AES 2010 Practice Management Course Practice Management Course - - PowerPoint PPT Presentation
AES 2010 Practice Management Course Practice Management Course - - PowerPoint PPT Presentation
AES 2010 Practice Management Course Practice Management Course December 7, 2010 Gregory L. Barkley, M.D. Comprehensive Epilepsy Program Comprehensive Epilepsy Program Henry Ford Hospital Detroit MI Detroit, MI Associate Professor of
Outline Outline
C lt ti C d
Consultation Codes 2011 Medicare Conversion Factor and SGR October 2010 ICD-9 coding changes of interest
2011 CPT C d
2011 CPT Codes PQRI update
p
Gearing up for ICD-10 on October 1, 2013
Mi ll Miscellaneous: Please note, I have removed the cell slice images
from this set to keep the file size smaller. Images are at:
http://www nytimes com/slideshow/2010/11/29/science/20101130 brain 1 html http://www.nytimes.com/slideshow/2010/11/29/science/20101130-brain-1.html
Deadline extended until Dec 10. We specifically need members from: Alaska, Arizona, Arkansas Colorado, Connecticut Delaware, Kansas Kentucky, Maine Mississippi Nebraska Mississippi, Nebraska Nevada, North Dakota Rhode Island, South Carolina South Dakota, West Virginia Melissa Larson
Manager, Advocacy Development
AAN Professional Association AAN Professional Association Ph: 651.695.2748 FAX: 651.361.4848 mlarson@aan.com www.aan.com\advocacy
Consultation Codes Are Gone Forever Consultation Codes Are Gone Forever
CMS t d i f lt ti 9924 d 9925
- CMS stopped paying for consultations, 9924x and 9925x
– In 2007, > 28 million claims – Money from Consultation codes redistributed to other physician codes to maintain budget neutrality
- Other payers stopped paying for consults during 2010
- Other payers stopped paying for consults during 2010
- An attempt this year by AAN and other societies to get
reconsideration of consult codes was rejected reconsideration of consult codes was rejected
- CMS commented: "in most cases there is no substantial
difference in physician work between E/M visits and services that would otherwise be reported with CPT consultation codes."
Coding an outpatient New Patient visit (3/3 H PE d MDM) (3/3 or Hx, PE, and MDM)
History Exam Decision Time Code
elements
making
(minutes) HPI 1 3 f t 1 5 St i ht 10 99201 HPI 1-3 facts 1-5 Straight- forward 10 99201 HPI 1-3 facts ROS 1 fact 6 Straight- forward 20 99202 HPI 4 facts ROS 2, PSFH 1 12 low 30 99203
HPI 4 facts, ROS 10, PSFH 3
25 moderate 45 99204
Coding an outpatient Established Coding an outpatient Established Patient visit (2/3 MDM + Hx or PE)
History
Exam elements
Decision making
Time (minutes)
Code making
- Minimal or
none
5
99211 HPI 1-3 facts 1-5 Straight- forward
10
99212 HPI 1-3 facts ROS 1 6 low 15 99213
HPI 4 facts, ROS 2, PSFH 1
12 moderate 25 99214
HPI 4 facts, ROS 10, PSFH 3
25 high 40 99215
9922x Coding an inpatient Initial 9922x Coding an inpatient Initial Care Day (3/3)
History (CC Exam Decision Time Code History (CC always needed) Exam
elements
Decision making Time
(minutes)
Code (wRVU) HPI 4 facts, 1 PFSH, 2-9 ROS 12 Neuro SSE or 5-7 systems Straight-forward or low 30 99221 (1.89) y HPI 4 facts
Full Neuro
Moderate 50 99222 HPI 4 facts, 3 PFSH, 10 ROS
Full Neuro SSE (25) or 8 Systems
Moderate (2 Chronic with 1 exacerbation) 50 99222 (2.57) HPI 4 facts, 3 PFSH
Full Neuro SSE (25) or High Threatening, acute
70 99223 (3 79)
9923x Coding an inpatient Subsequent Day Care (2/3)
History Exam Decision Time Code History Exam
elements
Decision making Time
(minutes)
Code (wRVU) HPI 1-3 facts 1-5 straight-forward or low 15 99231 (0.76) HPI 1-3 facts ROS 1 f t 6 moderate 25 99232 (1 39) ROS 1 fact (1.39) HPI 4 facts ROS 2 facts 12 high 35 99233 (2.00)
Counseling and Coordination of Care Counseling and Coordination of Care
Counseling is a discussion with patient or family about diagnoses Counseling is a discussion with patient or family about diagnoses Counseling is a discussion with patient or family about diagnoses, Counseling is a discussion with patient or family about diagnoses, test results, recommended tests, prognosis, treatment test results, recommended tests, prognosis, treatment alternatives, compliance, risk factor reduction, and patient and alternatives, compliance, risk factor reduction, and patient and f il d ti f il d ti family education. family education. Coordination of care is arranging for care with other health care Coordination of care is arranging for care with other health care Coordination of care is arranging for care with other health care Coordination of care is arranging for care with other health care
- providers. This includes any type of such activity.
- providers. This includes any type of such activity.
Counseling and Coordination of Care Counseling and Coordination of Care
- This can be used
This can be used in place of in place of the above HX the above HX-PE PE-MDM MDM
- This can be used
This can be used in place of in place of the above HX the above HX-PE PE-MDM. MDM.
- It uses
It uses time time to set LOS to set LOS
- The documentation should state:
The documentation should state: Minutes Minutes spent face spent face to to face face – Minutes Minutes spent face spent face-to to-face face – That That more than 50% more than 50% of time was counseling and/or coordinating
- f time was counseling and/or coordinating
care, care, – Give some general idea of Give some general idea of what what counsel/coord. care. counsel/coord. care.
- Time is:
Time is: Face Face to to face with patient (outpatient) face with patient (outpatient) – Face Face-to to-face with patient (outpatient) face with patient (outpatient) – At bedside and on unit/floor (inpatient). At bedside and on unit/floor (inpatient).
- No history or exam elements are needed except of course for real patient
No history or exam elements are needed except of course for real patient
- No history or exam elements are needed except, of course, for real patient
No history or exam elements are needed except, of course, for real patient care purposes! care purposes!
Emergency Room Care Emergency Room Care
- Most ER services provided by neurologists and neurosurgeons are
Most ER services provided by neurologists and neurosurgeons are
- Most ER services provided by neurologists and neurosurgeons are
Most ER services provided by neurologists and neurosurgeons are as “consultants” as “consultants”
- Use Established Patient (99211
Use Established Patient (99211-
- 99215) codes for Medicare
99215) codes for Medicare ti t b i i th t th ti t b i i th t th patients seen by anyone in your group in the past three years patients seen by anyone in your group in the past three years
- Otherwise use Outpatient New Patient (99201
Otherwise use Outpatient New Patient (99201-
- 99205) codes
99205) codes
- If the patient is admitted to the hospital, then use the initial hospital
If the patient is admitted to the hospital, then use the initial hospital p p , p p p , p day codes (99221 day codes (99221-
- 99223)
99223)
- Critical Care services provided in ER, e.g. tPA or status epilepticus
Critical Care services provided in ER, e.g. tPA or status epilepticus management: management: management: management: – Use Critical Care codes 99291 Use Critical Care codes 99291 -
- 99292
99292
Critical Care Critical Care
- 99291
first hour of critical care (31 99291 first hour of critical care (31-74 minutes) 74 minutes) 99291 first hour of critical care (31 99291 first hour of critical care (31 74 minutes) 74 minutes)
- 99292 each additional 30 minutes
99292 each additional 30 minutes
- Coded by time for bedside and unit physician work for an unstable, critically ill
Coded by time for bedside and unit physician work for an unstable, critically ill patient patient p – Not for consultant's time Not for consultant's time – Need not be continuous in any location Need not be continuous in any location
- Generally cannot bill other E/M on same day
Generally cannot bill other E/M on same day
- Generally cannot bill other E/M on same day.
Generally cannot bill other E/M on same day.
- Exceptions are if an E & M is performed at one time, then a crisis occurs and
Exceptions are if an E & M is performed at one time, then a crisis occurs and critical services are performed. critical services are performed.
- Make sure you document times carefully so you do not appear to be combining
Make sure you document times carefully so you do not appear to be combining times of routine care with critical care times or procedure times. times of routine care with critical care times or procedure times.
- Not every day in the ICU is critical care!!!
Not every day in the ICU is critical care!!! Not every day in the ICU is critical care!!! Not every day in the ICU is critical care!!! – Patients awaiting transfer to GPU are not critically ill Patients awaiting transfer to GPU are not critically ill
- Critical care can be provided anywhere including in the clinic
Critical care can be provided anywhere including in the clinic
- You must document time spent and what you did in your note
You must document time spent and what you did in your note
A Very Short Primer on American A Very Short Primer on American Health Care Financing:
$ illi h l h i P i i d $2.5 trillion spent on health care in 2009. Private insurance covered 59% of Americans. Government programs paid for 53% of direct health care costs and 62% if tax exemptions counted. More than 50 illi A i ith t h lth million Americans without health care coverage.
Private insurance policies Private insurance policies Medicare Trust Fund Medicare Trust Fund
- Elderly and those qualifying for
Elderly and those qualifying for di di bili di di bili
- Largely paid for by
Largely paid for by em ployers em ployers
- Usually sm all, but
Usually sm all, but increasing, out increasing, out-
- of
- f-
pocket Medicare disability Medicare disability
- For outpatient care, covers 8 0 % of
For outpatient care, covers 8 0 % of professional fee schedule for visits professional fee schedule for visits and procedures + APC for technical and procedures + APC for technical g, g, p costs borne by individuals costs borne by individuals
- Thousands of com panies
Thousands of com panies
- ffering tens of thousands of
- ffering tens of thousands of
individual policies individual policies charges charges
- In 20 0 6 outpatient m edications
In 20 0 6 outpatient m edications were covered were covered
- For inpatient care, covers 8 0 % of
For inpatient care, covers 8 0 % of individual policies individual policies
- Range m inim al coverage
Range m inim al coverage for catastrophic illness to for catastrophic illness to full coverage full coverage p , p , fee schedule for professional costs + fee schedule for professional costs + DRG for technical costs DRG for technical costs
- Covers 55% of psychiatric care
Covers 55% of psychiatric care charges (Chapter 5 of ICD charges (Chapter 5 of ICD-
- 9)
9) g ( p 5 g ( p 5 9) 9)
In 2007, U.S per capita health care spending was $7 290 2 5 times the OECD average and 16% of $7,290, 2.5 times the OECD average and 16% of GDP
U.S. government alone already pays more than total costs in nearly all
- ther countries
Health Care Spending is 16% of GDP Health Care Spending is 16% of GDP
To Control US Debt To Control US Debt
O l ti t
Only options are to:
Cut Medicare spending
2010 Accountable Care Act reduces Medicare spending by $350 Billion over 10 years
Cut Defense spending
Cut Social Security spending
Raise taxes
Reality is that all of the above are necessary Reality is that all of the above are necessary
Social Security Social Security
- P. Krugman, NYTimes 12/06/2010
2011 Medicare Proposed Conversion p Rate issued 11/02/2010, 2023 pages
In the final rule, the Medicare Conversion Factor will be $25.5217
In the final rule, the Medicare Conversion Factor will be $25.5217 starting 01/01/2011 – 30% drop compared to 2010 to meet SGR law Comment period is open until January 3 2011 – Comment period is open until January 3, 2011
Conversion factor law override from 06/01/2010 until 11/30/2010
was $36.8729 – A 2.2% increase from 2009 and averted a 21.5% cut
Legislation proposals in Congress to override remain contentious at
g p p g this time – On 11/18/2010, Senate passed a one month extension of current pay scale current pay scale – House passed same bill on 11/30/2010 R li f RVU i ht ( 8 2%) d ( 0 5%) b d t t lit
Rescaling of RVU weights (-8.2%) and (+0.5%) budget neutrality
change due to RVU changes mandated by law, so CF likely to be $34.00 if Congress overrides
2011 Medi a e Co e io Rate 2011 Medicare Conversion Rate
12/06/2010, 8:17 PM , To: mem@lyris.aan.com From: mamery@aan.com y@ Re: SGR Agreement Dear MEM Members: The Senate Finance committee just announced a one year delay of the SGR cuts. The deal will be fully paid for. Details to come. Michael J. Amery, Esq. L i l i C l Legislative Counsel American Academy of Neurology 202 506 7468 202-506-7468
SGR A l O id SGR Annual Override..
- Does not fixed flawed formula and increases the
decrease needed the next year, currently $210-279 B
$210-279 B
AMA AMA
2011 ICD-9 Code Changes 2011 ICD-9 Code Changes
On October 1 of each year, the ICD-9 code changes occur
There are new codes as well as new index terms. – Index terms can be used by coders to map to a specific code
New index terms for epilepsy I presented at the ICD Coding and Maintenance Committee Meeting on 9/25/2008, my presentation is at: http://www.cdc.gov/nchs/icd/icd9cm maintenance.htm http://www.cdc.gov/nchs/icd/icd9cm_maintenance.htm
Epilepsy, epileptic (idiopathic) 345.9
Note: use the following fifth-digit subclassifications with categories 345.0, Note: use the following fifth digit subclassifications with categories 345.0, 345.1, 345.4-345.9 without mention of intractable epilepsy 1 with intractable epilepsy pharmacoresistant (pharmacologically resistant) poorly controlled refractory (medically) refractory (medically) treatment resistant
2011 ICD-9 Code Changes 2011 ICD-9 Code Changes
345 Epilepsy and recurrent seizures
Delete Excludes: progressive myoclonic epilepsy (333.2) p g y p p y ( )
780 General symptoms y p
780.3 Convulsions
New code 780.33 Post traumatic seizures
Excludes: post traumatic epilepsy (345.00-345.91)
2011 ICD-9 Code Changes 2011 ICD-9 Code Changes
225 B i l f b i d th t f t
225 Benign neoplasm of brain and other parts of nervous system
Revise Excludes: neurofibromatosis (237.70-237.79)
237 Neoplasm of uncertain behavior of endocrine glands and nervous s stem system
237.7 Neurofibromatosis D l R kli h ' di
Delete von Recklinghausen's disease
New code 237.73 Schwannomatosis N d 237 79 O h fib i
New code 237.79 Other neurofibromatosis
2011 ICD-9 Code Changes g
Codes in Red are in Chapter 5, reimbursed at 55% vs. 80%
278 0 O i ht d b it
278.0 Overweight and obesity
New code 278.03 Obesity hypoventilation syndrome Pi k i ki d
Pickwickian syndrome
307 Special symptoms or syndromes not elsewhere classified
307 Special symptoms or syndromes, not elsewhere classified
Revise 307.0 Stuttering Adult onset fluency disorder
Add Excludes: childhood onset fluency disorder (315 35)
Add Excludes: childhood onset fluency disorder (315.35)
Revise stuttering (fluency disorder) due to late effect of cerebrovascular accident (438.14)
Add fluency disorder in conditions classified elsewhere (784.52)
2011 ICD-9 Code Changes g
Codes in Red are in Chapter 5, reimbursed at 55% vs. 80%
315 Specific delays in development
315.3 Developmental speech or language disorder
New code 315.35 Childhood onset fluency disorder
Cluttering NOS
Stuttering NOS
Excludes: adult onset fluency disorder (307.0) l di d d l b l
fluency disorder due to late effect of cerebrovascular accident (438.14)
fluency disorder in conditions classified elsewhere (784.52) y ( )
315.39 Other
Delete Excludes: stammering and stuttering (307.0) g g ( )
2011 ICD-9 Code Changes 2011 ICD-9 Code Changes
337 Disorders of the autonomic nervous system
337.3 Autonomic dysreflexia y
Revise Use additional code to identify the cause, such as: fecal impaction (560.32)
488 Influenza due to certain identified influenza viruses
488.0 Influenza due to identified avian influenza virus
New code 488.09 Influenza due to identified avian influenza virus with other manifestations Avian influenza with involvement of gastrointestinal tract
Avian influenza with involvement of gastrointestinal tract
Encephalopathy due to identified avian influenza
Excludes: "intestinal flu" [viral gastroenteritis] (008 8)
Excludes: intestinal flu [viral gastroenteritis] (008.8)
2011 ICD-9 Code Changes 2011 ICD-9 Code Changes
488.1 Influenza due to identified novel H1N1 influenza virus
New code 488.19 Influenza due to identified novel H1N1 influenza virus with other manifestations
Novel H1N1 influenza with involvement of gastrointestinal tract
Encephalopathy due to identified novel H1N1 influenza
Excludes: "intestinal flu" [viral gastroenteritis] (008.8)
721 Spondylosis and allied disorders
721.4 Thoracic or lumbar spondylosis with myelopathy
721.42 Lumbar region
Delete Spondylogenic compression of lumbar spinal cord
2011 ICD-9 Code Changes 2011 ICD-9 Code Changes
724 Other and unspecified disorders of back
724.0 Spinal stenosis, other than cervical p ,
Revise 724.02 Lumbar region, without neurogenic claudication
Add Lumbar region NOS g
New code 724.03 Lumbar region, with neurogenic claudication
742 Other congenital anomalies of nervous system
742 8 Other specified anomalies of nervous system
742.8 Other specified anomalies of nervous system
Revise Excludes: neurofibromatosis (237.70-237.79)
2011 ICD-9 Code Changes 2011 ICD-9 Code Changes
781 Symptoms involving nervous and musculoskeletal systems
Revise 781.8 Neurologic neglect syndrome g g y
Add Excludes: visuospatial deficit (799.53)
New code V13.63 Personal history of (corrected) congenital malformations
- f nervous system
V49 Other conditions influencing health status
V49.8 Other specified conditions influencing health status
New code V49.86 Do not resuscitate status
2011 ICD 9 Code Changes 2011 ICD-9 Code Changes
784 S t i l i h d d k
784 Symptoms involving head and neck
784.5 Other speech disturbance R i E l d t i d t tt i (315 35)
Revise Excludes: stammering and stuttering (315.35)
Delete that of nonorganic origin (307.0, 307.9) N d 784 52 Fl di d i di i l ifi d l h
New code 784.52 Fluency disorder in conditions classified elsewhere
Stuttering in conditions classified elsewhere C d fi d l i di di i h
Code first underlying disease or condition, such as:
Parkinson’s disease (332.0) Excludes: adult onset fluency disorder (307 0)
Excludes: adult onset fluency disorder (307.0)
childhood onset fluency disorder (315.35)
fluency disorder due to late effect of cerebrovascular accident
fluency disorder due to late effect of cerebrovascular accident (438.14)
2011 ICD 9 Code Changes 2011 ICD-9 Code Changes
799 Oth ill d fi d d k f bidit d t lit
799 Other ill-defined and unknown causes of morbidity and mortality New Subcategory 799.5 Signs and symptoms involving cognition i ( 80 93)
Excludes: amnesia (780.93)
amnestic syndrome (294.0) tt ti d fi it di d (314 00 314 01)
attention deficit disorder (314.00-314.01)
late effects of cerebrovascular disease (438)
memory loss (780 93)
memory loss (780.93)
mild cognitive impairment, so stated (331.83)
specific problems in developmental delay (315.00-315.9) p p p y ( )
transient global amnesia (437.7)
visuospatial neglect 781.8
2011 ICD 9 Code Changes 2011 ICD-9 Code Changes
799 Oth ill d fi d d k f bidit d t lit
799 Other ill-defined and unknown causes of morbidity and mortality
New code 799.51 Attention or concentration deficit 99 2 C i i i i d fi i
New code 799.52 Cognitive communication deficit
New code 799.53 Visuospatial deficit
New code 799.54 Psychomotor deficit
New code 799.55 Frontal lobe and executive function deficit
New code 799.59 Other signs and symptoms involving cognition
2011 ICD 9 Code Changes 2011 ICD-9 Code Changes
992 Eff t f h t d li ht
992 Effects of heat and light
992.0 Heat stroke and sunstroke Add U dditi l d ( ) t id tif i t d li ti f h t
Add Use additional code(s) to identify any associated complication of heat stroke, such as:
Add alterations of consciousness (780.01-780.09) Add alterations of consciousness (780.01 780.09)
Add systemic inflammatory response syndrome (995.93-995.94)
2011 Practice Expense (PE) Changes
- Second year of 4 year transition on PE methodology
Second year of 4 year transition on PE methodology – CMS is using results of 2009 AMA Physician Practice Information Survey
- www.ama-assn.org/go/ppisurvey
- Neurology $73 PE/hr, $127.21Total PE/hr; Overall
increase 3%
- Neurosurgery $81 PE/hr, $132.52 Total PE/hr;
Overall increase 2% Overall increase 2% – Assume that imaging equipment such as CT and MRI are used 90% of the time instead of current 50% – Other equipment remains at 50% usage for now – Work defined as 150,000 minutes/year (48 hour work , y ( week)
2011 MFS for Neurology Services* gy
*RVUs, excluding the conversion factor
- 95812, EEG 41-60 minutes
– Total RVUs: 9.31, +28% – Practice Expense: 8.16, 33% – Professional: 1.60, +8% Professional: 1.60, 8% – Physician Work (wRVU): 1.08, No change
- 95813, EEG > 1 hour
– Total RVUs: 10.48, +21% – Practice Expense: 8.64, 26% – Professional: 2.54, +7% – Physician Work (wRVU): 1.73, No change
2011 MFS for Neurology Services* gy
*RVUs, excluding the conversion factor
- 95816, Awake EEG
– Total RVUs: 8.39, +26% – Practice Expense: 7.22, 31% – Professional: 1.60, +8% Professional: 1.60, 8% – Physician Work (wRVU): 1.08, No change
- 95819, Awake and Asleep EEG
– Total RVUs: 9.62, +32% – Practice Expense: 8.47, 38% – Professional: 2.54, +7% – Physician Work (wRVU): 1.73, No change
2011 MFS for Neurology Services* gy
*RVUs, excluding the conversion factor
- 95822, Sleep EEG
– Total RVUs: 7.84, +33% – Practice Expense: 7.22, +31% – Professional: 1.60, +8% Professional: 1.60, 8% – Physician Work (wRVU): 1.08, No change
- 95824, EEG for Brain Death
– Total RVUs: 0.00, No change – Practice Expense: 0.00, N/A – Professional: 1.12, +8% – Physician Work (wRVU): 0.74, No change
2011 MFS for Neurology Services* gy
*RVUs, excluding the conversion factor
- 95827, Overnight EEG
– Total RVUs: 16.52, +33% – Practice Expense: 15.31, +36% – Professional: 1.60, +8% Professional: 1.60, 8% – Physician Work (wRVU): 1.08, No change
- 95829, Surgery Electrocorticogram
– Total RVUs: 44.12 +20% – Practice Expense: 37.71, +29% – Professional: 9.11, +8% – Physician Work (wRVU): 6.20, No change
2011 MFS for Neurology Services* gy
*RVUs, excluding the conversion factor
- 95950, Ambulatory Cassette EEG
– Total RVUs: 7.99, +18% P i E 6 38 22% – Practice Expense: 6.38, +22% – Professional: 2.25, +9% h i i k ( ) h – Physician Work (wRVU): 1.51, No change
- 95951, 24 Hour Video EEG
l * i d fi d h i l – Total RVUs: 0.00, *Carrier-defined technical expense – Practice Expense: *Carrier-defined technical expense – Professional: 9.14, +8% – Physician Work (wRVU): 5.99, No change
2011 MFS for Neurology Services*
*RVU l di th i f t *RVUs, excluding the conversion factor Codes presented at RUC 04/2010 by M. Spanaki
- 95953, 24 hour computerized digital EEG, unattended
– Total RVUs: 12.19, +6% P i E 7 56 8 78% – Practice Expense: 7.56, +8.78% – Professional: 4.63, 1.76% h i i k ( ) – Physician Work (wRVU): 3.08
- 95956, 24 Hour attended EEG without video
l – Total RVUs: 29.82, 49.92% – Practice Expense: 24.6, 57.19% – Professional: 5.22, +23.11% – Physician Work (wRVU): 3.61
2011 MFS for Neurology Services* gy
*RVUs, excluding the conversion factor
- 95954, EEG with administration of drugs
– Total RVUs: 9.15, +26.56% P i E 5 8 RVU 41 12% – Practice Expense: 5.8 RVUs, +41.12% – Professional: 3.35 RVUs, 7.37% h i i k ( ) – Physician Work (wRVU): 2.45
- 95955, EEG during surgery
l – Total RVUs: 4.96, 25.89% – Practice Expense: 3.48, 35.41% – Professional: 1.48, 8.03% – Physician Work (wRVU): 1.01
2011 MFS for Neurology Services* gy
*RVUs, excluding the conversion factor
- 95957, EEG Digital Analysis
– Total RVUs: 10.01, +27.68% P i E 7 05 RVU 41 12% – Practice Expense: 7.05 RVUs, +41.12% – Professional: 2.96 RVUs, 8.03% h i i k ( ) – Physician Work (wRVU): 1.98
- 95958, EEG monitoring, functional mapping (Wada Test)
l – Total RVUs: 13.39, 20.20% – Practice Expense: 7.08, 34.35% – Professional: 1.48, 8.03% – Physician Work (wRVU): 4.24
2011 MFS for Neurology Services* gy
*RVUs, excluding the conversion factor
- 95961, Electrode stimulation, brain, first hour
– Total RVUs: 7.41, +16.88% P i E 2 93 RVU 33 79% – Practice Expense: 2.93 RVUs, +33.79% – Professional: 4.48 RVUs, +7.95% h i i k ( ) – Physician Work (wRVU): 2.97
- 95962, Electrode stimulation, brain, each additional hour
l – Total RVUs: 6.67, +14.21% – Practice Expense: 1.8, +33.33% – Professional: 4.79, +8.13% – Physician Work (wRVU): 3.21
2011 MFS for Neurology Services* gy
*RVUs, excluding the conversion factor
- 95970, Analyze neurostimulator, no programming
– Physician Work (wRVU): 0.45
- 95975, Cranial neurostimulation, complex analysis and programming
– Physician Work (wRVU): 1.70
2009 AAN MEG Payment 2009 AAN MEG Payment Policy
I 2008 AAN MEM P t P li S b itt d id d t
y
In 2008, AAN MEM Payment Policy Subcommittee decided to
develop a model payment policy for MEG due to difficulties in getting MEG payments by insurers S t S t M ti Willi S th li d G L B kl – Saty Satya-Murti, William Sutherling, and Gregory L. Barkley wrote the policy – Joel Kaufman, M.D. & Katie Kuechenmeister lead AAN efforts – Passed by AAN Board of Directors on May 8, 2009 – Sent by AAN MEM to major insurance companies http://www aan com/globals/axon/assets/5641 pdf – http://www.aan.com/globals/axon/assets/5641.pdf
ACMEGS developed a similar policy in 2009
– Anto Bagic, Michael Funke, & John Ebersole wrote the policy – JClinNeurophys 26 (4) p290-293, 2009
Model payment policy, letters, & meetings changed insurance
coverage by major providers coverage by major providers
Secrets to success in dealing Secrets to success in dealing with insurance companies p
Data, data, data, especially evidence-based The AAN & ACMEGS statements are referenced in the
MEG policy review.
I am certain that the AAN MEG policy review was a crucial
piece of information in this change in policy piece of information in this change in policy – Several of the points in the AAN payment policy statement are restated in the AETNA review
Personal Contacts and establishing relationships with the
decision-makers were also key factors
CIGNA MEG Payment Policy #0248
For 12/15/2009 to 12/15/2010, “CIGNA does not cover
magnetoencephalography (MEG) or magnetic source magnetoencephalography (MEG) or magnetic source imaging (MSI) for any condition because they are considered experimental, investigational or unproven.”
The AAN MEM Payment Policy Subcommittee The AAN MEM Payment Policy Subcommittee
(PPS) met with CIGNA representatives in September 2010 p
CIGNA requested a letter regarding their policies AAN Response letter sent November 12, 2010 by
p , y Joel Kaufman, Chair of AAN PPS
CIGNA has not yet posted MEG policy for 2011
2011 Medicare MEG Medicare Fee Schedule
95965 Spontaneous MEG for epileptic spike mapping
2011 P ofe io al 12 34 Total RVU (7 99 RVU ) – 2011 Professional 12.34 Total RVUs (7.99 wRVUs)
- 2010 11.83 Total RVUs (+8.0%) Payment ?
– 2011 Technical (APC 067) $3408.69 (‐4.6 %)
95966 Evoked magnetic fields 95966 Evoked magnetic fields
– 2011 Professional 6.16 Total RVUs (3.99 wRVUs) 2010 5.72 Total RVUs (+8,0 %) Payment ? Technical (APC 066) $977 12 – Technical (APC 066) $977.12
- 2010 $962.61 (+1.5 %)
95967 Each additional evoked magnetic field procedure
2011 Professional 5 34 Total RVUs (3 49 wRVUs) – 2011 Professional 5.34 Total RVUs (3.49 wRVUs)
- 2010 4.92 Total RVUs (+9.0 %) Payment ?
– Technical (APC 066) $977.12
- 2010 $962 61 (+1 5 %)
- 2010 $962.61 (+1.5 %)
* When one procedure is performed with another, payment would be reduced by 50% * Charges to private insurance are set by each laboratory and cannot be compared due to US antitrust (price fixing) laws be compared due to US antitrust (price‐fixing) laws
MEG Practice Expense MEG Practice Expense Payment Rate y
The Affordable Care Act (ACA) requires that
CMS establish the equipment utilization rate CMS establish the equipment utilization rate for CT, MR and PET at 75 percent. CMS had previously set the equipment utilization rate for p y q p this equipment at 90 percent, phasing in reduced payments over four years. This may lt i h t t t f CT d result in changes to payment rates for CT and MR services.
May affect MEG technical pricing since MEG May affect MEG technical pricing since MEG
grouped in imaging APCs
2010 e Prescribing 2010 e-Prescribing
PQRI i i f R
- PQRI revision for e-Rx
– For 2011, only have to report at least 25 uses of e-Rx to qualify for PQRI payment – Failure to register for e-Rx in first half of 2011 and do not qualify for an exemption will face penalties in 2012. – AAN has signed on to a letter of protest – Physicians who participate in 2011 EHR cannot participate in e-Rx incentive program
PQRI
(Ph i i Q lit R ti I iti ti ) (Physician Quality Reporting Initiative)
http://www.cms.hhs.gov/apps/media/press/factsheet.asp?
AAN h d l d 8 il l d b N F t i
- AAN has developed 8 epilepsy measures lead by N. Fountain
and P Van Ness Approved by AMA Physician's Consortium for – Approved by AMA Physician s Consortium for Performance Improvement – Currently under review by National Quality Forum y y y (NQF) – If NQF approves, then will be submitted to CMS for ibl i l i i th PQRI possible inclusion in the PQRI – Being developed by AAN for Maintenance of Certification program as a module Certification program as a module
CPT M di P t R l ti t Sit CPT Medicare Payment Relative to Site
- f Services
Professional Component Technical Component Inpatient Use -26 modifier; Paid to physician Single DRG payment made to hospital to cover all technical expenses p for that admission (IPPS) Outpatient medical center (includes EDs) Use -26 modifier; Paid to physician APC payment made to medical center (HOPPS) (includes EDs) Paid to physician medical center (HOPPS) Outpatient, private office Global bill Global bill Submitted for professional and technical components Submitted for professional and technical components Paid to physician Paid to physician
M i f S i /E il DRG Mapping of Seizure/Epilepsy DRG
Documentation Principle
Diagnosis Secondary Diagnosis MS DRG v25
Seizure, psychogenic nonepileptic seizure, 780.39
(other l i )
101 Sz w MCC 100
spells
( convulsions)
100 Sz w/o MCC
Recurrent seizures,
345 8y 101
Epilepsy, Seizure disorder Specific epilepsies
345.8y
(other recurrent seizures)
345 101 Sz w MCC 100 Sz w/o MCC
p p p
345.xy
Psychogenic
300.11 780.39 880 Acute
conversion disorder
300.11
(Conversion disorder)
780.39 880 Acute
Adjustment Reaction
2011 Hospital Outpatient Prospective Payment System (HOPPS) Payment System (HOPPS)
Published 11/24/2010
– 782 pages in the Federal Register – 782 pages in the Federal Register – http://edocket.access.gpo.gov/2010/pdf/2010-27926.pdf
Payment for the technical portion of CPT codes done on Medicare Payment for the technical portion of CPT codes done on Medicare
Outpatients
Some outpatient procedures with HOPPS values have no payment
i d i MFS f d billi l b l assigned in MFS for doctors billing global – 95951 24 hour video EEG is “carrier priced” 95965 MEG i “ i i d” – 95965 MEG is “carrier priced”
Payment for technical portion of Medicare inpatients is bundled into a
single DRG payment single DRG payment
Payment for technical fees in outpatients in private offices is in the
Medicare Physician Fee Schedule
- Billing “global” in private offices
2011 HOPPS APC 0213 2011 HOPPS APC 0213
APC 0213 L l 1 Sl EEG d CV t di
- APC 0213 Level 1 Sleep, EEG, and CV studies
– 95812 EEG 41-60 min – 95812 EEG > 1 hour – 95816 EEG awake and drowsy – 95819 EEG awake and asleep – 96822 EEG sleep and/or coma – 95827 EEG all night recording – 95958 EEG monitoring/function test
- 2010 APC rate is $162.06
- 2011 APC rate will be $166.64
2011 APC rate will be $166.64
- Increase of $4.62 or 2.83%
2011 HOPPS APC 0209 2011 HOPPS APC 0209
APC 0209 L l II l EEG & CV
- APC 0209 Level II sleep, EEG, & CV
– 95950 ambulatory cassette EEG – 95951 24 hour video EEG – 95953 ambulatory digital EEG 95953 ambulatory digital EEG – 95956 24 hour EEG without video MSLP and polysomnograms – MSLP and polysomnograms
- 2010 APC Rate is $770.55
- 2011 APC Rate will be $780.77
- Increase of $10 22 or 1 33%
- Increase of $10.22 or 1.33%
2011 HOPPS APC 218 2011 HOPPS APC 218
APC 218 L l II N d M l T t
- APC 218 Level II Nerve and Muscle Tests
– 95970 Neurostimulation, analysis with no programming – 95954 EEG monitoring with drug administration
- 2010 payment is $80.65
- 2011 payment will be $80 78
- 2011 payment will be $80.78
- Increase of $0.13 or 0.16%
2011 HOPPS APC 216 2011 HOPPS APC 216
APC 216 L l III N d M l T t
- APC 216 Level III Nerve and Muscle Tests
– 95961 Cortical Stimulation, 1st hour – 95962 Cortical Stimulation, each additional hour
- 2010 payment is $180 86
2010 payment is $180.86
- 2011 payment will be $186.17
- Increase of $5.31 or 2.94%
2011 HOPPS APC 0692 2011 HOPPS APC 0692
- APC 0692 Level III Electronic Analysis of Devices
y
– 95971 Analyze neurostim, simple – 95972 Analyze neurostim, complex y , p – 95973 Analyze neurostim, complex – 95974 Cranial neurostim, complex – 95974 Cranial neurostim, complex – 95978 Analyze neurostim brain, 1st hour – 95979 Analyze neurostim brain, each 1 hour – 95982 Low gain neurostim subseq w/ reprogram
- 2010 payment is $107.85
- 2011 payment will be $110.95
2011 payment will be $110.95
- Increase of $3.10 or 2.87%
2011 MEG HOPPs
T h i l t f MEG t di i h it l
Technical payments for MEG studies in hospital-
based outpatient care facilities Does not apply to free standing MEG sites –Does not apply to free standing MEG sites
- Carrier priced
–Does not apply to MEG studies done on inpatients –Does not apply to MEG studies done on inpatients
- Technical fees bundled to DRG
2010 HOPPS APC 0067 2010 HOPPS APC 0067
- APC 0065 Level III Stereotactic Radiosurgery, MRgFUS, and
MEG MEG – 95965 MEG, spontaneous
- 2010 payment is $3571.78
- 2011 payment is $3408.69
- Decrease of $163.09 or 4.57%
- Caught by the change in assumption of work hours for
g y g p equipment costing more than $1 M. Decrease of $394.54 in past two years. N MEG i h l
- New MEG cost reporting may help
– MEG and EEG were combined on Line 54 of the Medicare Cost Report Cost Report – Now MEG is moved to a new line, 54.01
2011 HOPPs APC 0065
L l I St t ti di M GUS d MEG
Level I Stereotactic radiosurgery, MrgGUS, and MEG
– 95966 MEG Evoked Response – 95967 Additional MEG Evoked Response 95967 Additional MEG Evoked Response
2010 payment is $962.61 2011 payment will be $977 12 2011 payment will be $977.12 Increase of $14.51 or 1.5%
Update on HFHS Transition to p ICD-10 Coding System
Kickoff: December 9 2010 Kickoff: December 9, 2010
Nov 18th , 2010 Nov 18 , 2010
ICD‐10‐CM/PCS
(Cli i l M difi ti /P d C di S t ) (Clinical Modification/Procedure Coding System)
Final Rule: HHS published on Jan 2009 Compliance Date: October 1st, 2013
- ICD‐10‐CM/PCS will enhance accurate payment for services rendered and facilitate
evaluation of medical processes and outcomes. h di i l ifi i d l d b h f i l
- ICD‐10‐CM – The diagnosis classification system developed by the Centers for Disease Control
and Prevention for use in all (inpatient and outpatient) U.S. health care treatment settings. Diagnosis coding under this system uses 3–7 alpha and numeric digits and full code titles, but the format is very much the same as ICD‐9‐CM ICD 10 PCS Th d l ifi i d l d b h C f M di &
- ICD‐10‐PCS – The procedure classification system developed by the Centers for Medicare &
Medicaid Services (CMS) for use in the U.S. for inpatient hospital settings ONLY. The new procedure coding system uses 7 alpha or numeric digits while the ICD‐9‐CM coding system uses 3 or 4 numeric digits. A b f h i h l d d ICD 10 i l di
- A number of other countries have already moved to ICD‐10, including:
– United Kingdom (1995); – France (1997); – Australia (1998); – Germany (2000); and – Canada (2001).
65
HIPAA X12 5010 Electronic Transaction Changes HIPAA X12 5010 Electronic Transaction Changes
All HIPAA X12 El t i T ti ith ( li ibilit
- All HIPAA X12 Electronic Transactions with payors (e.g., eligibility
verification, claims, remittance advise) have to be upgraded from current 4010 version to newer 5010 version
- This will enable payors to request more information in the future
electronic transactions electronic transactions (adding extra lanes to electronic freeway system to carry more information)
- This change has to be operational by Jan 1 2012 and it is a pre‐
requisite for ICD 10 CM/PCS changes requisite for ICD 10 CM/PCS changes
66
ICD‐9‐CM ‐ Shortcomings
- Shortcomings of ICD‐9 include:
– ICD‐9 is outdated, with only a limited ability to accommodate new procedures and diagnoses; – ICD‐9 lacks the precision needed for a number of emerging uses such as pay‐ for‐performance and biosurveillance. Biosurveillance is the automated monitoring of information sources that may help in detecting an emerging epidemic, whether naturally occurring or as the result of bioterrorism; – ICD‐9 limits the precision of diagnosis‐related groups (DRGs) as a result of very p g g p ( ) y different procedures being grouped together in one code; – ICD‐9 lacks specificity and detail, uses terminology inconsistently, cannot capture new technology, and lacks codes for preventive services; and capture new technology, and lacks codes for preventive services; and – ICD‐9 will eventually run out of space, particularly for procedure codes.
67
Expected Benefits from usage of ICD 10 codes Expected Benefits from usage of ICD 10 codes
- Adoption of the ICD‐10 code sets is expected to:
S t l b d h i d M di ’ ti f d d b – Support value‐based purchasing and Medicare’s anti‐fraud and abuse activities by accurately defining services and providing specific diagnosis and treatment information; – Support comprehensive reporting of quality data; pp p p g q y ; – Ensure more accurate payments for new procedures, fewer rejected claims, improved disease management, and harmonization of disease monitoring and reporting worldwide; and All th U it d St t t it d t ith i t ti l d t t t k – Allow the United States to compare its data with international data to track the incidence and spread of disease and treatment outcomes because the United States is one of the few developed countries not using ICD‐10.
68
Next Generation of Coding
S. No. ICD‐9‐CM ICD‐10‐CM / PCS
Structural Changes
1. Minimum of 3 digits, maximum of 5 digits, decimal point after the third digit Minimum of 3 digits, maximum of 7 digits, decimal point after the third digit 2. Numeric, except for supplementary codes — V d d d Alphanumeric, with all codes using alphabetic lead character; V d d h b l d d d h codes and E codes and E codes have been eliminated and incorporated into the main code set 3. Structure of injuries designated by wound type Structure of injuries designated by body part (location) 4. Diagnosis: 13,000 Codes IP Procedure: 4,000 Codes 67,000 ICD‐10‐CM Codes 87,000 ICD‐10‐PCS Codes
M i ICD 9 T ICD 10
One to One: One old code to one new code . 3,458 codes or 24.52 % of all ICD‐9 DX codes Single Entry: One old code to one of many new code. 9,600 codes or 68.07 % of all ICD‐9 DX codes
Mapping – ICD‐9 To ICD‐10
Combination Entry: One old code is split into multiple new code. 629 codes or 4.46 % of all ICD‐9 DX codes No Match: All new codes. 416 codes or 2.95 % of all ICD‐9 DX codes
69
Difference between ICD‐9 and ICD‐10
ICD‐9‐CM Mechanical complication of other vascular device, implant and graft 1 code (996.1) ICD‐9‐CM Angioplasty 1 code (39.50)
ICD‐10‐CM Mechanical complication of other vascular grafts 156 codes, including T82 310 B kd ( h i l) f ti (bif ti ) ft ICD‐10‐PCS Angioplasty codes 854 codes S if i b d t h d d i i l di T82.310 – Breakdown (mechanical) of aortic (bifurcation) graft (replacement) T82.311 – Breakdown (mechanical) of carotid arterial graft (bypass) T82 312 Breakdown (mechanical) of femoral arterial graft (bypass) Specifying body part, approach, and device, including: 047K04Z – Dilation of right femoral artery with drug‐eluting intraluminal device, open approach 047K0DZ Dilation of right femoral artery with intraluminal device T82.312 – Breakdown (mechanical) of femoral arterial graft (bypass) T82.318 – Breakdown (mechanical) of other vascular grafts T82.319 – Breakdown (mechanical) of unspecified vascular grafts 047K0DZ – Dilation of right femoral artery with intraluminal device,
- pen approach
047K0ZZ – Dilation of right femoral artery, open approach 047K34Z – Dilation of right femoral artery with drug‐eluting T82.320 – Displacement of aortic (bifurcation) graft (replacement) T82.321 – Displacement of carotid arterial graft (bypass) T82.322 – Displacement of femoral arterial graft (bypass) 047K34Z Dilation of right femoral artery with drug eluting intraluminal device, percutaneous approach 047K3DZ – Dilation of right femoral artery with intraluminal device, percutaneous Approach p g ( yp ) T82.328 – Displacement of other vascular grafts
70
ICD‐10 Example
Fracture of wrist
- Patient fractures left wrist
- A month later, fractures right wrist
- ICD‐9‐CM does not identify left versus right
(requires additional documentation to clarify during claim adjudication)
- ICD‐10‐CM describes left versus right, Initial encounter, subsequent
encounter, routine healing, delayed healing, nonunion, or malunion
71
Potential Risks of Transition to ICD10 Potential Risks of Transition to ICD10
T i i d Ed ti ICD10 d b d h t
- Training and Education – ICD10 codes are based on human anatomy
and physiology will require significant mind set change for coders to get used to new system
- Business Process – Potential significant shift in roles and
responsibilities between clinicians and coders to handle the complexity of ICD 10s complexity of ICD 10s
- Information Technology – Significant risk in modifications to several
systems to accommodate new code sets i i l/ i b f
- Financial/Reimbursement – Transition from ICD 9 to ICD 10 can
result into temporary delays in cash flow from payors due to technology implementation glitches
72
ICD 10 Potential Impacts to HFMG Operations
Si ifi h i h f
- Significant process changes in the areas of
documentation, coding and charge capture
- May result in extensive training for Physicians,
Coders and other care‐givers
- MediPac revenue cycle systems will be modified to
address transition to ICD 10
- OMR and TCAP systems have to be replaced with
newer technology to handle the complexity and explosion of ICD 10 codes
74
OMR Considerations OMR Considerations
- HFMG Clinic Coding model: Physician Model
enabled by branching technology logic (CAC) vs. Centralized Coder model
- Handheld devices with future integration with
g CarePlus(NG)/CPOE solution
75
HFHS ICD-10 Project Phasing Phase 1 – Impact Assessment & Planning
- Develop project management structure
- Engage Steering Committee and Business Unit Operational Teams
- Assess Process Implications
- Assess Process Implications
- Assess IT Systems impact
- Create Multi‐Year Capital and Expense budget to address the change
Phase 2 – Process Redesign and IT System Changes
- Process Redesign‐Current and Future State
- Detailed analysis, design and build of IT changes
C t t ti l t lid t d i d IT t h
- Create testing plans to validate process redesign and IT system changes
76
HFHS ICD-10 Project Phasing Phase 3 – Testing and Implementation Planning
- Internal Testing and Training
- External Testing (Payors, Regulatory Reporting)
- Operational Readiness and Implementation Planning
Operational Readiness and Implementation Planning
Phase 4 – End User Training and Go‐Live
- Finalize IT system changes and certify testing
- Finalize process changes and certify operational readiness
C l t i t i di f i l d ti
Phase 5 – Post Go‐Live Support
- Complete intensive coding professional education
Phase 5 – Post Go‐Live Support
- Monitor coding accuracy for reimbursement, coding productivity and continue
with appropriate coding professional training
77
HFHS Project Phasing and Tentative Timeline
Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 2011 2012 2013 2010 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4
Phase 1 - Impact Assessment & Planning Phase 2 - Process Redesign
Jan 1, 2012 - Version 5010 EDI Transaction Compliance
g and IT System Modifications Phase 3- Testing and Implementation Planning
Oct 1, 2013 ICD 10 Compliance
p g Phase 4- End User Training and Go-Live Phase 5 - Post Go-Live Support
78
Key components of level of service Key components of level of service
History
- Chief complaint (CC)
- History of present illness (HPI)
History History of present illness (HPI)
- Past medical, family, social history (PFSH)
- Review of systems (ROS)
Examination
- Neurological single system exam
Examination
- Neurological single system exam
- r general multi-system exam
Medical Decision Making
- Number of diagnoses or number of
management options
- Complexity of data
Making
- Complexity of data
- Risk of morbidity and mortality
You Get Credit for Trying You Get Credit for Trying...
S ti t d f ll H & P tt h t
- Sometimes, you cannot do a full H & P no matter what
– Document your attempt and what happened
- History
– Patient aphasic, lethargic, in coma, won't answer, demented, etc.
- PE
– Patient aphasic, uncooperative, limb amputated, strict bedrest, etc.
- Do not write “unable to obtain”
- Forgetting one bullet point on a New Patient visit has
major consequences in billing: drops to a level 1 visit
Tips for documenting history Tips for documenting history
- CC always required
- ROS is very important
– must document pertinent positives, may be in HPI “all other systems negative” permitted – “all other systems negative” permitted – ROS deficiency a major reason for not meeting criteria for highest level of service g
- ROS and PFSH
– staff may record, and physician note – may use previous ROS and PFSH, revise as needed
- If history not obtainable document why
- If history not obtainable, document why
History of Present Illness (HPI) History of Present Illness (HPI)
1997 E &M G id li ll f th ti f 1997 E &M Guidelines allow for the option of documenting the status/acuity of chronic problems and/or inactive problems to complete the History of and/or inactive problems to complete the History of Present Illness. IMPORTANT: You must document the chronic or inactive problem that you are addressing during p y g g the visit and detail the current status/acuity of the problem
Documenting the neurological g g examination
- CPT™ defines 25 individual elements (“bullets”) of the
neuro exam, in 4 main groups
– constitutional, eyes, cardiovascular – higher integrative functions or mental status cranial nerves – cranial nerves – musculoskeletal, motor, and sensory
- CPT™ specifies the numbers of elements that must be
CPT specifies the numbers of elements that must be documented for each level of service
- You must comment on these elements (“WNL” not
( acceptable)
Medical Decision Making (MDM) Medical Decision Making (MDM)
Documentation Tips Documentation Tips
- Document the test(s) that you have reviewed (summarize what you have
reviewed) and ordered
- Document discussing test(s) with the physician who performed the test
- Document discussing test(s) with the physician who performed the test.
For example discussing with the cardiologist the interpretation of an echocardiogram
- Document the review of old records. Remember you must summarize
y what you have reviewed.
- For Example: Patient was admitted a month ago for __________.
Course of treatment included ____and patient was discharged with home health care and continue with home health care and continue with _________.
IF IT IS NOT DOCUMENTED IT IS NOT DONE
Medical Decision Making (MDM) Medical Decision Making (MDM)
M di l d i i ki f t th l it f Medical decision making refers to the complexity of establishing a diagnosis and/or selecting a management option It can be broken down into three management option. It can be broken down into three components.
– Number of diagnoses or management options g g p – Amount and complexity of data to review (Previous documentation tips support this component) Ri k f li ti d/ bidit t lit – Risk of complication and/or morbidity or mortality
2002 CMS Regulations on Supervision
- f Residents and Students
- Effective date November, 22, 2002
R id t i di id l h ti i t i
- Resident means an individual who participates in an
approved graduate medical education (GME) program
- Receiving a staff or faculty appointment or participating in a
- Receiving a staff or faculty appointment or participating in a
fellowship does not by itself alter the status of “resident”.
- A student is never considered to be an intern or a resident.
Medicare does not pay for any clinical service furnished by a student. (Medicare pays hospitals and medical schools l f i th ) large sums of money in other ways.)
Medicare Teaching Definitions Medicare Teaching Definitions
- Critical or key portion means that part (or parts) of
a service that the teaching physician determines is g p y (are) a critical or key portion(s).
- Documentation may be dictated and typed hand-
Documentation may be dictated and typed, hand written or computer-generated, and typed or handwritten handwritten.
- Documentation must be dated and include a legible
i t id tit signature or identity.
Payment Definitions y
- For purposes of payment, E/M services billed by teaching
physicians require that they personally document at least the physicians require that they personally document at least the following:
– a. That they performed the service or were physically present during h k i i l i f h i h f d b h the key or critical portions of the service when performed by the resident; and – b. The participation of the teaching physician in the management of p p g p y g the patient.
- When assigning codes to services billed by teaching
h i i i ill bi h d i f b h physicians, reviewers will combine the documentation of both the resident and the teaching physician.
- Documentation for the service must support the medical
- Documentation for the service must support the medical
necessity of the service.
Examples of Acceptable Notes p p
- “I was present with resident during the history and
p g y
- exam. I discussed the case with the resident and agree
with the findings and plan as documented in the id t’ t ” resident’s note.”
- “I saw the patient with the resident and agree with the
resident’s findings and plan ” resident s findings and plan.
- “See resident’s note for details. I saw and evaluated the
patient and agree with the resident’s finding and plans pat e t a d ag ee w t t e es de t s d g a d p a s as written.”
- “I saw and evaluated the patient. Agree with resident’s
note but lower extremities are weaker, now 3/5; MRI of L/S Spine today.”
Examples of Unacceptable Notes Examples of Unacceptable Notes
- “Agree with above.”
- “Rounded, Reviewed, Agree”
, , g
- “Discussed with resident. Agree.”
“S d ”
- “Seen and agree.”
- “Patient seen and evaluated”
- A legible countersignature or identity alone.
E/M Service Documentation Provided d By Students.
A ib i d i i i f d
- Any contribution and participation of a student to
the performance of a billable service (other than the i f t d/ t f il / i l hi t review of systems and/or past family/social history which are not separately billable, but are taken as part of an E/M service) must be performed in the part of an E/M service) must be performed in the physical presence of a teaching physician or physical presence of a resident in a service meeting physical presence of a resident in a service meeting the requirements set forth in this section for teaching physician billing. e c g p ys c b g.
E/M Service Documentation Provided d By Students.
S d d i i h di l d
- Students may document services in the medical record.
- Documentation by a student that may be referred to by the
teaching physician is limited to the review of systems and/or teaching physician is limited to the review of systems and/or past family/social history.
- The teaching physician may not refer to a student’s
The teaching physician may not refer to a student s documentation of physical exam findings or medical decision making in his or her personal note.
- The teaching physician must verify and redocument the
history of present illness as well as perform and redocument th h i l d di l d i i ki ti iti f the physical exam and medical decision making activities of the service.
DISCHARGE DAY
- On the day of discharge code as follows:
On the day of discharge code as follows:
- On the day of discharge, code as follows:
On the day of discharge, code as follows: – 99238 for a total staff time of 30 minutes or less 99238 for a total staff time of 30 minutes or less – 99239 for a total staff time of more than 30 minutes 99239 for a total staff time of more than 30 minutes
- You must document the time spent in your note
You must document the time spent in your note – Time does not need to be continuous Time does not need to be continuous Time does not need to be continuous Time does not need to be continuous – Time does not need to be spent with the patient Time does not need to be spent with the patient and includes: and includes:
- Writing Rx
Writing Rx
- Doing discharge summary
Doing discharge summary
- Making follow up arrangements
Making follow up arrangements
- Contacting other providers
Contacting other providers
- Resident time does not count