TrailBlazer Medical Review Activities
Transcription
TrailBlazer Medical Review Activities
A CMS Contracted Intermediary and Carrier Education Makes the Difference Education Makes the Difference Education Makes the Difference Medicare Update 2010 Texas Tech University School of Medicine May, 2010 Debra L. Patterson, M.D. J4 Medicare Medical Director Published Month Year Medicare Update 2010 Education Makes the Difference Education Makes the Difference Education Makes the Difference Discussion Topics • Identifying Aberrant Billing Patterns • Documentation Risks Basics Teaching Physicians EMR Recent TrailBlazer Medical Review Audit Examples • TrailBlazer Concerns • Questions Education Makes the Difference Education Makes the Difference Education Makes the Difference Medicare Administrative Contractors Education Makes the Difference Education Makes the Difference Education Makes the Difference Correct payment? Honest payment error? Fraud? Abuse? Fraud and Abuse Definitions Education Makes the Difference Education Makes the Difference Education Makes the Difference Fraud – An intentional deception or misrepresentation made by an individual knowing it to be false, resulting in unauthorized benefit(s) for himself or another person. Abuse – Practice that is inconsistent with accepted, sound medical or fiscal standards. The practice may directly or indirectly result in unnecessary costs to the Medicare program, improper payments for services that fail to meet professionally recognized standards of care, or services that are medically unnecessary. Fraud and Abuse Definitions Education Makes the Difference Education Makes the Difference Education Makes the Difference There is no absolute data or medical review finding to clearly differentiate honest billing errors and/or poor documentation practices from fraud and/or abuse. Progressive Corrective Action Education Makes the Difference Education Makes the Difference • Problem Identification • Problem Validation • Intervention • Monitoring • Problem Closure Education Makes the Difference Problem Identification Education Makes the Difference Education Makes the Difference Wound Care – • OIG-HHS/DOJ • CERT • Part A and B Contractors • PSCs • RACs Education Makes the Difference Problem Identification Education Makes the Difference Education Makes the Difference Education Makes the Difference OIG Report May 2007 • Medicare spent $188 million in 2004 for surgical debridement services • $64 million in improper payments • 64% of services did not meet one or more Medicare program requirements –Incorrectly coded = 39% –No documentation or insufficient documentation = 29% –Not medically necessary = 1% Problem Identification Education Makes the Difference Education Makes the Difference Education Makes the Difference POINT #1 Numerous suspicious observations DC 24-Month Trend by Allowed Amount Procedure Codes 11040-11044 Education Makes the Difference 11040 11041 Education Makes the Difference 11042 11043 11040 11044 Allowed Services Per Patient Allowed Amount $250,000 $200,000 $150,000 $100,000 $50,000 $0 OctDec 2003 JanMar 2004 AprJun 2004 Jul- OctSep Dec 2004 2004 JanMar 2005 AprJun 2005 Education Makes the Difference 11041 11042 11043 11044 3.50 3.00 2.50 2.00 1.50 1.00 0.50 0.00 OctDec 2003 JulSep 2005 JanMar 2004 AprJun 2004 JulSep 2004 Paid Quarters Oct 2003 thru Sept 2004 compared to Oct 2004 thru Sept 2005 Procedure Codes 11040 11041 11042 11043 11044 Percent change of allowed amount -0.12% 4.76% 17.58% -3.01% -3.35% Percent change of allowed services -2.50% -0.23% 13.90% -6.21% -4.73% OctDec 2004 JanMar 2005 AprJun 2005 JulSep 2005 DE 24-Month Trend by Allowed Amount Procedure Codes 11040-11044 11040 11041 11042 Education Makes the Difference 11043 11044 Allowed Amount $60,000 $50,000 $40,000 $30,000 $20,000 $10,000 $0 Oct- Jan- Apr- Jul- Oct- Jan- Apr- JulDec Mar Jun Sep Dec Mar Jun Sep 2003 2004 2004 2004 2004 2005 2005 2005 Education Makes the Difference 11040 Allowed Services Per Patient Education Makes the Difference 11041 11042 11043 11044 3.00 2.50 2.00 1.50 1.00 0.50 0.00 OctDec 2003 JanMar 2004 AprJun 2004 JulSep 2004 OctDec 2004 Paid Quarters Oct 2003 thru Sept 2004 compared to Oct 2004 thru Sept 2005 Procedure Codes 11040 11041 11042 11043 11044 Percent change of allowed amount 32.93% 23.69% 23.79% -23.89% -27.13% Percent change of allowed services 31.78% 19.45% 22.11% -28.30% -31.06% JanMar 2005 AprJun 2005 JulSep 2005 MD 24-Month Trend by Allowed Amount Procedure Codes 11040-11044 Education Makes the Difference Education Makes the Difference Education Makes the Difference 11041 11042 11043 $400,000 Allowed Amount 11040 11044 $350,000 $300,000 $250,000 $200,000 $150,000 $100,000 $50,000 $0 Oct- Jan- Apr- Jul- Oct- Jan- Apr- JulDec Mar Jun Sep Dec Mar Jun Sep 2003 2004 2004 2004 2004 2005 2005 2005 Allowed Services Per Patient 11040 11041 11042 11043 11044 3.50 3.00 2.50 2.00 1.50 1.00 0.50 0.00 JulOct- Jan- AprJul- Oct- Jan- AprSep Dec Mar Jun Sep Dec Mar Jun 2003 2003 2004 2004 2004 2004 2005 2005 Paid Quarters Oct 2003 thru Sept 2004 compared to Oct 2004 thru Sept 2005 Procedure Codes 11040 11041 11042 11043 11044 Percent change of allowed amount -10.59% 2.97% 30.12% 12.16% -5.20% Percent change of allowed services -11.75% -0.30% 23.41% 8.61% -5.76% TX 24-Month Trend by Allowed Amount Procedure Codes 11040-11044 11040 11041 Education Makes the Difference 11042 11043 11040 11044 Allowed Amount $1,600,000 $1,400,000 $1,200,000 $1,000,000 $800,000 $600,000 $400,000 $200,000 $0 OctDec 2003 JanMar 2004 AprJun 2004 JulSep 2004 OctDec 2004 JanMar 2005 AprJun 2005 JulSep 2005 Allowed Services Per Patient Education Makes the Difference Education Makes the Difference 11041 11042 11043 11044 5.00 4.50 4.00 3.50 3.00 2.50 2.00 1.50 1.00 0.50 0.00 Oct- Jan- Apr- JulOct- Jan- Apr- JulDec Mar Jun Sep Dec Mar Jun Sep 2003 2004 2004 2004 2004 2005 2005 2005 Paid Quarters Oct 2003 thru Sept 2004 compared to Oct 2004 thru Sept 2005 Procedure Codes 11040 11041 11042 11043 11044 Percent change of allowed amount 11.95% 11.36% 14.04% 46.69% 21.39% Percent change of allowed services 9.86% 6.78% 11.23% 45.29% 19.61% VA 24-Month Trend by Allowed Amount Procedure Codes 11040-11044 Education Makes the Difference 11040 11041 Education Makes the Difference 11042 11043 11040 11044 $200,000 11041 11042 11043 11044 3.00 $180,000 Allowed Services Per Patient Allowed Amount Education Makes the Difference $160,000 $140,000 $120,000 $100,000 $80,000 $60,000 $40,000 $20,000 2.50 2.00 1.50 1.00 0.50 0.00 $0 OctDec 2003 JanMar 2004 AprJun 2004 JulSep 2004 OctDec 2004 JanMar 2005 AprJun 2005 Oc t- Jan- AprJul- Oc t- Jan- Apr- JulDec Mar Jun Sep Dec Mar Jun Sep 2003 2004 2004 2004 2004 2005 2005 2005 JulSep 2005 Paid Quarters Oct 2003 thru Sept 2004 compared to Oct 2004 thru Sept 2005 Procedure Codes 11040 11041 11042 11043 11044 Percent change of allowed amount 0.56% 4.14% 17.82% -3.56% 31.66% Percent change of allowed services -2.20% 1.55% 17.08% -3.11% 23.42% Problem Identification Education Makes the Difference Education Makes the Difference Education Makes the Difference POINT #2 Trends and Patterns TX Scattergraph Procedure Code 11042 Education Makes the Difference Education Makes the Difference Education Makes the Difference TX Scattergraph of Allowed Dollars versus Frequency of Therapy Dates of Service: January-December 2007 Paid Dates: January-December 2007 Modifiers: KX + GN, GO, GP 500 Education Makes the Difference Education Makes the Difference Education Makes the Difference 450 400 350 300 250 200 150 100 Peer Average = 34.23 50 0 $0 $500,000 $1,000,000 $1,500,000 $2,000,000 $2,500,000 $3,000,000 Modifier KX Allowed Dollars * Therapy is based on modifiers GO, GN, and GP. $3,500,000 $4,000,000 $4,500,000 $5,000,000 Problem Identification Education Makes the Difference Education Makes the Difference Education Makes the Difference POINT #3 Absolute utilization difference TX Scattergraph Procedure Code 11042 Education Makes the Difference Education Makes the Difference Education Makes the Difference TX Scattergraph Procedure Code 11043 Education Makes the Difference Education Makes the Difference Education Makes the Difference Extreme outlier removed from graph. Total allowed dollars $1,408,820.29 and allowed services per patient 12.15. TX Scattergraph Procedure Code 11044 Education Makes the Difference Education Makes the Difference Education Makes the Difference Problem Identification Education Makes the Difference Education Makes the Difference Education Makes the Difference POINT #4 Multiple code utilization variation TX Procedure Code 11043 by Allowed Dollars Education Makes the Difference the Difference Education Makes the Difference Paid Dates:Education AprilMakes – September 2005 Top Specialties TOP DIAGNOSES 10% 5% 6% 2,615 2,615 $420,410.63 $397,490.66 16.93% 190 1,397 1,397 $243,076.22 $203,959.06 8.69% 25081 - DIABETES WITH OTHER SPECIFIED MANIF 103 1,004 1,004 $171,662.15 $169,042.34 7.20% 8911 - OPEN WND KNEE/LEG-COMPL 202 993 993 $234,309.85 $164,841.80 7.02% NBR PATS BILLED ALLWD BILLED AMT SRVCS SRVCS 97 - Physician Assistant All Others % OF TOTAL ALLOWED AMT 9,639 9,639 $1,737,589.68 $1,567,374.19 66.74% 920 2,936 2,936 $1,081,882.46 19.81% TOP MODIFIERs 1 $465,232.02 % OF TOTAL ALLOWED AMT $1,830,754.70 $1,417,990.25 60.38% $678,013.89 $431,102.03 18.36% $361,233.91 $193,869.33 8.26% $126,778.82 $62,492.78 2.66% BILLED ALLWD NBR PATS BILLED AMT SRVCS SRVCS 58 - STAGED OR RELATED PROCEDURE BY SAME No Modifier Used 59 - DISTINCT PROCEDURAL SERVICES RT - PROCS PERFORMED ON RIGHT SIDE 1,149 1,322 629 206 TOP MODIFIERs 2 NBR PATS No Modifier Used 59 - DISTINCT PROCEDURAL SERVICES 51 - MULTIPLE SURGERY 58 - STAGED OR RELATED PROCEDURE BY SAME 2,434 596 564 77 9,022 2,146 1,695 339 9,022 2,146 1,695 339 11 - Internal Medicine 48 - Podiatry ALLOWED AMT 1,118 9% 02 - General Surgery % OF TOTAL ALLOWED AMT 188 22 - OUTPATIENT HOSPITAL 25 - Physical Medicine & Rehabilitation ALLOWED AMT 70709 - DECUBITUS ULCER, OTHER SITE 11 - OFFICE 61% BILLED ALLWD BILLED AMT SRVCS SRVCS 4542 - VARICOSE VEINS OF LOWER EXTREMITIES TOP PLACE OF SERVICE 9% NBR PATS % OF TOTAL ALLOWED AMT $2,262,529.21 $1,513,219.91 64.44% $724,018.13 $535,778.12 22.81% $336,653.28 $162,385.14 6.91% $80,387.87 $48,357.79 2.06% BILLED ALLWD BILLED AMT SRVCS SRVCS 7,549 4,714 1,583 277 7,549 4,714 1,583 277 ALLOWED AMT ALLOWED AMT TX Procedure Code 11044 by Allowed Dollars Paid Dates: April 2005 Makes the Difference Education Makes the Difference Education Makes– theSeptember Difference Education TOP DIAGNOSES Top Specialties 22% 42% 70715 - ULCER OF OTHER PART OF FOOT 25081 - DIABETES WITH OTHER SPECIFIED MANIF 25080 - DIABETES WITH OTHER SPECIFIED MANIF 70714 - ULCER OF HEEL AND MIDFOOT 99883 - NON-HEALING SURGICAL WOUND TOP PLACE OF SERVICE 11 - OFFICE 22 - OUTPATIENT HOSPITAL 10% BILLED ALLWD NBR PATS BILLED AMT SRVCS SRVCS 287 56 50 150 67 14% 25 - Physical Medicine & Rehabilitation 02 - General Surgery 399 512 48 - Podiatry 11 - Internal Medicine All Others 58 - STAGED OR RELATED PROCEDURE BY SAME No Modifier Used 79 - UNRELATED PROCEDURE OR SERVICE BY T 59 - DISTINCT PROCEDURAL SERVICES TOP MODIFIERs 2 No Modifier Used 59 - DISTINCT PROCEDURAL SERVICES 51 - MULTIPLE SURGERY RT - PROCS PERFORMED ON RIGHT SIDE 562 554 284 256 239 BILLED ALLWD NBR PATS SRVCS SRVCS TOP MODIFIERs 1 12% 562 554 284 256 239 1,968 1,225 1,968 1,225 $ 286,973.90 $ 121,887.03 $ 71,242.98 $ 131,413.99 $ 88,028.96 NBR PATS 1,149 202 155 71 2,030 664 224 270 $ 136,462.10 $ 120,816.31 $ 63,590.69 $ 61,171.09 $ 60,616.68 2,030 664 224 270 ALLOWED AMT % OF TOTAL ALLOWED AMT $644,871.95 $458,385.29 50.41% $343,145.68 $175,115.81 19.26% $115,188.85 $51,519.47 5.67% $123,033.31 $44,195.47 4.86% BILLED AMT 2,544 812 233 90 ALLOWED AMT % OF TOTAL ALLOWED AMT $1,214,302.66 $663,335.54 72.95% $184,722.03 $124,926.37 13.74% $105,870.94 $31,718.58 3.49% $65,913.17 $20,191.00 2.22% BILLED ALLWD BILLED AMT SRVCS SRVCS 2,544 812 233 90 % OF TOTAL ALLOWED AMT 15.01% 13.29% 6.99% 6.73% 6.67% % OF TOTAL ALLOWED AMT $521,769.38 $450,521.46 49.55% $667,774.05 $284,645.02 31.30% BILLED AMT BILLED ALLWD NBR PATS SRVCS SRVCS 467 505 87 185 ALLOWED AMT ALLOWED AMT Problem Identification Education Makes the Difference Education Makes the Difference Education Makes the Difference POINT #5 Unexpected provider specialty or types Unexpected place(s) of service Texas Ambulance (Specialty 59) BLS Non-Emergency Transport (Procedure Code A0428) Trend of Maximum Potential Savings and Carrier-to-Nation Ratio $40,000,000 Education Makes the Difference 2.50 Education Makes the Difference Education Makes the Difference $35,000,000 $30,000,000 $25,000,000 1.50 $20,000,000 1.00 $15,000,000 $10,000,000 0.50 $5,000,000 $0 0.00 Jan-Jun 2004 Jul-Dec 2004 Jan-Jun 2005 Jul-Dec 2005 Time Period Maximum Potential Savings Source: National BESS Data Carrier-to-Nation Ratio Jan-Jun 2006 Carrier to Nation Ratio Maximum Potential Savings 2.00 Problem Identification Education Makes the Difference Education Makes the Difference Education Makes the Difference POINT #6 Dramatic utilization upturns January – June 2006 BESS Data Procedure Code A0428 – BLS Non-emergency Ambulance service, basic life support, non - emergency transport Education Makes the Difference Education Makes the Difference Education Makes the Difference $40,000,000 2.5 $30,000,000 2 $25,000,000 $20,000,000 1.5 $15,000,000 $10,000,000 1 $5,000,000 $0 ($5,000,000) 0.5 DC DE MD TX VA ($10,000,000) 0 Maximum Potential Savings Carrier to Nation Ratio Carrier to Nation Ratio Maximum Potential Savings $35,000,000 TX Scattergraph by UPIN Procedure Code A0428 - BLS Paid Dates: June – November 2006 A l l o w e d S e r v i c e s Education Makes the Difference 3SD 2SD Mean 160 Education Makes the Difference Education Makes the Difference 140 120 P a t i e n t 100 3SD 80 2SD 60 40 P e r Mean 20 0 $0 $500,000 $1,000,000 $1,500,000 $2,000,000 $2,500,000 Total Allowed Amount There are 474 UPINs Mean = $175,510.01 allowed amount and 16.64 allowed services per patient 2nd standard deviation = $670,743.14 allowed amount and 67.63 allowed services per patient (19 UPINs over 2nd standard deviation for allowed amount) 3rd standard deviation = $918,359.70 allowed amount and 93.13 allowed services per patient (6 UPINs over 3rd standard deviation for allowed amount) Texas Ambulance (Specialty 59) BLS Non-Emergency Transport (Procedure Code A0428) Trend of Carrier-to-Nation Ratio 2.5 Education Makes the Difference Education Makes the Difference Education Makes the Difference Carrier-to-Nation Ratio 2.0 1.5 1.0 0.5 0.0 Jan-Jun 2004 Jul-Dec 2004 Jan-Jun 2005 Time Period Source: National BESS Data Jul-Dec 2005 Jan-Jun 2006 Problem Identification Education Makes the Difference Education Makes the Difference Education Makes the Difference POINT #7 Aberrancies in multiple data sources Problem Identification Education Makes the Difference Education Makes the Difference Education Makes the Difference •48% (26 of 54) of the providers are located in the Houston area. •11% (6 of 54) have fewer than 10 patients •42% (23 of 54) have more than 7,000 services/100 patients. Problem Identification Education Makes the Difference Education Makes the Difference Education Makes the Difference POINT #8 Unusual business plans Texas A0428 Modifiers RJ, JR Dates of Service July – December 2007 Paid Dates July 2007 – January 2008 Education Makes the Difference Education Makes the Difference Education Makes the Difference 180 160 3 SD 140 Allowed Services Per Patient 2 SD 120 100 80 Mean 60 40 20 0 $0 $200,000 $400,000 $600,000 $800,000 Allowed Dollars $1,000,000 $1,200,000 $1,400,000 $1,600,000 Problem Identification Education Makes the Difference Education Makes the Difference Education Makes the Difference POINT #9 Birds of a feather flock together Education Makes the Difference Education Makes the Difference Education Makes the Difference Problem Identification Education Makes the Difference Education Makes the Difference Education Makes the Difference POINT #10 There is no single data aberrancy to indicate billing errors, fraud, or abuse with 100% specificity or 100% sensitivity Claim Review Education Makes the Difference Education Makes the Difference Education Makes the Difference What’s Medicare Looking For? • Validate the information on the face of the claim • Verify that all Medicare benefit and medical necessity requirements were met TrailBlazer Medical Review Activities Education Makes the Difference Education Makes the Difference Education Makes the Difference • Numerous medical review “probe audits” and pre-payment audits last year. • Audits included numerous drugs and pharmacologic administration services. • Significant error rates • Multiplex nature of errors o Medical necessity o “Incident to” violations o Failure to document the services to have been performed. o Provider identity/signature TrailBlazer Medical Review Activities Education Makes the Difference Education Makes the Difference Education Makes the Difference Representative Errors From IVIG Audit • Failure to meet one or more LCD requirement. • Failure to demonstrate appropriate “Incident To” reporting (i.e. absence of documentation indicating the presence of the supervising physician on site during the IVIG infusion). • Documentation entries lacked legible signatures identifying the performing/supervising persons. TrailBlazer Medical Review Activities Education Makes the Difference Education Makes the Difference Education Makes the Difference Representative Errors From IVIG Audit • Errors associated with related infusion services Services inherent to the cost of the infusion reported separately. Normal saline (HCPCS codes J7040 and J7050) and used to administer the drug. Heparin flush (HCPCS codes J1642 and J1644) Introduction of needle or intracatheter into a vein (CPT code 36000) Failure to document infusions and/or push (CPT codes 96366, 96367 96368, 96373 and 96374) at the quantity reported. TrailBlazer Medical Review Activities Education Makes the Difference Education Makes the Difference Education Makes the Difference Representative Errors From IVIG Audit • Errors associated with related infusion services Failure to document administration of other pharmacologic agents reported for payment: Metaclopramide (HCPCS code J2765), Dexamethasone (HCPCS code J1110) Diphenhydramine (HCPCS code J1200) Methylprednisolone (HCPCS code J2930). Failure to document Evaluation and Management (E/M) Services (CPT codes 99213 and 99214) Failure to document a significant, separately identifiable E/M service. Failure to document the level of E/M code level reported. TrailBlazer Medical Review Activities Education Makes the Difference Education Makes the Difference Education Makes the Difference Representative Errors From IVIG Audit • Errors associated with related infusion services Failure to document miscellaneous reported services Portable pump maintenance (CPT 96521) Spirometry (CPT code 94010) Professional services for allergen immunotherapy (CPT code 95115). Recent Local Policy Activities Education Makes the Difference Education Makes the Difference Education Makes the Difference Drafts To Be Presented To June 2010 CACs • Computed Tomographic Coronary Arteriography • Audiologic and Vestibular Function • Cardiac Rehabilitation • Pulmonary Rehabilitation TrailBlazer Medical Review Activities Education Makes the Difference WHO WHAT Education Makes the Difference Performing, supervising, and referring practitioners Services and quantities of services performed WHERE Place of service WHEN Date of service WHY Education Makes the Difference Medical necessity and diagnosis TrailBlazer Medical Review Activities Education Makes the Difference Education Makes the Difference Education Makes the Difference Performing, Supervising, and Referring Practitioners • Legible identity and signature* • Appropriate professional • Incident to • (erstwhile) Consultations Medicare Payment Requirements Education Makes the Difference Education Makes the Difference Education Makes the Difference Medicare assumes the following: • Physicians and other providers of healthcare services who report services for payment by Medicare know and have followed the rules (“could have known, should have known”) • Every item of information reported on every claim is true and accurate and is supported by appropriate medical record documentation – That physicians and other providers of healthcare services understand and correctly report CPT, HCPCS, and ICD-9 codes – That the medical record demonstrates that the work of the CPT code reported was performed by the reporting practitioner Medicare Payment Requirements Education Makes the Difference Education Makes the Difference Education Makes the Difference Reported services must be: • Performed in accordance with federal laws, regulations, and Medicare national payment rules • Performed by a qualified practitioner • Performed for a qualified beneficiary • Medically reasonable and necessary • Coded correctly Medical Necessity In The Law Education Makes the Difference Education Makes the Difference Education Makes the Difference Social Security Act, Title XVIII Section 1862 (a) (1) (A) "Notwithstanding any other provision of this title, no payment can be made under Part A or Part B for any expenses incurred for items or services which are not reasonable and necessary for the diagnosis or treatment of illness or injury or to improve the functioning of a malformed body member.” Medical Necessity Defined Education Makes the Difference Education Makes the Difference Education Makes the Difference Medical Necessity Education Makes the Difference Education Makes the Difference Education Makes the Difference • Statute • National Coverage Decisions • Local Coverage Determinations Medical Necessity Education Makes the Difference • • • • Education Makes the Difference Education Makes the Difference Statute National Coverage Decisions Local Coverage Determinations Clinician judgment considering the “rules” – Safe and effective – Not investigational – Meet but not exceed patient’s medical need – Accepted standard of medical practice • Peer reviewed Medical literature • Practice guidelines • Respected textbooks • Authoritative opinion Medical Necessity Education Makes the Difference • • • • Education Makes the Difference Education Makes the Difference Statute National Coverage Decisions Local Coverage Determinations Clinician judgment considering the “rules” – Safe and effective – Not investigational – Meet but not exceed patient’s medical need – Accepted standard of medical practice • Peer reviewed Medical literature • Practice guidelines • Respected textbooks • Authoritative opinion Medical Necessity Education Makes the Difference • • • • Education Makes the Difference Education Makes the Difference Statute National Coverage Decisions Local Coverage Determinations Clinician judgment considering the “rules” – Safe and effective – Not investigational – Meet but not exceed patient’s medical need – Accepted standard of medical practice • Peer reviewed Medical literature • Practice guidelines • Respected textbooks • Authoritative opinion Medical Necessity Education Makes the Difference • • • • Education Makes the Difference Education Makes the Difference Statute National Coverage Decisions Local Coverage Determinations Clinician judgment considering the “rules” – Safe and effective – Not investigational – Meet but not exceed patient’s medical need – Accepted standard of medical practice • Peer reviewed Medical literature • Practice guidelines • Respected textbooks • Authoritative opinion Medical Necessity Education Makes the Difference • • • • Education Makes the Difference Education Makes the Difference Statute National Coverage Decisions Local Coverage Determinations Clinician judgment considering the “rules” – Safe and effective – Not investigational – Meet but not exceed patient’s medical need – Accepted standard of medical practice • Peer reviewed Medical literature • Practice guidelines • Respected textbooks • Authoritative opinion Miscellaneous Information Education Makes the Difference Education Makes the Difference Education Makes the Difference Miscellaneous Information Education Makes the Difference Education Makes the Difference Education Makes the Difference Medical Necessity – Beyond E/M Education Makes the Difference Education Makes the Difference • Medical literature Education Makes the Difference Medical Necessity – Beyond E/M Education Makes the Difference Education Makes the Difference • Medical literature Education Makes the Difference Medical Necessity – Beyond E/M Education Makes the Difference Education Makes the Difference • Medical literature Education Makes the Difference Medical Necessity – Beyond E/M Education Makes the Difference Education Makes the Difference • Medical literature Education Makes the Difference Medical Necessity – Beyond E/M Education Makes the Difference Education Makes the Difference • Medical literature Education Makes the Difference Education Makes the Difference Education Makes the Difference Education Makes the Difference Education Makes the Difference Education Makes the Difference Education Makes the Difference Medical Necessity Education Makes the Difference Education Makes the Difference Education Makes the Difference • Clinician judgment considering the “rules” – Safe and effective – Not investigational – Meet but not exceed patient’s medical need – Accepted standard of medical practice • Peer reviewed medical literature • Practice guidelines • Respected textbooks • Authoritative opinion Teaching Physician Services Education Makes the Difference Education Makes the Difference Education Makes the Difference When documenting teaching physician services remember Part B does not pay physicians to teach Part B payments for teaching physicians’ supervision of residents reimburses the teaching physician for his personal service to the patient Teaching Physician Services Education Makes the Difference Education Makes the Difference Education Makes the Difference For E/M services performed by a resident and teaching physician • The teaching physician may report to Medicare for payment a service represented by the combined documentation of the resident and the teaching physician • The teaching physician’s personal documentation must demonstrate A face-to-face visit with the patient Physical presence during the visit of the resident (when applicable) Participation in the management of the patient Teaching Physician Services Education Makes the Difference Education Makes the Difference Education Makes the Difference Following are examples of unacceptable documentation (physician attestation): • “Agree with above.” followed by legible countersignature or identity; • “Rounded, Reviewed, Agree.” followed by legible countersignature or identity; • “Discussed with resident. Agree.” followed by legible countersignature or identity; • “Seen and agree.” followed by legible countersignature or identity; Teaching Physician Services Education Makes the Difference Education Makes the Difference Education Makes the Difference •Review the resident’s note in its entirety to assure the resident included required elements necessary to meet CPT defined physician key component work •Beware of notoriously missing History elements ( HPI and ROS) •Beware inaccurate or conflicting HPI and ROS •Beware of legibility issues Documentation Education Makes the Difference Education Makes the Difference Education Makes the Difference Documentation Red Flags • Patient’s medical condition not described or described in very vague terms Ambulance services Physical therapy services • Patient’s condition does not vary over time Documentation Education Makes the Difference Education Makes the Difference Education Makes the Difference Documentation Red Flags • Extensive, repetitious unnecessary documentation Unrelated to the presenting problem “Blown in” records Documentation by “exception” • Records lack individualization “Cloned” notes Templates Documentation Education Makes the Difference Education Makes the Difference Education Makes the Difference Documentation Red Flags • CPT defined “work” not demonstrated Procedures not documented Level of effort not demonstrated E/M Surgical debridement Infusion services Procedures do not meet any CPT code definition and describe non-covered services “Electroceutical” services Nerve conduction studies Documentation Education Makes the Difference Education Makes the Difference Education Makes the Difference Documentation Red Flags •Circumstances described by modifiers not demonstrated Documentation Education Makes the Difference Education Makes the Difference Education Makes the Difference Documentation Red Flags • Drugs/radiopharmaceuticals not documented • Drug wastage not documented Documentation Education Makes the Difference Education Makes the Difference Education Makes the Difference Documentation Red Flags • Performing and/or record author not identified “Incident to” Scribing Teaching physician Documentation Education Makes the Difference Education Makes the Difference Education Makes the Difference Documentation Red Flags • Failure to identify users Electronic signatures Passwords Audit trail • Need for clear EMR policies procedures Documentation Education Makes the Difference Education Makes the Difference Education Makes the Difference Documentation Red Flags • Documentation inconsistencies Within the provider’s own record Compared to records of other providers Documentation Education Makes the Difference Education Makes the Difference Education Makes the Difference Documentation Red Flags • Conclusions, impressions, and plans of care not supported by the facts • Subjective statements not supported by objective information Medicare Update 2010 Education Makes the Difference Education Makes the Difference “Trying is the first step towards failure.” ~Homer Simpson~ Education Makes the Difference A CMS Contracted Intermediary and Carrier Education Makes the Difference Education Makes the Difference Education Makes the Difference Medicare Update 2010