required specifi cations according to CMS? Features like these will ease documentation burdens and help ensure that documentation supports claims 100 percent of the time. Comprehensive reporting and auditing tools Front offi ce staffs, therapists, compliance offi cers and practice owners each have compliance tasks and responsibilities. An EMR system that provides fl exible reporting tools to give insight into potential compliance issues will help practices enforce compliance policies and take corrective action or make process improvements when needed. Does the EMR solution you are looking at provide comprehensive reporting tools? Does it provide reporting dashboards to alert you to potential risks? Can you view which patients are nearing their therapy caps? Does it provide pre-loaded templates for tracking referrals, outcomes, authorizations, payers, diagnosis codes, denials, cash fl ow, reimbursement rates, etc.? Backed up with proven compliance expertise for outpatient rehabilitation Compliance is complex and ever changing. Any EMR solution you implement should be backed by an EMR vendor that will be your trusted partner. Any EMR vendor you choose should have extensive experience navigating the various rules and regulations that impact private physical therapy practices and be up-to-date and understand the current compliance guidelines. They will be best able to develop the tools and technologies to respond to new compliance demands facing physical therapists. About Clinicient Clinicient is focused exclusively on helping outpatient rehabilitation practices succeed, bringing decades of experience learned from providing the fi rst web- based EMR system for therapists and managing nearly $1 billion in collections. Clinicient offers truly integrated EMR with billing management software, an unprecedented payer knowledge based and rules engine, and collaborative billing services to deliver practices unmatched effi ciency and complete visibility and control of their businesses. The end result is a practice that runs more smoothly with a culture of compliance, increased staff productivity and faster payment cycles with more revenue per therapist. For More Information For more information on how Clinicient can help your practice manage compliance better using the industry s leading EMR and Practice Management system, call toll free: or visit us online at Clinicient Inc. All rights reserved.