Office of Billing Compliance 2014 Professional Coding, Billing and Documentation Program

Office of Billing Compliance 2014 Professional Coding, Billing and Documentation Program Psychiatry Prepared by: Medical Compliance Services, Miller School of Medicine/University of Miami and Compliance Concepts, Inc. April 2014 1

What is a Compliance Program? 7 Elements of an Effective Compliance Program A centralized process to promote honest, ethical behavior in the day-to-day operations of an organization, which will allow the organization to identify, correct, and prevent illegal conduct. It is a system of: FIND FIX PREVENT The University of Miami implemented the Billing Compliance Plan on November 12, 1996. The components of the Compliance Plan are: 1. Policies and Procedures 2. Having a Compliance Officer and Compliance Committees 3. Effective Training and Education 4. Effective Lines of Communication (1-877-415-4357 or 305-243-5842) 5. Disciplinary Guidelines 6. Auditing and Monitoring 7. Detect Non-Compliance Issues and Develop Corrective Action Plans 2 2

The Government In order to address fraud and abuse in the Healthcare Field, the government has on-going reviews and investigations nationally to detect any actual or perceived waste and abuse. The Government does believe that the majority of Healthcare providers deliver quality care and submit accurate claims. However, the amount of money in the healthcare system, makes it a prime target for fraud and abuse. Centers for Medicare and Medicaid Services (CMS) Estimates > $50 Billion In Payment Errors Annually in Healthcare OIG reported that in FY 2013 that $5.8 billion was recovered from auditing providers 3 3

Health Care Laws There are five important health care laws that have a significant impact on how we conduct business: False Claims Act Health Care Fraud Statute Anti-Kickback Statute Stark Law Sunshine Act Requires manufacturers of drugs, medical devices and biologicals that participate in U.S. federal health care programs to report certain payments and items of value >$10 given to physicians and teaching hospitals. 4

False Claims Act : United States Code Title 31 3729-3733 What is a False Claim? A false claim is the knowing submission of a false or fraudulent claim for payment or approval or the use of a false record that is material to a false claim. OR Reckless disregard of the truth or an attempt to remain ignorant of billing requirements are also considered violations of the False Claims Act. 5

How do you create a False Claim? One method is to submit a claim form to the government This certification forms the basis for a false claim. 6

MEDICAL NECESSITY Quality & Cost: Emphasis on Pay-for- Performance 7

Quality & Cost: Emphasis on Pay-for- Performance PQRS & Meaningful Use Practitioner reimbursement will likely be tied to outcomes soon. Some experts say that the CMS penalties for not participating in the Physician Quality Reporting System (PQRS) signal that the pay-for-performance trend is not fading away and will likely will be adopted by private payers. I think we re slowly transitioning out of fee-for-service and into a system that rewards for quality while controlling cost, says Miranda Franco, government affairs representative for the Medical Group Management Association. The intent of CMS is to have physicians moving toward capturing quality data and improving metrics on [them]. 8

Medical Necessity for E/M Services Audits are being conducted for all payer types based on the medical necessity of procedures and E/M levels. Procedure are often linked to diagnosis codes and the E/M audits are generally expressed in two ways in conjunction with the needs of the patient: Frequency of services (how often the patients are being seen) and, Intensity of service (level of CPT code billed). 9

Elements of Medical Necessity CMS s determination of medical necessity is separate from its determination that the E/M service was rendered as billed. Complexity of documented co-morbidities that clearly influenced physician work. Physical scope encompassed by the problems (number of physical systems affected by the problems). 10

Referring Page: http://www.cgsmedicare.com/kyb/coverage/mr/articles/em_volume.html November 2012 E/M Coding: Volume of Documentation versus Medical Necessity Word processing software, the electronic medical record, and formatted note systems facilitate the "carry over" and repetitive "fill in" of stored information. Even if a "complete" note is generated, only the medically reasonable and necessary services for the condition of the particular patient at the time of the encounter as documented can be considered when selecting the appropriate level of an E/M service. Information that has no pertinence to the patient's situation at that specific time cannot be counted. An ISO 9001:2008 certified company 11

Office of the Inspector General (OIG) Audit Focus Annually OIG publishes it "targets" for the upcoming year. Included is: Cutting and Pasting Documentation in the EMR REMEMBER: More volume is not always better in the medical record, especially in the EMR with potential for cutting/pasting, copy forward, pre-defined templates and pre-defined E/M fields. Ensure the billed code is reflective of the service provided on the DOS. 12

Medical Record Documentation Standards Pre EMR: If it isn t documented, it hasn t been done. - Unknown Post EMR: If it was documented, was it done and was it medically necessary to do. - Reviewers 13

EMR Documentation Pitfalls On reviews, the following are targets to call into question EMR documentation is original and accurate: HPI and ROS don t agree HPI and PE don t agree CC is not addressed in the PE ROS and PFSH complete on every visit ROS all negative when patient coming for a CC Identical documentation across services (cloning) The lack of or Inappropriate Teaching Physician Attestations 14

Top Procedure Codes Billed in Q4 2013 Top 5 Description % Procedure 90834 PSYCHOTHERAPY PATIENT &/ FAMILY 45 MINUTES 17% 96118 PSYCH/NEUROPSYCH TESTS 2% 90791 PSYCHIATRIC DIAGNOSTIC EVAL 2% 90792 PSYCHIATRIC DIAGNOSTIC EVAL W/MEDICAL SERVICES 2% 90870 ELECTROCONVULSIVE THERAPY,1 SEIZ 2% All other Procedure Codes 75% Top 5 E&M Description % 99232 SUBSEQUENT HOSPITAL 24% 99213 OFFICE/OUTPT 21% 99231 SUBSEQUENT HOSPITAL 16% 99214 OFFICE/OUTPT 9% 99223 INITIAL HOSPITAL 6% All other E/M Codes 24% 15

National CMS Data For Speciality E/M 45% 40% 35% 30% 25% 20% 15% 10% 5% 0% 42% 27% 17% 11% 4% 99211 99212 99213 99214 99215 Psychiatry National Dist. 16

National CMS Data For Speciality E/M 60% 50% 40% 30% 20% 10% 0% 51% 32% 17% 99231 99232 99233 Psychiatry National Dist. 17

Evaluation and Management E/M Documentation and Coding Inpatient, Outpatient and Consultations 18

New vs Established Patient for E/M Outpatient Office and Preventive Medicine https://questions.cms.gov/faq.php?id=5005&faqid=1969 What is the definition of "new patient" for billing E/M services? New patient" is a patient who has not received any professional services, i.e., E/M service or other face-to-face service (e.g., Procedure) from the same physician or another physician in the same group practice (same group NPI# and physician specialty) within the previous three years. An interpretation of a diagnostic test, reading an x-ray or EKG etc., in the absence of an E/M service or other face-to-face service with the patient does not affect the designation of a new patient. In 2012, the AMA CPT instructions for billing new patient visits include physicians in the same specialty and subspecialty. However, for Medicare E/M services the same specialty is determined by the physician's or practitioner's primary specialty enrollment in Medicare. 19

20 E/M Key Components History (HX)- Subjective information Examination (PE)- Objective information Medical Decision Making (MDM)- Linked to medical necessity The billable service is determined by the combination of these 3 key components with MDM often linked to medical necessity. For new patients all 3 components must be met or exceeded and established patient visits 2 of 3 are required to be met or exceeded. Often when downcoded for medical necessity it is determined that documented History and Exam exceeded what was necessary for the visit.

Elements of an E/M History The extent of information gathered for history is dependent upon clinical judgment and nature of the presenting problem. Documentation of the patient s history includes some or all of the following elements: Chief Complaint (CC) & History of Present Illness (HPI) WHY IS THE PATIENT BEING SEEN TODAY Review of Systems (ROS), Past Family, Social History (PFSH). 21

History of Present Illness (HPI) A KEY to Support Medical Necessity to in addition to MDM Chronological description of the patient s present illness from the first sign/symptom or from the previous encounter to the present. HPI: Current symptoms, depression/mania/psychosis screen, safety, compliance, stressors, ETOH/Drugs (inc w/d) HPI drivers: Extent of PFSH, ROS and physical exam performed Medical necessity for amount work performed and documented & Medical necessity for E & M assignment The HPI must be performed and documented by the billing provider for New Patients in order to be counted towards the New Patient level of service billed. 22

Review of Systems (ROS) 1 ROS documented = Pertinent 2-9 ROS documented = Extended 10 + = Complete (or documentation of pertinent positive and negative ROS and a notation all others negative. This would indicate all 14 ROS were performed and would be complete.) Record positives and pertinent negatives. Never note the system(s) related to the presenting problem as "negative". When using "negative" notation, always identify which systems were queried and found to be negative. 23

Past, Family, and/or Social History Past History includes illnesses, operations, injuries or treatments : (remember to ask about TBI) Family history includes a review of medical events, : mental illness, substance abuse, suicide Social history includes an age-appropriate review of past and current activities (e.g., smoking, marital status, employment status, education, income/employment/ disability, living situation, marriage/partner/kids, legal, hx trauma/abuse.) Record Past/Family/Social History (PFSH) appropriately considering the clinical circumstance of the encounter. Extensive PFSH is unnecessary for lower-level services. Don't use the term "non-contributory" 24

Psychiatric 1997 EXAMINATION 4 TYPES OF EXAMS Problem focused (PF) Expanded problem focused (EPF) Detailed (D) Comprehensive (C) Axis I. Psychiatric d/o including Substance abuse Axis II. Personality d/o and developmental disorders Axis III. Medical Problems 25

Constitutional MS Psychiatric PSYCH Examination Measurement of any three of the following seven vital signs: 1) sitting or standing blood pressure, 2) supine blood pressure, 3) pulse rate and regularity, 4) respiration, 5) temperature, 6) height, 7) weight (May be measured and recorded by ancillary staff) General appearance of patient (eg, development, nutrition, body habitus, deformities, attention to grooming) Assessment of muscle strength and tone (eg, flaccid, cog wheel, spastic) with notation of any atrophy and abnormal movements Examination of gait and station Description of speech including: rate; volume; articulation; coherence; and spontaneity with notation of abnormalities (eg, perseveration, paucity of language) Description of thought processes including: rate of thoughts; content of thoughts (eg, logical vs. illogical, tangential); abstract reasoning; and computation Description of associations (eg, loose, tangential, circumstantial, intact) Description of abnormal or psychotic thoughts including: hallucinations; delusions; preoccupation with violence; homicidal or suicidal ideation; and obsessions Description of the patient s judgment (eg, concerning everyday activities and social situations) and insight (eg, concerning psychiatric condition) Complete mental status examination including: Orientation to time, place and person Recent and remote memory Attention span and concentration Language (eg, naming objects, repeating phrases) Fund of knowledge (eg, awareness of current events, past history, vocabulary) Mood and affect (eg, depression, anxiety, agitation, hypomania, lability) Page 26

1997 Exam Definitions Problem Focused (PF) 97=Specialty and GMS: 1-5 elements identified by bullet. Expanded Problem Focused (EPF) 97=Specialty and GMS: At least 6 elements identified by bullet. Detailed (D) 97=Specialty: At least 9 elements identified by bullet for psyc Comprehensive (C) 97=Specialty: All elements with bullet in shaded areas and at least 1 in non-shaded area. 27

Medical Decision Making DOCUMENT EVERYTHING THAT EFFECTS YOUR SERVICE!! Exchange of clinically reasonable and necessary information and the use of this information in the clinical management of the patient Step 1: Number of possible diagnosis and/or the number of management options. Step 2: Amount and/or complexity of data reviewed, diagnostic tests, and/or other information that must be obtained, reviewed, and analyzed. Step 3: The risk of significant complications, morbidity, and/or mortality with the patient s problem(s), diagnostic procedure(s), and/or possible management options. Note: The 2 most complex elements out of 3 will determine the overall level of MDM 28

29 MDM Step 1 Number of Diagnosis or Treatment Options Identify Each That Effects Patient Care For The DOS Problem(s) Status Self-limited or minor (stable, improved or worsening) Est. Problem (to examiner) stable, improved Number Points Results Max=2 1 Est. Problem (to examiner) worsening 2 New problem (to examiner); no additional workup planned Max=1 3 New prob. (To examiner); additional workup planned Total 1 4 1 POINT: E- 2, NEW-1,2 2 POINTS: E-3, NEW-3 3 POINTS: E-4, NEW-4 4 POINTS: E-5. NEW-5

MDM Step 2 Amount and/or Complexity of Data Reviewed Total the points REVIEWED DATA Points Review and/or order of clinical lab tests 1 Review and/or order of tests in the radiology section of CPT 1 Review and/or order of tests in the medicine section of CPT 1 Discussion of test results with performing physician 1 Decision to obtain old records and/or obtain history from someone other than patient Review and summarization of old records and/or obtaining history from someone other than patient and/or discussion of case with another health care provider Independent visualization of image, tracing or specimen itself (not simply review of report). Total 1 2 2 1 POINT: E- 2, NEW-1,2 2 POINTS: E-3, NEW-3 3 POINTS: E-4, NEW-4 4 POINTS: E-5. NEW-5 30

MDM Step 3: Risk The risk of significant complications, morbidity, and/or mortality is based on the risks associated with the presenting problem(s), the diagnostic procedure(s), and the possible management options. DG: Comorbidities/underlying diseases or other factors that increase the complexity of medical decision making by increasing the risk of complications, morbidity, and/or mortality should be documented. Risk is assessed based on the risk to the patient between present visit and the NEXT time the patient will be seen by billing provider or risk for planned intervention 31

Presenting Problem Min One self-limited / minor problem Low 2 or more self-limited/minor problems 1 stable chronic illness (controlled HTN) Diagnostic Procedure(s) Ordered Labs requiring venipuncture CXR EKG/ECG UA MDM Step 3: Risk (barium enema) Acute uncomplicated illness / injury (simple sprain) Mod 1 > chronic illness, mod. Exacerbation, progression or side effects of treatment 2 or more chronic illnesses Undiagnosed new problem w/uncertain prognosis Acute illness w/systemic symptoms (colitis) Acute complicated injury High 1 > chronic illness, severe exacerbation, progression or side effects of treatment Acute or chronic illnesses that may pose threat to life or bodily function (acute MI) Abrupt change in neurologic status (TIA, seizure) Physiologic tests not under stress (PFT) Non-CV imaging studies Superficial needle biopsies Labs requiring arterial puncture Skin biopsies Physiologic tests under stress (stress test) Diagnostic endoscopies w/out risk factors Deep incisional biopsies CV imaging w/contrast, no risk factors (arteriogram, cardiac cath) Obtain fluid from body cavity (lumbar puncture) CV imaging w/contrast, w/risk factors Cardiac electrophysiological tests Diagnostic endoscopies w/risk factors Management Options Selected Rest Elastic bandages Gargles Superficial dressings OTC meds Minor surgery w/no identified risk factors PT, OT IV fluids w/out additives Prescription meds Minor surgery w/identified risk factors Elective major surgery w/out risk factors Therapeutic nuclear medicine IV fluids w/additives Closed treatment, FX / dislocation w/out manipulation Elective major surgery w/risk factors Emergency surgery Parenteral controlled substances Drug therapy monitoring for toxicity DNR 32

Draw a line down any column with 2 or 3 circles to identify the type of decision making in that column. Otherwise, draw a line down the column with the 2 nd circle from the left. After completing this table, which classifies complexity, circle the type of decision making within the appropriate grid. Final Result for Complexity A Number diagnoses or treatment options < 1 Minimal 2 Limited 3 Multiple > 4 Extensive B Highest Risk Minimal Low Moderate High C Amount and complexity of data < 1 Minimal or low 2 Limited 3 Multiple > 4 Extensive Type of decision making STRAIGHT- FORWARD LOW COMPLEX. MODERATE COMPLEX. HIGH COMPLEX. 33

USING DIFFERENT LEVELS OF CARE 99223 * PATIENT ADMITTED 99233 * (PT. IS UNSTABLE) 99232 * (PT. HAS DEVELOPED MINOR COMPL.) 99231 * (PT. IS STABLE, RECOVERING, IMPROVING) 99238 or * 99239 PATIENT DISCHARGED

Using Time to Code Time shall be considered for coding an E/M level when greater than 50% of total Teaching Physician visit time is Counseling /Coordinating Care Total time must be Face-to-face for OP and floor time / face-to-face for IP 47 35

What Is Counseling /Coordinating Care (CCC)? A Discussion of: Diagnostic results, impressions, and/or recommended studies Prognosis Risks and benefits of management Instructions for treatment and/or follow-up Importance of compliance Required Documentation: Total time of the encounter John Doe MR# 11122234 D.O.S. 9/15/014 Patient counseled regarding health risk, contraceptives, exercise, and usage of medication. Counseling Time: 20min. Total Encounter Time: 30 min. The amount of time dedicated to counseling / coordination of care The nature of counseling/coordination of care 48 36

Working With NP's and PA's (NPP's) The NP or PA MUST BE AN EMPLOYEE OF THE PRACTICE AND CANNOT BE A HOSPITAL EMPLOYEE TO UTILIZE ANY OF THEIR DOCUMENTATION FOR PHYSICIAN BILLING AS SHARED Shared visit with an NPP may be billed under the physician's name only if: The physician provides a face-to-face portion of the visit and The physician personally documents in the patient's record the portion of the E/M encounter with the patient they provided. If the physician does not personally perform or personally and contemporaneously document their face-to-face portion of the E/M encounter with the patient, then the E/M encounter may only be billed under the PA/ARNP's name and provider number Procedures must be billed under the performing provider & not the supervisor. They cannot be shared 37

Guidelines for Teaching Physicians, Interns, Residents and Fellows For Billing Services, All Types of Services Involving a Teaching Physician (TP) Requires Attestations In EHR or Paper Charts 38

Evaluation and Management (E/M) IP or OP: TP must personally document at least the following: That s/he performed the service or was physically present during the key or critical portions of the service when performed by the resident; AND The participation of the teaching physician in the management of the patient. Example: I saw and examined the patient and agree with the resident s note Time Based E/M Services: The TP must be present and document for the period of time for which the claim is made. Examples : Critical Care, Hospital Discharge (>30 minutes) or E/M codes where more than 50% of the TP time spent counseling or coordinating care Psychotherapy Medical Student documentation for billing only counts for ROS and PFSH 39

Teaching Physicians and Mental Health When psychiatric services are furnished under an approved AC- GME program, the requirement for the presence of the teaching physician during the service may be met by: Concurrent observation of the service by use of a one-way mirror or video equipment. Note the following: Audio-only equipment does not meet this exception to the physical presence requirement. In the case of time-based services such as individual medical psychotherapy, the teaching physician must be present throughout the session Medicare teaching physician policy does not apply to psychologists who supervise psychiatry residents in approved GME programs. Page 40 40

Unacceptable TP Documentation Assessed and Agree Reviewed and Agree Co-signed Note Patient seen and examined and I agree with the note As documented by resident, I agree with the history, exam and assessment/plan 41

42 Psychiatric Diagnostic Evaluation CPT 90791 & With Medical Evaluation CPT 90792 These codes require the same documentation as the previous Psychiatric Diagnostic Interview codes (90801-90802) A psychiatric diagnostic evaluation is performed, which includes the assessment of the patient's psychosocial history, current mental status, review, and ordering of diagnostic studies followed by appropriate treatment recommendations. In 90792, additional medical services such as physical examination and prescription of pharmaceuticals are provided in addition to the diagnostic evaluation. Interviews and communication with family members or other sources are included in these codes.

Psychiatric Diagnostic Evaluation CPT 90791 With Medical Evaluation CPT 90792 The evaluation must include Name of beneficiary and date of service Reason for referral / presenting problem Prior psychological history, including therapy Other pertinent medical, social and family history Clinical observations and mental status examination Present evaluation Diagnosis Recommendations Identity of provider of service The evaluation may include Communication with family or other sources, Ordering and medical interpretation of laboratory tests and other medical diagnostic studies, as appropriate. Use of interactive tools or techniques 43

Common Coding Questions 1. Directions for billing when a patient is admitted to the Psych Facility and then develops a medical problem requiring discharge from the unit and admission to the medical unit. 2. Directions for billing when a patient is initially seen in the medical hospital as a Consultation, who is later discharged from the medical hospital and admitted to a Psych Facility. Medicare Claims Processing (PUB. 100-04) Manual History Chapter 12 30 - Correct Coding Policy 30.6.9.1 - Payment for Initial Hospital Care D - Physician Services Involving Transfer From One Hospital to Another; Transfer Within Facility to Prospective Payment System (PPS) Exempt Unit of Hospital; Transfer From One Facility to Another Separate Entity Under Same Ownership and/or Part of Same Complex; or Transfer From One Department to Another Within Single Facility 44

Common Coding Questions Physicians may bill both the hospital discharge management code and an initial hospital care code when the discharge and admission do not occur on the same day if the transfer is between: 1. Different hospitals; 2. Different facilities under common ownership which do not have merged records; or 3. Between the acute care hospital and a PPS exempt unit within the same hospital when there are no merged records. In all other transfer circumstances, the physician should bill only the appropriate level of subsequent hospital care for the date of transfer. 45

Individual Psychotherapy Psychotherapy codes are no longer site specific Psychotherapy time includes face-to-face time spent with the patient and/or family member Interactive psychotherapy is reported using the appropriate psychotherapy code along with the interactive complexity add-on code 90832, Psychotherapy, 30 minutes 90834, Psychotherapy, 45 minutes 90837, Psychotherapy, 60 minutes 90832 plus 90875, Psychotherapy, 30 minutes with interactive complexity add-on 90834 plus 90875, Psychotherapy, 45 minutes with interactive complexity add-on 90837 plus 90875, Psychotherapy, 60 minutes with interactive complexity add-on 46

Psychotherapy with E/M Services Psychotherapy with E/M is now reported by selecting the appropriate E/M service code (99xxx series) and the appropriate psychotherapy add-on code The E/M code is selected on the basis of the site of service and the key elements performed The psychotherapy add-on code is selected on the basis of the time spent providing psychotherapy and does not include any of the time spent providing E/M services If no E/M services are provided, use the appropriate psychotherapy code (90832, 90834, 90837) 47

E/M Services with Psychotherapy If Psychotherapy is provided in addition to the E/M use the Psychotherapy add-on codes The psychotherapy add-on codes +90833 (30 min.), +90836 (45 min.), or +90838(60 min.) can be billed with the following E/M codes: Outpatient, established patient: 99212 99215 Subsequent hospital care: 99231 99233 Subsequent nursing facility care: 99307 99310 Subsequent ALF care: 99334 99337 Subsequent home care; 99341 99345 If no E/M services are provided, use the appropriate psychotherapy code (90832, 90834, 90837) 48

Psychotherapy for Crisis Crisis Psychotherapy 90839, Psychotherapy for crisis, first 60 minutes (30-74 minutes) +90840, Psychotherapy for crisis each additional 30 minutes Crisis Psychotherapy is an urgent assessment and history of a crisis state, a mental status exam, and a disposition. The treatment includes psychotherapy, mobilization of resources to defuse the crisis and restore safety, and implementation of psychotherapeutic interventions to minimize the potential for psychological trauma. The presenting problem is typically life threatening or complex and requires immediate attention to a patient in high distress. 49

Pharmacologic Management Psychiatrists should use the appropriate E/M service code (99xxx) to report Pharmacologic Management. Physicians SHOULD NOT use this code The add-on code + 90863 has been added to describe pharmacologic management when performed by a prescribing psychologist during the same session as the psychotherapy. 50

Electroconvulsive Therapy (ECT) 90870 Indications: Major depressive episode and/or major depressive disorder that meet the criteria according to the DSM-IV. Depression with acute suicide risk, extreme agitation, or unresponsive to pharmacological therapy. Bipolar illness with either mania or depression where medications are ineffective or not tolerated, or severe mania presenting a safety risk to the patient or to others. Intolerance to the side effects of antidepressant medication or to antidepressant or psychotropic medications that pose a particular medical risk. When rapid resolution of depression is necessary, e.g., the patient is acutely suicidal or physically compromised, and the time factor to achieve maximal effectiveness of antidepressants or mood stabilizers places the patient at immediate risk to health or safety. Inability to medically tolerate maintenance medication. Catatonia Acute schizophrenia, or severe, life-threatening psychoses, which have not responded to, or cannot be treated with short term, high dose tranquilization. When continuation of ECT treatments is necessary to sustain remission or to sustain significant improvement. 51

Electroconvulsive Therapy (ECT) Documentation Requirements The medical record documentation will provide an explanation of why ECT is prescribed and must meet the conditions stated in the Indications and Limitations of Coverage and/or Medical Necessity section of the LCD. Any clinical history supporting the use of ECT needs to clearly document the medical reasonable and necessary conditions as described in the indications and limitations section on the policy Documentation supporting the medical necessity of this procedure must be a part of and kept in the medical record. It must be available upon request. Failure to provide the required documentation will result in a denial of the claim(s). Documentation should include, but is not limited to, the following: History and Physical Examination. Medical record containing established psychiatric diagnosis according to the DSM-IV. Medical records containing the patient s evaluation and management findings and treatments with relevant clinical signs, symptoms, and/or abnormal diagnostic/lab tests. The clinical record should further indicate changes/alterations and response or non-response to medical management or treatment of the patient s condition and 52

Electroconvulsive Therapy (ECT) Documentation should include, but is not limited to, the following: History and Physical Examination. Medical record containing established psychiatric diagnosis according to the DSM-IV. Medical records containing the patient s evaluation and management findings and treatments with relevant clinical signs, symptoms, and/or abnormal diagnostic/lab tests. The clinical record should further indicate changes/alterations and response or non-response to medical management or treatment of the patient s condition and reflect the continued need and appropriateness of ECT based on psychiatrist s ongoing assessment and mental status examination of the patient during the course of treatments. It is understood that any diagnostic and clinical information submitted and presented in the medical record must substantiate that the components of the procedure performed and billed were actually performed. Procedure Record. 53

Electroconvulsive Therapy (ECT) Utilization Guidelines Tests for screening purposes that are performed in the absence of signs, symptoms, complaints, or personal history of disease or injury will be considered non-covered. Exams required by insurance companies, business establishments, government agencies, or other third parties, without rationale for necessity will be denied. Tests that are not reasonable and necessary for the diagnosis or treatment of an illness or injury are not covered according to the statute. Failure to provide documentation of the medical necessity of tests will result in denial of claims. 54

Neuropsychological Testing 96118 NEUROPSYCHOLOGICAL TESTING (EG, HALSTEAD-REITAN NEUROPSYCHOLOGICAL BATTERY, WECHSLER MEMORY SCALES AND WISCONSIN CARD SORTING TEST), PER HOUR OF THE PSYCHOLOGIST S OR PHYSICIAN S TIME, BOTH FACE-TO-FACE TIME ADMINISTERING TESTS TO THE PATIENT AND TIME INTERPRETING THESE TEST RESULTS AND PREPARING THE REPORT The psychological/neuropsychological testing codes should not be reported by the treating physician for only reading the testing report or explaining the results to the patient or family. Payment for these services is included in the payment for other services rendered to the patient, such as evaluation and management services. Psychological and neuropsychological testing codes should be reported by the performing provider (i.e., clinical psychologist, neuropsychologist, or physician) who administered the test. Testing conducted when no mental illness/disability is suspected would be considered screening and would not be covered by Medicare. Non-specific behaviors that do not suggest the possibility of mental illness or disability are not an acceptable indication for testing. 55

Neuropsychological Testing Documentation Requirements The medical record must indicate testing is necessary as an aid in the diagnosis and therapeutic planning. The record must show the tests performed, scoring and interpretation, as well as the time involved for services that are time-based. The medical record should include all of the following information: Reason for referral. Tests administered, scoring/interpretation, and time involved. Present evaluation. Diagnosis (or suspected diagnosis that was the basis for the testing if no mental/neurocognitive illness was found). Recommendations for interventions, if necessary. Identity of person performing service. 56

Neuropsychological Testing Psychological testing/neuropsychological testing may require four (4) to six (6) hours to perform (including administration, scoring, and interpretation.) If the testing is done over several days, the testing time should be combined and reported all on the last date of service. Supporting documentation in the medical record must be present to justify the medical necessity and hours tested per patient per evaluation. If the testing time exceeds eight (8) hours, medical necessity for the extended testing should be documented in the report. Use of such tests when mental or neurocognitive illness is not suspected would be a screening procedure not covered by Medicare. Each test performed must be medically necessary. Therefore, standardized batteries of tests are not acceptable unless each test in the battery is medically necessary. Routine re-evaluation of chronically disabled patients that is not required for a diagnosis or continued treatment is not medically necessary. 57

2014 CPT Code Changes Interprofessional consultations New codes to report interprofessional ( doctor-to-doctor ) telephone/internet consulting. Code 99446 is defined as an interprofessional telephone/internet assessment and management service provided by a consultative physician, including a verbal and written report to the patient s treating/requesting physician or other qualified health care professional, and involves 5 to 10 minutes of medical consultative discussion and review. 99447: 11 to 20 minutes of medical consultative discussion and review 99448: 21 to 30 minutes of medical consultative discussion and review 99449: 31 minutes or more of medical consultative discussion and review 58

2014 CPT Code Changes Interprofessional consultations The services will typically be provided in complex and/or urgent situations where a timely face-to-face service with the consultant may not be possible. The written or verbal request, its rationale, and the conclusion for telephone/internet advice by the treating/requesting physician or other qualified health care professional should be documented in the patient s medical record. Medicare allowable $0.00 59

Increased specificity of the ICD-10 codes requires more detailed clinical documentation to code some diagnoses to the highest level of specificity. Coding and documentation go hand in hand ICD-10 based on complete and accurate documentation, even where it comes to right and left or episode of care. ICD-10 should impact documentation as physicians are required to support medical necessity using appropriate diagnosis code this is not an easy situation. Will not change the way a physician practices medicine 60

HIPAA Final Reminders for All Staff, Residents, Fellows or Students Health Insurance Portability and Accountability Act HIPAA Protect the privacy of a patient s personal health information Access information for business purposes only and only the records you need to complete your work. Notify Office of HIPAA Privacy and Security at 305-243-5000 if you become aware of a potential or actual inappropriate use or disclosure of PHI, including the sharing of user names or passwords. PHI is protected even after a patient s death!!! Never share your password with anyone and no one use someone else s password for any reason, ever even if instructed to do so. If asked to share a password, report immediately. 61

Any Questions 62

Available Resources at University of Miami, UHealth and the Miller School of Medicine If you have any questions or concern regarding coding, billing, documentation, and regulatory requirements issues, please contact: Gemma Romillo, Assistant Vice President of Clinical Billing Compliance and HIPAA Privacy; or Iliana De La Cruz, RMC, Director Office of Billing Compliance Phone: (305) 243-5842 Officeofbillingcompliance@med.miami.edu Also available is The University s fraud and compliance hotline via the web at www.canewatch.ethicspoint.com or toll-free at 877-415-4357 (24hours a day, seven days a week). Office of billing Compliance website: www.obc.med.miami.edu 63