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E/M Coding & Auditing

Paul Chandler, BS-HRM, AA-C

CPC, CPC-I, CPC-H, CPC-P, CPMA, CPCO, CPPM, CPB, CANPC, CCC, CCVTC, CEDC, CEMC, CFPC, CGSC, CGIC, CHONC,

CIMC, COBGC, COSC, CPCD, CPEDC, CPRC, CRHC, CUC

E/M content standards and documentation criteria

Qualitative versus quantitative necessity standards

CMS Value Modifier

How to make a record audit ready

EHR Challenges to coding and auditing

A/R staff’s role in regulatory compliance

How to initiate a self-audit

Today’s Objectives:

Subjective (history)

Objective (exam)

Assessment (MDM)

Plan (MDM)

SOAP note

MDM = Medical Decision Making

1995 CMS Guidelines

15 pages

Examinations are based on the organ systems and body areas.

1997 CMS Guidelines

53 pages

Examinations are based on bullets outlined through specific system examinations.

CMS Guidelines

Audit Sheets

Based on the documentation provided, E/M services are provided with a score based on 3 necessary components.

History

Examination

Medical Decision Making

Factors used to decide level: time spent with patient, coordination of care provided, the presenting problem of the patient, and counseling provided by the doctor(s).

Components of E/M services

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Four areas of documentation needed to decide correct level of history:

Chief Complaint (CC)

History of Present Illness (HPI)

Review of Systems (ROS)

Past, Family, and Social History (PFSH)

HISTORY

The Chief Complaint provides the medical necessity requirement of the E/M service provided.

“The medical record should clearly reflect the chief complaint”, CMS Guidelines.

The doctor is required to write, type, or dictate a chief complaint for the medical record.

Example:

NO: patient has headache (good)

YES: patient presents with chronic non-progressive headache in the frontal lobe (better, helps HPI)

HISTORY: Chief Complaint

Location

Context

Modifying Factors

Associated Signs & Symptoms

Quality

Severity

Timing

Duration

HISTORY: History of Present Illness HISTORY: History of Present Illness

1995 Guidelines

Brief History

1-3 elements

Extended History

4+ elements

1997 Guidelines Brief History 1-3 elements

Extended History 4+ elements OR 3+ chronic/inactive conditions

Allergy / Immunology

Cardiovascular

Constitutional

Ears, Nose, Throat (ENT)

Endocrine

Eyes

GI

GU

Homeopathy / Lymphadenopathy

Integumentary

Musculoskeletal

Neurologic

Psychiatric

Respiratory

HISTORY: Review of Systems

ROS documentation must contribute to the CC

Cannot ‘double dip’ (by payors, different MACs, organizational documentation may or may not allow it, typically we are taught we cannot)

All ROS must meet medical necessity

If a positive finding is documented, it must be specified (not just ‘yes’)

Following the positive finding documentations, doctor may say “all remaining # ROS were reviewed and all # were negative” is acceptable

HISTORY: Review of Systems

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Available options:

None

Pertinent to 1 system

Extended to 2-9 systems

Complete 10 systems or “all other # negative”

HISTORY: Review of Systems

Past Medical, Family, & Social History Past History Current medications, past surgeries, past illnesses Family History Parents, siblings, children, aunts and uncles (by blood),

grandparents Social History Smoking, alcohol usage, marital status, sexual history, employment

status, education information

HISTORY: PFSH

Established patient:

Detailed = 1 history area

Comprehensive = 2-3 history areas

New patient:

Detailed = 1-2 history areas

Comprehensive = 3 history areas

HISTORY: PFSH

Level of history is determined by the column that is marked farthest to the left.

2 detailed + 1 comprehensive = 1 detailed

HISTORY

Problem Focused: 1 organ system or 1 body area (limited…..) Exp. Problem Focused: 2-7 organ systems or body areas, no detail of system requirement (limited…..) Detailed: 2-7 organ systems of body areas, with affected system in detail Comprehensive: 8+ organ systems

OR Problem Focused: 1 organ system or 1 body area Exp. Problem Focused: 2-4 organ systems or body areas Detailed: 5-7 organ systems or body areas Comprehensive: 8+ organ systems

Examination – 95 guidelines

Problem Focused: 1-5 elements identified by a bullet

Exp. Problem Focused: 6+ elements identified by a bullet

Detailed: 2+ elements identified by a bullet from each 6 areas/systems OR at least 12 elements identified by a bullet in 2+ areas/systems

Comprehensive: Performed all elements identified by a bullet and document at least 2 elements by a bullet from each of the 9 areas/systems

Examination – 97 guidelines

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Three areas of documentation:

Diagnosis (based on points)

Complexity (based on points)

Risk (based on elements)

Cannot get credit for mentioning a diagnosis that may be not applicable to the day’s visit.

Minimum of one diagnosis treated with a developed plan of care.

Diagnosis should have relevance to the treatment.

Mentioning diagnosis may be a secondary issue.

Medical Decision Making MDM: Diagnosis

MDM: Complexity MDM: Risk

Level with 2 components or 1 in the middle

MDM Scoring

Depending on the CPT code, either 2 of 3 or 3 of 3 components are required.

2 of 3 = middle or level of 2 components

Established patient, office visit

3 of 3 = the lowest component of all 3

New patient, office visit

Level of Service

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Place of Service = Office

New/Est. = Established

Code ranges: 99211-99215

2/3 or 3/3? 2 out of 3 components

1995 Guidelines

Detailed History

Detailed Exam

Moderate MDM

CPT 99214

1997 Guidelines

Detailed History

Expanded Problem Focused Exam

Moderate MDM

CPT 99214

Level of Service example

Medical necessity is the key to avoiding fraud/abuse

Key

Many people feel more comfortable in the realm of numbers and, as a result, frequently design their evaluations solely around quantitative data. But this approach provides only a partial picture of your project. Quantitative data can lead to conclusions about your project that miss the larger picture.

For example: A hospital implements a new clinical reminder system with the

goal of increasing compliance with health maintenance recommendations. An evaluation study is devised to measure the percentage change in the number of patients discharged from the facility who receive influenza vaccines, as recommended.

Consider both Quantitative and Qualitative Metrics

The study is carried out, and, to the disappointment of the research team, the rates of vaccinated patients discharged pre- and post-implementation do not change. The team concludes that their implementation goals have not been met, and that the money spent on the system was a poor investment.

But a qualitative study of the behaviors of the clinicians using the new system would have reached different conclusions. In this scenario, the qualitative study reveals that clinicians, bombarded with a number of alerts and health maintenance reminders, click through the alerts without reading them. The influenza vaccine reminders are not read; thus the rates of influenza vaccination remain unchanged.

Consider both Quantitative and Qualitative Metrics

The study also notes that a significant number of clinicians are distracted by and frustrated with the frequent alerts generated by the new system, with no way to distinguish the more important alerts from the less important ones. In addition, some clinicians are unaware of the evidence supporting this vaccine reminder and of the financial (pay-for-performance) implications for the hospital if too few patients receive this vaccine. One clinician had the idea that the vaccine reminder could be added to the common admission order sets. These findings could be used to refocus the design, education, and implementation efforts for this intervention.

Consider both Quantitative and Qualitative Metrics

But, lacking a qualitative evaluation, these insights are lost on the project team.

Qualitative studies add another important dimension to an evaluation study: They allow evaluators to understand how users interact with a new system. In addition, qualitative studies speak to a larger audience because they generally are easier to understand than quantitative studies. They often generate anecdotes and stories that resonate with audiences.

Source: HealthIT.gov

Consider both Quantitative and Qualitative Metrics

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Section 3007 of the Affordable Care Act mandated that, by 2015, CMS begin applying a value modifier under the Medicare Physician Fee Schedule (MPFS)

VM assesses both quality of care furnished and the cost of that care under the

Medicare Physician Fee Schedule

For CY 2015, CMS will apply the VM to groups of physicians with 100 or more eligible professionals (EPs)

For CY 2016, CMS will apply the VM to groups of physicians with 10 or more EPs Phase-in to be completed for all physicians by 2017

Implementation of the VM is based on participation in Physician Quality Reporting

System

Value-Based Payment Modifier PQRS Value Modifier EHR Incentive Program

Eligible for

Incentive

Subject to

Payment

Adjustment

Included in

Definition

of “Group” (1)

Subject to

VM (2)

Eligible for

Medicare

Incentive

Eligible for

Medicaid

Incentive

Subject to Medicare

Payment Adjustment

Medicare Physicians

Doctor of Medicine X X X X X X X

Doctor of Osteopathy X X X X X X X

Doctor of Podiatric Medicine X X X X X X

Doctor of Optometry X X X X X X

Doctor of Oral Surgery X X X X X X X

Doctor of Dental Medicine X X X X X X X

Doctor of Chiropractic X X X X X X

Practitioners

Physician Assistant X X X X

Nurse Practitioner X X X X

Clinical Nurse Specialist X X X

Certified Registered Nurse

Anesthetist X X X

Certified Nurse Midwife X X X X

Clinical Social Worker X X X

Clinical Psychologist X X X

Registered Dietician X X X

Nutrition Professional X X X

Audiologists X X X

Therapists

Physical Therapist X X X

Occupational Therapist X X X

Qualified Speech-Language

Therapist X X X

Distinction: Medicare Physicians & Eligible Prof.

The size of a group is determined by how many EPs comprise the group

Definition of Group: A single Tax Identification Number (TIN) with 2 or more

individual EPs(as identified by Individual National Provider Identifier [NPI]) who have reassigned their billing rights to the TIN

An EP is defined as any of the following:

• A physician • A physician assistant (PA), nurse practitioner (NP), or clinical nurse specialist; a

certified registered nurse anesthetist; a certified nurse-midwife; a clinical social worker; a clinical psychologist; or a registered dietitian or nutrition professional

• A physical or occupational therapist or a qualified speech-language pathologist • A qualified audiologist

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How Is a Group Practice Defined?

Physicians include: • MDs / DOs • Doctor of dental surgery or dental

medicine • Doctor or podiatric medicine • Doctor of optometry • Chiropractor

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VM Will Be Applied to Physician Payment Only

PQRS Value Modifier EHR Incentive Program

Incentive Pay Adj

10-99 EPs 100+ EPs

Medicare Inc.

Medicaid Inc.

Medicare Pay Adj

PQRS-Reporting

Non-PQRS Reporting

PQRS-Reporting (Up or Neutral Adj)

PQRS-Reporting (Down Adj)

Non-PQRS Reporting

MD & DO

0.5% of MPFS (1.0% with

MOC)

-2.0% of

MPFS

+2.0 (x), +1.0(x),

or neutral

-2.0% of

MPFS

+2.0 (x), +1.0(x),

or neutral

-1.0% or -2.0% of

MPFS

-2.0% of

MPFS

$4,000-$12,000 (based

on when EP 1st demo MU)

$8,500 or $21,250

(based on when EP

did A/I/U)

$8,500 or $21,250

(based on when EP

did A/I/U) -2.0%

of MPFS

DDM

Oral Sur

Pod. N/A

Opt.

Chiro.

2014 Incentives and 2016 Payment Adjustments PQRS Value

Modifier EHR Incentive Program

Incentive Pay Adj. Groups of 10+

EPs Medicare

Inc. Medicaid

Inc. Medicare Pay Adj.

Practitioners

Physician Assistant

0.5% of MPFS

-2.0% of MPFS

EPs included in the definition of “group” to determine group size for application of the value modifier in 2016 (10 or more EPs); VM only applied to reimbursem*nt of physicians in the group

N/A

$8,500 or $21,250 (based on when EP did A/I/U)

N/A

Nurse Practitioner

Clinical Nurse Specialist N/A

Certified Registered Nurse Anesthetist

Certified Nurse Midwife $8,500 or $21,250 (based on when EP did A/I/U)

Clinical Social Worker

N/A

Clinical Psychologist

Registered Dietician

Nutrition Professional

Audiologits

Therapists

Physical Therapist 0.5% of MPFS

-2.0% of MPFS

See above

N/A N/A N/A Occupational Therapist

Qualified Speech-Language Therapist

2014 Incentives and 2016 Payment Adjustments

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Value Modifier Components

2015 Finalized Policies

2016 Finalized Policies

Performance Year 2013 2014

Group Size 100+ 10+

Available Quality Reporting Mechanisms

GPRO-Web Interface, CMS Qualified Registries, Administrative Claims

GPRO-Web Interface (Groups of 25+ EPs), CMS Qualified Registries, EHRs, and 50% of EPs reporting individually

Outcome Measures

NOTE: The performance on the outcome measures and measures reported through the PQRS reporting mechanisms will be used to calculate a quality composite score for the group for the VM.

All Cause Readmission Composite of Acute Prevention Quality Indicators: (bacterial pneumonia, urinary tract infection, dehydration) Composite of Chronic Prevention Quality Indicators: (chronic obstructive pulmonary disease (COPD), heart failure, diabetes)

Same as 2015

Patient Experience Care Measures N/A PQRS CAHPS: option for groups of 25+ EPs; required for groups of 100+ EPS reporting via Web Interface

Value Modifier Policies for 2015 & 2016 Value Modifier Components

2015 Finalized Policies

2016 Finalized Policies

Cost Measures Total per capita costs measure (annual payment standardized and risk-adjusted Part A and Part B costs, does not include Part D costs) Total per capita costs for beneficiaries with four chronic conditions: COPD, Heart Failure, Coronary Artery Disease, Diabetes

Same as 2015 and: Medicare Spending Per Beneficiary measure (includes Part A and B costs during the 3 days before and 30 days after an inpatient hospitalization)

Benchmarks Group Comparison Specialty Adjusted Group Cost

Quality Tiering Optional Mandatory Groups of 10-99 EPs receive only the upward (or neutral) adjustment, no downward adjustment. Groups of 100+ both the upward and downward adjustment apply (or neutral adjustment).

Payment at Risk

-1.0% -2.0%

Value Modifier Policies for 2015 & 2016

Groups with 10+ EPs may select one of the following PQRS GPRO quality reporting mechanisms and meet the criteria for the CY 2016 PQRS payment adjustment to avoid the 2.0% VM adjustment

Reporting Quality Data at the Group Level

PQRS Reporting Mechanism Type of Measure

1. GPRO Web interface (Groups of 25+ EPs)

Measures focus on preventive care and care for chronic diseases (aligns with the Shared Savings Program)

2. GPRO using CMS-qualified registries Groups select the quality measures that they will report through a PQRS-qualified registry.

3. GPRO using EHR Quality measures data extracted from a qualified EHR product for a subset of proposed 2014 Physician Quality Reporting System quality measures.

If a group does not seek to report quality measures as a group, CMS will calculate a group quality score if at least 50 percent of the eligible professionals within the group report measures individually. At least 50% of EPs must successfully avoid the 2016 PQRS

payment adjustment EPs may report on measures available to individual EPs via the

following reporting mechanisms: Claims CMS Qualified Registries EHR Clinical Data Registries (new for CY 2014)

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Reporting Quality Data at the Individual Level – 50% Threshold Option

Two-step process: • CMS will query the Provider Enrollment, Chain, and

Ownership System (PECOS) to identify groups of physicians with 10 or more EPs as of October 15, 2014

Generates a list of potential groups that could be subject to the VM

• CMS will analyze claims for services furnished during the CY 2014 performance year through at least February 28, 2015

Remove groups from the October 15 PECOS list that did not have 10 or more EPs that billed under the group’s TIN during 2014

Groups will NOT be added to the October 15 PECOS list

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How Does CMS Determine Whether a Group of Physicians Has 10 or More EPs?

Measures reported through the GPRO PQRS reporting mechanism selected by the group OR individual measures reported by at least 50% of the eligible professionals within the group (50% threshold option)

Three outcome measures: All Cause Readmission Composite of Acute Prevention Quality Indicators (bacterial pneumonia, urinary

tract infection, dehydration) Composite of Chronic Prevention Quality Indicators (COPD, heart failure, diabetes)

PQRS CAHPS Measures for 2014 (Optional) Patient Experience of Care measures For groups of 25 or more eligible professionals

Required for groups of 100+ EPS reporting via Web Interface

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What Quality Measures will be Used for Quality Tiering?

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Total per capita costs measures (Parts A & B)

Total per capita costs for beneficiaries with 4 chronic conditions: Chronic Obstructive Pulmonary Disease (COPD)

Heart Failure

Coronary Artery Disease

Diabetes

Medicare Spending Per Beneficiary (MSPB) measure (3 days prior and 30 days after an inpatient hospitalization) attributed to the group providing the plurality of Part B services during the hospitalization

All cost measures are payment standardized and risk adjusted.

Each group’s cost measures adjusted for specialty mix of the EPs in the group.

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What Cost Measures will be used for Quality-Tiering?

5 Total Per Capita Cost Measures Identify all beneficiaries who have had at least one primary care service

rendered by a physician in the group.

Followed by a two-step assignment process 1. assign beneficiaries who have had a plurality of primary care services (allowed

charges) rendered by primary care physicians. 2. for beneficiaries that remain unassigned, assign beneficiaries who have received a

plurality of primary care services (allowed charges) rendered by any eligible professional

MSPB measure – attribute the hospitalization to the group of physicians providing the plurality of Part B services during the inpatient hospitalization

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Cost Measure Attribution

Each group receives two composite scores (quality and cost)

CMS uses the following steps to create each composite: Create a standardized score for each measure

(performance rate – benchmark / standard deviation) Equally weight each measure’s standardized score

within each domain. Equally weight each domain’s score into the composite

score.

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How Does CMS Use the Quality and Cost Measures to Create a Value Modifier Payment Adjustment

Use domains to combine each quality measure into a quality composite and each cost measure into a cost composite

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Quality-Tiering Methodology

Clinical Care

Patient Experience

Population/Community

Health

Patient Safety

Care Coordination

Efficiency

Total per capita costs

(plus MSPB)

Total per capita costs

for beneficiaries with

specific conditions

Quality of

Care

Composite

Score

Cost

Composite

Score

VALUE

MODIFIER

AMOUNT

Each group receives two composite scores (quality of care; cost of care), based on the group’s standardized performance (e.g., how far away from the national mean).

Group cost measures are adjusted for specialty composition of the group

This approach identifies statistically significant outliers and assigns them to their respective cost and quality tiers.

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Quality-Tiering Approach for 2016 (Based on 2014 PQRS Performance)

Low cost Average cost High cost

High quality +2.0x* +1.0x* +0.0%

Average quality +1.0x* +0.0% -1.0%

Low quality +0.0% -1.0% -2.0%

Eligible for an additional +1.0x if reporting clinical data for quality measures

and average beneficiary risk score in the top 25 percent of all beneficiary risk

scores.

VM for CY 2016 will be applied to Medicare paid amounts to items and services billed under the Physician Fee Schedule at the TIN level

• Beneficiary cost-sharing not affected

Applied to the items and services billed by physicians under the TIN, but not to other eligible professionals

If physician changes from TIN (A) in performance year (CY 2014) to TIN (B) in payment adjustment year (CY2016), VM would be applied to TIN (B) for physician’s items and services billed under TIN (B) during CY 2016

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Downward VM Payment Adjustment in 2016

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PQRS Participation in 2014 for Individuals and Groups of 2-9 EPs

Individual EPs and

Groups of 2-9 EPs

Did EP or group meet 2014 PQRS

incentive criteria?

Yes No

All EPs earn 0.5% PQRS

incentive (additional 0.5%

available for successful MOC

participation for eligible

physicians); ALSO avoids

2016 PQRS payment

adjustment

Did EP or group meet criteria to avoid

2016 PQRS payment adjustment?

Yes No

You will avoid the 2016

PQRS payment adjustment

All EPs will be

subject to the 2016

PQRS payment

adjustment of -2.0% EPs and Groups of 2-9 EPs are not subject to the Value

Modifier in 2016 (will be subject in 2017, based on

PQRS participation)

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How Does PQRS Participation Affect the Value Modifier?

Groups 10+ EPs

Do you plan to report for PQRS in 2014? Yes No

Does the group plan to report PQRS

as a group?

No

Does group meet

50% threshold?

All EPs in group will

be subject to the 2016

PQRS payment

adjustment of -2.0%

All physicians in

group will be subject

to the 2016 Value

Modifier downward

adjustment of -2.0%

Yes

Does group plan to meet 2014

PQRS incentive criteria?

All EPs earn 0.5% PQRS

incentive (additional

0.5% available for

successful MOC

participation for eligible

physicians); ALSO

avoids 2016 PQRS

payment adjustment

Yes

Does group plan to meet

criteria to avoid 2016 PQRS

payment adjustment?

No

No Yes

Group will avoid the

2016 PQRS payment

adjustment

Physicians in Groups of 10-99 EPs: Subject to upward or neutral VM adjustment

Physicians in Groups of 100+ EPs: Subject to upward, neutral or downward VM adjustment

No Yes

At least 50% of Individual EPs

in group report satisfactorily

and meet the criteria to avoid

2016 PQRS payment

adjustment .

Source: CMS.gov

Know where previous improper payments have been found

Know if you are submitting claims with improper payments

Be prepare to respond to medical record requests

Conduct audits: self, internal, and external

What can a provider do to prepare to an audit?

Authorship integrity risk: Borrowing record entries from another source or author and representing or displaying past as current documentation, and sometimes misrepresenting or inflating the nature and intensity of services provided

Auditing integrity risk: Inadequate auditing functions that make it impossible to detect when an entry was modified or borrowed from another source and misrepresented as an original entry by an authorized user

EHR Challenges to Coding and Auditing

Documentation integrity risk: Automated insertion of clinical data and visit documentation, using templates or similar tools with predetermined documentation components with uncontrolled and uncertain clinical relevance

Patient identification and demographic data risks: Automated demographic or registration entries generating incorrect patient identification, leading to patient safety and quality of care issues, as well as enabling fraudulent activity involving patient identity theft or providing unjustified care for profit

EHR Challenges to Coding and Auditing

Two varieties: Word (Ctrl C) Computer generated

Concern: Copying and pasting is not noncompliant. It is how the

information is used or “counted.” Medicare is also concerned that the provider's computerized

documentation program defaults to a more extensive history and physical examination than is typically medically necessary to perform, and does not differentiate new findings and changes in a patient's condition.”

EHR Challenges to Coding and Auditing

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Changing provider names on claims

Changing DOS on claims

Adjustments

False Claims

‘Chain of Command’ for detected offenses

A/R Staff’s Role in Regulatory Compliance

Steps: 1. Audit Preparation 2. Identify Audit Objective 3. Determine the Sample 4. Develop/Select Audit Tools 5. What to Look For 6. Complete Review Analysis & Summary Report 7. Meet with Providers 8. Develop an Education Plan 9. Develop a Monitoring Process

How to Initiate a Self-Audit

Decide who will perform the audit (self-audit, internal, external)

Decide where the audit will be performed

Decide focus of audit (documentation, CPT, ICD-9, HCPCS, or combination)

Will the audit be done pre-payment or post-payment?

1) Audit Preparation

Educate

Benchmark

Investigate a suspicious pattern

Government mandate under CIA

Determine provider bonus

Identify missed charges

Detect unbundling

Global periods

2) Identify Audit Objective

For a routine audit, review of 10 records per provider is recommended

No fewer than 5 records is recommended

For a probe review of an identified problem, 20-40 records should be reviewed

For a follow-up audit, 5-10 records (90% score)

Recommended time period is the most recent 3-6 months of service

3) Determine the Sample

Audit Tool

Service specific tool (office, hospital)

Specialty specific tool (ENT, Neurology)

Surgery audit tool

Electronic audit tool and software

Other Tools

Frequency report by physician

Benchmarking utilization based on specialty

4) Develop/Select Audit Tools

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Proper recording of time

Special guidelines followed (incident to, academic practice, global period)

Documentation is legible

Doctor’s orders are present for all tests documents

All diagnosis billed are on record

Correct provider

Correct DOS

5) What to Look For

Analyze raw data

Research guidelines as necessary

Include source documents as needed

Calculate an error rate, accuracy rate, compliance rate

Prepare a report listing each encounter reviewed, correct and incorrect coding, comments, recommendations

6) Complete Review Analysis & Summary Report

Review the provider’s individual results and recommendations for improvement, preferably one-on-one

Provide feedback, ask questions, educate, answer questions, review source documents (back-up your facts!)

Make any agreed upon changes to the final report based on insight form the provider

7) Meet with Providers

Should be based on problem areas identified in the audits Develop tools to assist in correct coding Cheat sheets Templates Coding tool Shadowing

Develop a training program

8) Develop an Education Plan

Frequency: quarterly, semiannually, or annual

Annually for an external audit of internal auditor to insure that his/her findings are objective

Based on achievement of a set accuracy score

Immediately upon discovery of a serious coding issue providing a compliance risk

9) Develop a Monitoring Process

Paul Chandler, BS-HRM, AA-C

CPC, CPC-I, CPC-H, CPC-P, CPMA, CPCO, CPPM, CPB, CANPC, CCC, CCVTC, CEDC, CEMC, CFPC, CGSC, CGIC, CHONC, CIMC, COBGC, COSC, CPCD, CPEDC, CPRC, CRHC, CUC

Ohana Healthcare LLC 134 Enchanted Parkway

Suite 204

Manchester, MO 63021

Office: 855.OHANA.66 (855.642.6266)

[emailprotected] www.ohanacoding.com

Questions?

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