Accurate clinical documentation is the bedrock of the legal medical record, billing, and coding. It is also the most complex and vulnerable part of revenue cycle because independent providers must document according to intricate and sometimes vague rules.
Medicare recently published revisions to its appeals process, focusing on the Administrative Law Judge (ALJ) level of appeal. These revisions were published in the Federal Register in the form of final regulations on January 17, 2017, and became effective March 20.
The 2017 calendar year marks the beginning of a new approach to physician payment through the Quality Payment Program (QPP), an initiative created by the Medicare Access and CHIP Reauthorization Act to revise the physician payment system previously updated through the Sustainable Growth Rate.
Accurate clinical documentation is the bedrock of the legal medical record, billing, and coding. It is also the most complex and vulnerable part of revenue cycle because independent providers must document according to intricate and sometimes vague rules.
As OPPS packaging has increased, providers may be less likely to appeal claims for certain denied charges based on medically unlikely edits, since it would not increase payments. However, providers should consider appeals when services are medically necessary and appropriate, as CMS bases future payment rates on accepted claims.
The intersection of CMS’ packaged payment policy and the increasing volume of Medically Unlikely Edits (MUE) can be likened to a car crash waiting to happen. Hospitals are having valid, medically necessary claim lines denied – including charges and units below MUE limits. Providers can help stop the crash by ensuring their claims, CPT coding, medical necessity, and the units are all correct.
With a new year underway, providers likely need to get a handle on some key new modifiers, as well as important changes to an existing modifier and the deletion of a modifier that previously raised a lot of questions and operational concerns.
With a new year underway, providers likely need to get a handle on some key new modifiers, as well as important changes to an existing modifier and the deletion of a modifier that previously raised a lot of questions and operational concerns.
The focus for clinical documentation improvement (CDI) specialists has historically been on the inpatient hospital stay. Review of the chart for conditions that are not fully documented and/or evidence of conditions not documented at all has been standard practice.
Lori-Lynne A. Webb, CPC, CCS-P, CCP, CHDA, COBGC, CDIP, writes about the challenges faced in OB hospitalist practices and which procedures and services to focus on for coding, billing, and documentation.
Coding managers cannot always monitor every guideline update or coding-related issue targeted by the Office of Inspector General. Rose T. Dunn, MBA, RHIA, CPA, FACHE, FHFMA, CHPS, reviews what a coding manager can do during a coding audit and how to implement a plan.
Managers should not assume that they can review every guideline, every item in Coding Clinic , or every coding-related issue targeted by the Office of Inspector General (OIG) or Recovery Audit Contractor (RAC).
Chronic care management codes were adopted by CMS in 2015, but relatively few providers use them. Lori-Lynne A. Webb, CPC, CCS-P, CCP, CHDA, COBGC, CDIP, writes about the criteria needed to code and bill these services, as well as how coders can work with providers to ensure documentation supports the codes.
The 2017 OPPS final rule brings the end of modifier –L1 for separately reportable laboratory tests, along with changes to CMS’ packaging logic. Jugna Shah, MPH, and Valerie A. Rinkle, MPA, review how these changes will impact providers.
Each year, CMS reviews procedures on the inpatient-only list, which consists of services typically provided on inpatients and not payable under the OPPS, to consider whether they are being performed safely and consistently in outpatient departments.
As it does each year, CMS reviewed its packaging policies and proposed numerous modifications for 2017, finalizing a move to conditionally package at the claim level and deleting the controversial modifier used to identify separately reportable laboratory tests.
CMS made certain concessions from its proposed site-neutral payment policies required by Section 603 of the Bipartisan Budget Act, but it is still moving forward with implementation January 1, 2017, according to the 2017 OPPS final rule.
Rose T. Dunn, MBA, RHIA, CPA, FACHE, FHFMA, CHPS, writes about methods coders can use to improve the quality and detail of physician documentation to ensure important information is captured.
Providers need to make sure that electronic order templates include all the necessary information to bill correctly and avoid issues during audits. Valerie A. Rinkle, MPA, writes about what must be contained in the order and ICD-10-specific updates providers should consider.
Orders for services are a vital component of ensuring Medicare coverage. With the advent of computerized provider order entry (CPOE), it is important to review order templates in the electronic medical record (EMR) and the resulting order produced or printed in the formal legal medical record to ensure the templates meet requirements.
With only 60 days between the OPPS final rule's release and the January 1 implementation date, providers will be ahead of the curve by spending time now and thinking about the processes they may need to review, change, or implement based on what CMS finalizes and the sort of financial impact the final rule is likely to have.
Facilities may not yet be using clinical documentation improvement staff to review outpatient records, but the increasing number of value-based payment models and Medicare Advantage patients could make the practice worthwhile, according to Angela Carmichael, MBA, RHIA, CDIP, CCS, CCS-P, CRC, and Lena Lizberg, BSN.
The 2017 OPPS final rule is scheduled to be released in just a few weeks. Jugna Shah, MPH, writes about what facilities should be preparing for in case some of CMS’ proposals related to off-campus, provider-based departments, packaging, and device-intensive procedures are finalized.
The Medicare Reporting and Returning of Self-Identified Overpayments final rule (81 Fed. Reg. 7654‑7684), which became effective March 14, is designed to implement Section 1128J(d) of the Social Security Act, which was established under Section 6402(a) of the Affordable Care Act, effective March 23, 2010.
Billing correctly for observation hours is a challenge for many organizations. Getting it right requires knowing how to calculate observation hours for each patient, which is far from straightforward. Janet L. Blondo, LCSW-C, MSW, CMAC, ACM, CCM, C-ASWCM, ACSW, writes about how to properly calculate hours and report observation services properly.
Coders may not be aware of the impact place of service codes can have on coding and billing. Lori-Lynne A. Webb, CPC, CCS-P, CCP, CHDA, COBGC, CDIP, writes about how the codes are used and what coders should know about their application.
CMS proposes aligning its conditional packaging logic with how it applies packaging to labs, while also proposing to delete the much-maligned modifier -L1 for separately payable laboratory tests in 2017.
CMS released the 2017 OPPS proposed rule on July 5 without much fanfare. On July 14, the Federal Register version was posted, and upon initial review, it seems rather short at 186 pages.
CMS’ proposed changes to implement Section 603 of the Bipartisan Budget Act of 2015 would reshape payments for off-campus, provider-based departments (PBD) if finalized and represent the most significant changes in the calendar year (CY) 2017 OPPS proposed rule.
Jugna Shah, MPH, and Valerie Rinkle, MPA, recap CMS’ proposed changes to packaging logic in the 2017 OPPS proposed rule, as well as plans for new and deleted modifiers.
Debbie Mackaman, RHIA, CPCO, CCDS, reviews how CMS determines inpatient-only procedures and what changes the agency is considering in the 2017 OPPS proposed rule.
Deciphering documentation is frequently the most difficult aspect of coding. Lori-Lynne A. Webb, CPC, CCS-P, CCP, CHDA, COBGC, CDIP, writes about what documented information coders can use to assign codes—and what to do when that information is lacking.
Jugna Shah, MPH, and Valerie Rinkle, MPA, review changes in the 2017 OPPS proposed rule for providers to comment on, including site-neutral payments and comprehensive APC updates.
CMS' Transmittal 3523, issued May 13, is the quarterly July 1 OPPS update. In this transmittal, CMS briefly mentions billing physical and occupational therapy and speech-language pathology services provided in support of or adjunctive to comprehensive APC (C-APC) services under revenue code 0940 (general therapeutic services) rather than the National Uniform Billing Committee--defined revenue codes for these services (i.e., 042x, 043x, and 044x, respectively).
Healthcare organizations have become mass gatherers of data. But without sophisticated analytics, integrated IT tools, and processes to mine that data, they may not be able to take advantage of it.
CMS issued a final rule in June to revamp the way it pays for tests under the Clinical Laboratory Fee Schedule (CLFS), though the agency has pushed the start date back a year and worked to ease administrative burden based on public comments.
Comprehensive APCs (C-APC) have added another complication to coding and billing for outpatient services. Valerie A. Rinkle, MPA, writes about recent changes that could impact the reporting of physical and occupational therapy and speech-language pathology services provided in support of or adjunctive to a C-APC.
Congressional legislation is often written in a way that obfuscates or, at the very least, makes it difficult to discern the impact or intent of a bill.
When compared to data from past surveys, HCPro's 2016 HIM director and manager salary survey revealed a harsh truth that many HIM professionals already know: There has been little movement in HIM manager and director salaries over the years.
The value modifier is having an increasing effect on physician payments and coding each patient’s severity is key to accuracy. Richard D. Pinson, MD, FACP, CCS, writes about how the value modifier impacts payment and conditions coders should be aware of that quality scores.
CMS recently announced changes to require providers to report modifier -JW (drug amount discarded/not administered to any patient) when appropriate. Jugna Shah, MPH, looks at when providers will need to use the modifier and how to remain compliant.
As healthcare providers increasingly accept financial risk associated with patient management due to the transition from fee-for-service to risk-/value-based reimbursement, the traditional model of healthcare reimbursement has been flipped upside down.
The April 2016 I/OCE update brought a host of code and status indicator changes, as well as corrections to CMS' large January update that instituted policies and codes from the 2016 OPPS final rule.
On April 18, CMS issued its anticipated IPPS proposed rule for FY 2017. This year's proposed rule is very dense, including multiple coding fixes and updates, changes to payment provisions, quality updates, and even something for utilization review.
CMS’ April I/OCE update includes numerous code and status indicator changes, as well as corrections to its January release. Kimberly Anderwood Hoy Baker, JD, CPC, looks at the changes providers should review to ensure claims including these codes are processed correctly.
Which services should clinical documentation improvement (CDI) specialists target in outpatient facilities? Anny Pang Yuen, RHIA, CCS, CCDS, CDIP , writes about how outpatient CDI differs from inpatient CDI and how it can be applied in hospitals or physician practices.
