Electronic Medical Records: Auditing Challenges and Associated Risks



Similar documents
Electronic Medical Records: Auditing & Training Physicians

EMR Pearls and Perils Presented by Bruce Rappoport, MD, CPC, CHCC

6/8/2012. Cloning and Other Compliance Risks in Electronic Medical Records

5/2/2014. Beginning Biller / Coder 101 Thursday, May 8 1:00 p.m. to 2:30 p.m. Disclaimer. Stay in touch through Facebook Please note

EMR Pearls and Perils

Gone are the days when healthy

Modifiers 25 and 59. Modifier 25

EHR Support for Provider Coding

How to Improve Your Revenue Cycle Processes in a Clinic or Physician Practice

Balancing Compliance & Quality Templates, Encounter Forms & Electronic Medical Records..

Payment Policy. Evaluation and Management

CPT Coding in Oral Medicine

Optimizing Coding in Primary Care, Part 1

IMPLEMENTING AND MAINTAINING ELECTRONIC MEDICAL RECORDS

Revenue Integrity Boot Camp. Coding. Agenda

Compliance Risks with Non-Physician Practitioners

Compliance Risks with Non-Physician Practitioners

How To Write A Health Insurance Claim Form

Coding for Evaluation and Management Services

8/28/2013. Lessons Learned in the EHR. Documentation risks in an EMR AGENDA

9/15/2015. Learning objectives. Coding and compliance. Coding Compliance for the IDS Environment. Could Your Coding be Costing You Money?

How To Know If You Can Test For A Mental Health Test On A Medicare Card

Best ASC Billing Practices & Potential Issues

Medicare Physician Fee Schedule Modifiers

MEDICAL ASSISTANCE BULLETIN

Medicare 101: Basics of Modifier Billing. Part B Provider Outreach and Education February 26, 2014

There are two levels of modifiers: Level 1 (CPT) and Level II (CMS, also known as HCPCS).

5/16/2014. Revenue Cycle Impact Documentation risks in an EMR AGENDA. EMR Challenges Related to Billing and Revenue Cycle

2010 Medicare Part B Consultation Coding Changes 1/26/2010 & 1/27/2010

Appropriate Modifier Usage

E/M Documentation: Deal or No Deal? Documentation Guidelines. Documentation Elements 3/25/2013

Shellie Sulzberger, LPN, CPC, ICDCT-CM. Coding & Compliance Initiatives, Inc.

Special Investigations Unit (SIU) Coding and Auditing of Behavioral Health Services

Electronic Medical Records Friend or Foe?

VEI Consulting Services Evaluation and Management Update. Effective January 1, 2013

Nurse Practitioners in Long-Term Care. Mobile Medical and Nursing Inc.

Re: Horizon Blue Cross Blue Shield of New Jersey Inappropriate Application of Modifier 25

UNRAVELING THE MYSTERY OF INSURANCE AUDITS. Deborah J. Winegard Of Counsel Whatley Kallas, LLP

2008 Online Coding Seminars

HOW TO PREVENT AND MANAGE MEDICAL CLAIM DENIALS TO INCREASE REVENUE

Medicare- Tennessee Overview

Payment for Physician Services in Teaching Settings Under the MPFS Evaluation and Management (E/M) Services

Meeting the ICD-10 Compliance Date. Are You Going to Be Ready?! HCCA Regional Conference November 2011

IMPROPER PAYMENTS FOR EVALUATION AND MANAGEMENT SERVICES COST MEDICARE BILLIONS

Modifier Magic 4/13/2015. Modifiers. Anatomical Modifiers. April 15, 2015 MMBA

UNIVERSITY OF WASHINGTON SCHOOL OF DENTISTRY. Medicare Teaching Physician Billing Rules. Effective Date: February 1, 2009

AGENDA WHAT IS COMPUTER-ASSISTED CODING, REALLY? J03.0 F43.0 I10 A78 R52

The Changing Face of Medical Necessity under ICD-10

ICD-10: A Coders Perspective

Shellie Sulzberger, LPN, CPC, ICDCT-CM Coding & Compliance Initiatives, Inc.

Understanding Coding & Reimbursement for SBI. Presented By: Jen Cohrs CPC, CPMA, CGIC Director of Educational Strategies Wisconsin Medical Society

Importance of Auditing

MODIFIERS. Original Effective Date: July 7, 2009 Revision Date: February 1 st, 2014

MEDICARE TEACHING PHYSICIAN QUESTIONS & ANSWERS December 2003

APR,: Charlene Frizzera Acting Administrator Centers for Medicare & Medicaid Services. FROM: Daniel R. Levinson ~,u,l, ~.~ Inspector General

UNIVERSITY OF FLORIDA COLLEGE OF MEDICINE/JACKSONVILLE TEACHING PHYSICIAN BILLING POLICY August

Intra-operative Nerve Monitoring Coding Guide. March 1, 2011

Improving the Clinic Revenue Cycle. Through Cross-Functional Documentation

Billing, Coding and Reimbursement Guide

E/M coding workshop. The risk of not getting it right. PAMELA PULLY CPC, CPMA BILLING/CLAIMS SUPERVISOR GENESEE HEALTH SYSTEM

Non-Physician Practitioner Services Coding & Reporting. Karla R. Peter, RHIT, CCS, CCS-P, CPC Avera Health September 6, 2013

Page 1 of 11. MLN Matters Number: SE1010 REVISED Related Change Request (CR) #: Related CR Release Date: N/A Effective Date: January 1, 2010

Coding and Billing Guidelines *Psychiatry and Psychology Services PSYCH L Contractor Name Wisconsin Physicians Service (WPS)

ICD-10-CM Training Module for Dental Practitioners. Presented by Workgroup for Electronic Data Interchange

Navigating Compliance Landmines in Electronic Health Record (EHR) Documentation

HI-1018: The Electronic Health Record

Electronic Health Records: Issues, Concerns, and Best Practices

Split/Shared Services Documentation & Billing

REIMBURSEMENT CODING SERIES

Modifiers. This modifier can be located in the following rule(s): Anesthesia Global Maternity

AAPC Annual Conference Nashville, Tennessee April 13-16, Incident-to Billing and Scope of Practice: Staying Compliant with Both is no Easy Task!

The ASA defines anesthesiology as the practice of medicine dealing with but not limited to:

Professional Coders Role in Compliance

Objective of Presentation

AMERICAN OSTEOPATHIC ASSOCIATION

Documentation Guidelines for Physicians Interventional Pain Services

Mitigating Coding Risks. Concerns with electronic records and overcoding. Balancing Medical Necessity and Meaningful Use 2/20/2014

PHYSICAL PRESENCE REQUIREMENTS and DOCUMENTATION REQUIREMENTS (see Attachment I Acceptable Documentation Templates)

Modifier Usage Guide What Your Practice Needs to Know

Intraoperative Nerve Monitoring Coding Guide. March 1, 2010

Coding with the CPT. By: Amber M. Baylor, M.S.

THE VALUE OF A COMPLETE CODING QUALITY AUDIT PROGRAM. By Lisa Marks, RHIT, CCS, Coding Audit Director, Precyse

Anesthesia Billing: 101. Presented by: Medi-Corp, Inc

The following instructions are taken directly from the Consultations section of CPT:

2013 CODING & DOCUMENTATION UPDATE. Health Care Services Group October/November 2012

Question and Answer Submissions

ICD-10 Action Plan: Your 12-Step Transition Plan for ICD-10. Written by the AMA CPT Medical Informatics Department

REIMBURSEMENT CODING SERIES

Try This for Medicare Fraud (Well, At Least Abuse) Part II Riva Lee Asbell

The Official Guidelines for coding and reporting using ICD-9-CM

Coding for the Internist: The Basics

Modifiers. Disclaimer

Zimmer Payer Coverage Approval Process Guide

ENGAGING PHYSICIANS FOR ICD-10: ALL ABOARD Engaging Physicians for ICD-10: All Aboard

Compliance Department SURGERY AND SURGICAL MODIFIERS 11/2010

Basic Rural Health Clinic Billing

Common Billing Mistakes Costing Your ASC Money and Correct Modifier & Revenue Code Usage for ASC Claims

Outpatient Therapy Services

Five Things to Jump Start Your ICD-10 Transition. Denny Flint Complete Practice Resources Prepared for Availity

Unlisted Procedure Codes Frequently Asked Questions

Transcription:

Electronic Medical Records: Auditing Challenges and Associated Risks HCCA Compliance Institute Georgette Gustin, CPC, CCS-P, CHC Faith Marie Hope, CPC, CCS-P, CHC Nemours, Director Coding & Billing Compliance April 2009 Today s Discussion Points Impact on the coding and documentation auditing process Visit Types Time based services Modifiers Units/Quantities Conflicting diagnoses (lets discuss next time) Incident-to services Teaching Physician services Excision & Destruction Lesions Global Surgical Package Practical auditing tips Best practice discussion Questions/Answers 1 1

The way Medicare looks at an EMR, nothing has changed in its rules from using paper. Instead of pencil and paper, it s pixels and bytes. Dr. Debra Patterson Medicare Medical Director TrailBlazer Health Enterprises Medicare Compliance Alert June 2, 2008 2 Auditing Challenges Auditing EMR creates new challenges Integrity of the record Controls around access Who documented what? Signatures/authentication Cut/copy/paste features Cloning (defaulted documentation) Macro s How clinical documentation is filed within the EMR (understanding the protocols) 3 2

Auditing Challenges (cont d) Determining appropriate visit type and E&M category New Established Consultation Preventive Medicine Evaluating workflows associated with time-based codes Documentation of drugs, supplies and equipment Identifying consultation requests/written reports Interface with existing programs and processes 4 Auditing Challenges: Visit Types New versus Established Patient Specialty Designation Types Medicare Definition: Physicians Group Practice Consultations Preventive Medicine & E&M Problem Oriented Visit Same Day 5 3

Auditing Challenges: Time Based Services Analyzing all CPT codes to understand which have time elements E&M based on >50% of visit dominated by counseling and coordination of care Critical care services Genetic counseling Psychotherapy Neuropsychological testing 6 Auditing Challenges: Modifiers Depending in the EMR system functionality there maybe several places in which a modifier can be assigned at: E&M code level charge capture Procedure charge capture level 7 4

Auditing Challenges: Units/Quantities Inaccurate or missing units/quantities when appropriate Essential for time based codes such as, PT/OT services, allergy testing, etc. Applying units for codes that are not unit based (e.g., psychotherapy, E&M, etc) Incorrectly reporting units for administered medications Example, 40 mg of Kenalog injected = 4 units Multiple units to represent number of nerves for Nerve Conduction Studies 8 Auditing Challenges: Incident-to Services Identifying a plan of care has been established by the physician Evaluating whether or not the supervision requirements have been met How is this validated? Determining how new problems or new patients will be triaged with non-physician practitioners\ Make Me the Author feature 9 5

Auditing Challenges: Excision/Destruction Pre-malignant lesions Determining how the diagnosis and/or CPT code(s) will be modified for charge capture based on pathology report findings Excision of pre-malignant lesion (face, ears, eyelids, nose, lips, mucous membrane; excised diameter 1.1 to 2.0 cm) CPT code 11442 RVUs 4.53 Excision of malignant lesion (face, ears, eyelids, nose, lips, mucous membrane; excised diameter 1.1 to 2.0 cm) CPT code 11642 RVUs 6.80 Establishing protocols and training around the use of addendums 10 Auditing Challenges: Global Surgical Package Identifying multiple providers and/or specialties that maybe involved in various aspects of the global surgical package Pre-operative Intra-operative Post-operative Evaluating back-end system capabilities Process for appending modifiers Reviewing the workflow Determining which modifiers can be handled by the system vs. requiring providers to append Developing appropriate education and training for providers 11 6

Payer Concerns Cigna Cloning of documentation will be considered misrepresentation of the medical necessity requirement for coverage of services. Identification of this type of documentation will lead to denial of services for lack of medical necessity and recoupment of all overpayments made. Cigna Government Services Medical Record Cloning Documentation Reminder. Medical Bulletin Part B; March/April 1999 12 First Coast Service Options Documentation is considered cloned when each entry in the medical record for a beneficiary is worded exactly like or similar to the previous entries. Cloning also occurs when medical documentation is exactly the same from beneficiary to beneficiary. It would not be expected to see that every patient had the exact same problem, symptoms and required the same treatment. First Coast Service Options Requirements for the Payment of Medicare Claims A Selection of Some Important Criteria. Medicare Part B Update 4, No 3 (3 rd Qtr 2006) 13 7

Planning the EMR Audit Identify stakeholders: HIM Clinical Informatics Coders Physicians Compliance Internal Counsel Obtain and review the following: Policies & Procedures Departmental templates EMR process flows Training material 14 Auditing Copy Functionality If utilization of copy functionality is available as an auditable event, review a sample of it s use Review a list of patients re-admitted within a certain amount of time (i.e. within 30 days, 3 months). Randomly audit documentation such as readmissions history & physicals Review patients on a teaching service to verify original documentation by medical students & residents Consider using coders or clinical documentation specialists to identify copy practices when reviewing for chart completeness Determine if you have copy functionalities that originate in software other than the EMR such as copy in Microsoft Windows Source: AHIMA Copy Functionality Toolkit 2008 15 8

Copy Functionality Policies & Procedures Determine how & when audits will be conducted Who will perform these concurrent audits Establish frequency, time period and sample size Identifies how the sample is determined Identifies a description of the outcome indicators Determines how copy functionalities within the record are identified Establish a corrective action plan based on findings Provides a detailed list of copy functionalities as they exist in the EMR Provides testing of copy functionalities prior to implementation and prior to version upgrades Source: Journal of AHIMA/January 2009 http://library.ahima.org/xpedio/groups/public/documents/ahima/bok1_042416.hcsp?ddocname=bok1_042416 16 Get It Right the First Time Physician education is critical: Not clearly defining the learning objectives upfront Lack of evaluating and understanding the workflows Providing the training to far in advance of the go-live Not allowing adequate time to provide training Providing insufficient training materials or job aides Using the wrong type of instructional trainer Not providing an opportunity for practice and feedback Lack of sponsorship and commitment at all levels 17 9

Take-Away Pearls Get involved early and often Identify who is responsible for maintaining and updating clinical content (e.g., masterfiles, clinical content, etc.) Attend EMR Physician Training sessions Partner with Clinical Infomatics Perform audits prior to implementation and soon after install to identify risks 18 Questions/Answers Georgette Gustin, CPC, CCS-P, CHC (317) 432-9788 or ggbelieves@gmail.com Faith Marie Hope, CPC, CCS-P, CHC Nemours Children Health System (302) 651-4141 or fhope@nemours.org 19 10