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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
5
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
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
9
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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?