To view this newsletter online go to http://www.codingandreimbursement.net/Newsletter/issue200621.html
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| Issue #21 | June 1 , 2006 |
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Coding &
Reimbursement Network News |
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It's hard to believe we have put out 21 issues of the newsletter since last August. Here are a few fun statistics.
So do continue to tell your friends about the CRN! The more we network the more collective wisdom we have to do our jobs effectively, efficiently and compliantly. I do appreciate you as a member and hope you enjoy this issue. Until next time! --Laureen = )
For this week’s article, I thought I would demonstrate the vast variety of questions that come up daily on the list serve. So, for all those who don’t know if the list serve is right for your area, take a look at the last few weeks of subjects.
The list goes on and on. The subject that I thought to highlight this month dealt with Overpayments. The discussion was lively and extremely informative. I love how much I learn from this list! The overpayment question was interesting. In summary, can an office set a limit on how small a refund should be when sending it back to an insurance (if self discovered)? Does this dollar amount have to be an across the board decision? One lister suggested returning any and all money but ask the payer to make the request. Some payers won’t bother with the small dollars. But, sending a payer money without getting a “request for refund” letter may send that money into the abyss. Another comment was to make certain to refund all government payers as quickly as possible. There are also Escheat laws that need to be adhered to when dealing with the state funded programs. In Washington state, it was suggested to make certain that if the payer was Medicaid, have them ask for the money (there’s a form you can complete for this request) as it often gets improperly applied. Premera doesn’t request refunds less than $25, as mentioned by another lister. This discussion spawned another overpayment question. What if the physician’s office owes the patient a refund? Shouldn’t this also be refunded in a prompt manner. The accounting department seems to think that only if the patient complains does it need refunded. One lister provider a nice book reference to take back to that accounting department. Essentially, returning credit balances in a timely fashion is just one component of an efficient compliance program. Yet another poster gave a website to check the state laws http://www.auditservicesltd.com/uplaws/. Continuing, someone else made mention that if the money isn’t going to the patient, it should go to the state. Again, the Escheat laws of the state could govern these refunds. Most insurance contracts have clauses that indicate how to properly refund their patients when overpayments occur. If you’d like to read the entire chain on this one, you could start at http://health.groups.yahoo.com/group/CRN-L/message/53443. As always, see you on the list and in the meantime… Joining the list serve: $0 Until next time, --Suzan
CPT Basics and Laws Go back for a moment to when you were a kid. Go back to a time when you did something that got you in a whole lot of trouble. Even if your parents say you were a perfect child, I bet you can find at least one moment when your friends or siblings looked at you with raised eye brows and said, “Ooooo, you’re gonna be in trouble.” I don’t know what was more irritating, the fact that you had already deduced such a fact and really didn’t need them to tell you, or the way they put that extra emphasis on the word “trouble”. Does it take a minute or is there one specific memory that pops right up? Remember facing Mom and Dad and getting that look, the one that said “talking your way out of this is not an option?” There are similar rules when it comes to coding and choosing not to follow them can also lead to similar circumstances. I don’t know about you, but I would rather face my Mom and Dad again than have two men in black standing on my door saying, “Ooooo, you’re gonna be in trouble.” Ignorance is NOT Bliss - If there is one thing our friendly Inspector General makes very clear for all persons working in the medical field (among others) is that ignorance of the “rules” is not an excuse. There are very specific laws, guidelines, rules and downright simple facts governing every aspect of this field and our governments say, quite clearly actually, each one of us has the responsibility to know them and follow them. All of these laws, guidelines, rules and simple facts have been provided and are accessible, most for free on state and federal websites or by calling them. If you chose to be ignorant of these rules, you may just find yourself staring at another scary person who won’t just give you “that look.” They’ll be more than happy to tell you “talking your way of this one is not an option.” What’s Up Doc – Physicians have many guidelines to follow such as writing legibly. A coder, biller or practice manager may take the time to decipher the physician’s chicken scratch, but an auditor absolutely will not. Why you ask? The answer is simple, because they don’t have to. One of the first rules for reporting medical services is one I’m sure you’re familiar with; “if it’s not dictated or legible, it’s considered not done.” I’ve worked with doctors who handwriting resembled something more akin to an EKG read-out than official medical documentation. If you are uncomfortable telling your physician to clean up his writing, get over it. If you’re a physician who wouldn’t dream of having their coder telling them to clean up your writing, like Cher so aptly told Nicholas Cage in “Moonstruck”, “SNAP OUT OF IT.” The other basic rule for physicians is everything they bill for must be documented in detail according to the coding requirements for that particular service and each date of service must stand alone. There are a slew of guidelines for the physicians to follow, these are just a couple, and it’s the guidelines applicable to coding we want to take a closer look at. The physician is ultimately responsible for every code billed out under his name. Back to Basics – There is a great deal of responsibility on the part of anyone working with CPT, ICD-9-CM and HCPCS codes to understand the appropriate coding and reporting guidelines. Furthermore it’s a greater responsibility to follow these guidelines. Coding is much more than picking up the appropriate coding manual, finding a code, putting it on a claim form and sending it away for payment. The first and most important rule of coding and reporting is to stay up-to-date on coding changes. Each and every hospital, clinic, surgery center, insurance company, ambulance service, medical equipment provider or medical practice is required by law to obtain and use the most up-to-date coding manuals. You must update and implement them every year. Often the most common coding mistakes are made simply because the person choosing and applying the code has failed to read the guidelines already provided in their coding manuals. Experienced coders, auditors, practice managers and even some physicians are diligent at knowing the basics. If this information is nothing new to you, then I applaud you. Unfortunately there are many of these same people, flying by the seat of their pants. In this article we will take a look at some of the basic but all too important guidelines printed in black and white, right in our CPT. Pick a code, any code – As mentioned a moment ago, it’s not sufficient enough to choose just any code for reporting. I’m not talking about using a total hysterectomy code for reporting a colectomy. What I’m referring to are those times when you went looking for a code and found one that seemed “pretty close” to the service performed and stuck in on a claim. If you turn to the first few pages of the CPT manual (the ones you always skip over and are often in print condition at the end of the year), you will find a page labeled “Introduction”. On this page under the heading in red “Instructions for use of the CPT Codebook” you will find probably the most important information for using this book correctly. The first paragraph of this section states, “Select the name of the procedure or service that accurately identified the service performed. Do not select a CPT code that merely approximates the service provided.” In other words, close doesn’t count. The code reported must be a clear and concise representation of the total service performed. Just because something walks like a duck and quacks like a duck does it necessarily mean it’s a duck? Hey, the Ugly Duckling did all that and he turned out to be a swan. When there is no code to accurately report the service provided, CPT goes on to instruct the coder to report the service using an unlisted procedure code from the appropriate section of the CPT book. When an unlisted code is used, the claim should be dropped to a paper with a brief description of the procedure listed in box 19 on the claim form. A copy of the report or documentation should be sent along with the claim and an appropriate fee should be charge. The fee should be “fair and customary” as also required by federal guidelines. Unlisted procedures may often be performed alongside or in addition to valid CPT codes, in which both should be submitted separately. If the service you are reporting is accurately described in a CPT code but that same CPT code includes extra or additional services not performed, it would be appropriate to report the code for the services performed. To accurately show the service was reduced from the complete procedure described in the CPT code (not all parts of the procedure were performed), modifier -52 (reduced service) is appended to the CPT code prior to billing. Oh and by the way, that’s not an option either. Three is a magic number – Now that you understand when to use unlisted procedure codes there is one more thing to clear up. CPT codes have a type of hierarchy to them I guess you could say. When looking for the appropriate CPT code for the service performed there is an order that must be followed. When you are looking for a particular CPT code, the first place to look is in the already established CPT codes provided, known as Category I. This refers to those that have a description and established relative value attached to them. If, as in our example explained above, there is not a Category I CPT code to accurately report the service, there is one other place to look before turning to an unlisted procedure code. Near the end of the CPT manual, directly after the Medicine Section, you will find the Category III Code section. The codes in this chapter look different from the rest of the CPT. They start with one or two “0’s” and end in a “T”. Like Category I CPT codes they have specific descriptions attached to them. The difference between the two types of codes is Category III codes do not have a relative value attached to them. They are temporary codes and they very much resemble a temporary employee. They aren’t salaried yet and may or may not become permanent based on their performance. These codes represent emerging technology, services and procedures. These codes help facilitate the gathering of data for these services which in turn is used to determine if the service warrants becoming a permanent CPT code, what that code will entail and what the fee or RVU for the code will be. The life span of codes in this section can be as short as a year or may stay here for several years in order to gather enough data. The complete description and life span of these codes is described in detail in the last paragraph of the guidelines found at the beginning of the section. We want to concentrate on one specific sentence of this section which is found in the first paragraph. This sentence states “if a Category III code is available, this code must be reported instead of a Category I unlisted code”. For example, the physician performed an insertion of a temporary prostatic urethral stent. In 2006 there is not a code already established in the CPT for this service. However Category III code, 0084T, is available to report this specific procedure. Instead of billing 53899 for an unlisted urinary procedure, the coder is required to use the 0084T code. Since no value has been placed on these services, payment modifiers such as 52, 53, or 22 are not necessary for Category III codes. Instead the physician attaches a fair market price to the procedure, adjusts the fee based on the extent of the service performed and may send the claim electronically. There is no getting around this guideline. Like the other rules we have learned, this also, is not an option. In conclusion – The guidelines, rules and laws governing our field can seem endless and daunting. However knowing the basics of coding can often become the cornerstone of billing practice. The stronger that cornerstone, the stronger the company will become and the longer it will stand. It’s not enough for one person in a practice to know the rules. The responsibility to adhere to these rules and communicate them falls to all entities involved in the reimbursement process. This includes the physicians, coders, charge entry clerks, managers, billers, account representative and even third party billing companies. No one is exempt and all are responsible. We have learned or revisited two of the basic rules of CPT coding. There are many more guidelines in each section of the CPT and the ICD-9. If you haven’t read them in a while or perhaps have never read them, put down that copy of “The DaVinci Code” and pick up a coding manual. The reading will be well worth it. Until next time coders... --Tara
TeleWebinar Update
Shared Document Collection Initiative: Vacation was terrific with my family. My daughters got to re-know their mother and my husband re-meet his wife after all the travel I have been doing. It seems that my coding colleagues have gotten to see me more often than my family; I think many of the readers of this newsletter understands this all too well. Now I have a month at home to look forward to for the month of May and then off to travel again in May also. So, we have some plans to record some new telewebinars in May to add to our library of continuing education for the CRN Community. Don’t forget the classes currently available, Employee Overtime-Is Your Practice At Compliance Risk? taught by Pati Trites. Many physician practices underestimate the risk involved in making a mistake in administering the wage/hour laws. One of the most common mistakes made is improperly classifying certain employees as exempt from the wage and hour laws and not paying overtime when it is required. What about work time while traveling and the overtime considerations. This has not only great impact on the practice’s operations, but on their compliance program. One of the key elements of a compliance program is your employee policy manual. Come listen to Pati speak on this very timely topic. She recorded this class on 3/14/06 and it is available now for download on the CRNShoppe at TW_EmpOtCompliance. I have the wonderful opportunity of listening to all of these classes when they are being recorded and I have to tell you that it was extremely informative and of a lot of use for a practice. Not only did Pati address overtime rules, but she also touched on issues such as employees versus independent contractors and how to determine if an employee qualifies for an independent contractor. As we have more and more employees telecommute, these are important issues to grapple with and address to make sure your organization is within compliance of federal and/or state guidelines. Pati provided the information and tools to evaluate the employee and the appropriate status under which they should be paid. The practice’s employee manual and handbook is an integral and key aspect of the practice’s compliance program, and thus, this is important in making sure your business is in compliance with employment laws. If you have not started your compliance program, starting here will be starting your compliance program with your compliance program. The second class that Pati Trites recorded for CRN Telewebinars was; Mandatory Compliance Programs Have Arrived. The Deficit Reduction Act of 2005 has made it mandatory to have a fraud and abuse compliance program by Jan 1, 2007. This applies to all entities that pay or receive at least $5 million in Medicaid funds. Are you ready? Find out how to comply with the law. Even if you are not a large practice, and required by law, there are a lot of small things you can do to start your compliance pathway. Compliance is not only a good idea from a regulatory point of view, but history has proven that good compliance is actually an excellent aspect in cost control, increased patient outcomes, patient satisfaction and increased employee satisfaction. Pati provides many practical tools for you as you either are starting to plan a new compliance program or you are reviewing your existing compliance program. This continues to be a very timely topic. This is about how do you get started and stay on track with your compliance activities; how to not have them overwhelm you, and how do they fit into your daily activities. Compliance is not just for the big operations and you can do it. This course is available on the CRN Shoppe to purchase the recording at TW_Compliance. Pati’s third class is near and dear to my heart. The class, Evaluating EMR/EHR Systems for Compliance? addresses an area of EMR/EHR evaluation that seems to be overlooked in many system reviews. This is so important as the more we travel down the HIPAA security road and as automatic encoders become more prevalent, there will be more and more pressure on practices to prove that their electronic systems comply with certain audit and compliance issues. These systems are very expensive and their implementation is often a very rocky road. A practice cannot afford to take this lightly and not consider the compliance related issues when evaluating these systems. This recording is available on the CRN Shoppe for purchase at TW_EMR-EHR. First, Pati taught Employee Overtime-Is Your Practice At Compliance Risk? Many physician practices underestimate the risk involved in making a mistake in administering the wage/hour laws. One of the most common mistakes made is improperly classifying certain employees as exempt from the wage and hour laws and not paying overtime when it is required. What about work time while traveling and the overtime considerations. This has not only great impact on the practice’s operations, but on their compliance program. One of the key elements of a compliance program is your employee policy manual. Come listen to Pati speak on this very timely topic. She recorded this class on 3/14/06 and it is available now for download on the CRNShoppe at TW_EmpOtCompliance. I have the wonderful opportunity of listening to all of these classes when they are being recorded and I have to tell you that it was extremely informative and of a lot of use for a practice. Not only did Pati address overtime rules, but she also touched on issues such as employees versus independent contractors and how to determine if an employee qualifies for an independent contractor. As we have more and more employees telecommute, these are important issues to grapple with and address to make sure your organization is within compliance of federal and/or state guidelines. Pati provided the information and tools to evaluate the employee and the appropriate status under which they should be paid. The practice’s employee manual and handbook is an integral and key aspect of the practice’s compliance program, and thus, this is important in making sure your business is in compliance with employment laws. If you have not started your compliance program, starting here will be starting your compliance program with your compliance program. The second class that Pati Trites recorded was; Mandatory Compliance Programs Have Arrived. The Deficit Reduction Act of 2005 has made it mandatory to have a fraud and abuse compliance program by Jan 1, 2007. This applies to all entities that pay or receive at least $5 million in Medicaid funds. Are you ready? Find out how to comply with the law. Even if you are not a large practice, there are a lot of small things you can do to start your compliance pathway. Pati provides many practical tools for you as you either are starting to plan a new compliance program or you are reviewing your existing compliance program. This continues to be a very timely topic. This is about how do you get started and stay on track with your compliance activities; how to not have them overwhelm you, and how do they fit into your daily activities. Compliance is not just for the big operations and you can do it. This course is available on the CRN Shoppe to purchase the recording at TW_Compliance. Pati’s third class is near and dear to my heart. The class, Evaluating EMR/EHR Systems for Compliance? addresses an area of EMR/EHR evaluation that seems to be overlooked in many system reviews. This is so important as the more we travel down the HIPAA security road and as automatic encoders become more prevalent, there will be more and more pressure on practices to prove that their electronic systems comply with certain audit and compliance issues. These systems are very expensive and their implementation is often a very rocky road. A practice cannot afford to take this lightly and not consider the compliance related issues when evaluating these systems. This recording is available on the CRN Shoppe for purchase at TW_EMR-EHR. Last of the most recent classes, but definitely not least, Deb Grider is doing another minicourse for CRN CE on Coding Consulting 101. I have seen the slides and it is a terrific class. A lot of us are aware of the confusion that surrounds the “clarification” that CMS created when they updated section 30.6.10 of the Claims Processing Manual (Chapter 29), and a lot of concern exists on how we operate within the parameters that CMS has placed on the physicians, the practices and the coders. Deb addresses the AMA definition of Consultations as well as the CMS Guidelines as defined and clarified in Chapter 29 of the Claims Processing Manual (section 30.6.10). Deb brings clarity where there was fog and has some great suggestions for systems and procedures in the practice. She also has suggestions for you to bring back to your physicians on how they document the requests for consultations when they are truly requests for opinions. Deb has audited many charts, in and outpatient and it is through that experience that she can bring understanding to this topic, as well as practical operating advice. To order this minicourse, go to TW_ConsultationCoding101. We have some other classes lined up for May as well. I received a few emails requesting classes on Neurosurgery. So, Voila, Eric Sandhusen is developing a two-part mini course series on Neurosurgery, part 1 on the spine and part II on the brain. We have also been requested to develop something on ASC’s. I have not started on that one, but I promise I will find the appropriate Subject Matter Expert (SME) for that topic. The point here is that a few people have emailed me with their needs and we have been able to be responsive with finding the right SME’s for those topics and got them scheduled. So, do not be afraid to email me at b.cobuzzi@att.net with our needs and I will look into whether we can get your needed topics scheduled. Do not forget to look on the CRN CE web site at www.crnshoppe.com/tw and see all the classes that are already there available for purchase. There are a few on auditing, on appeals, on modifiers, on E&M, on radiology, on marketing the independent billing company, on non-physician practitioners and more. Go to the web site and see our ever-growing library of continuing education and CEU opportunities. Put a group around the phone (and if you want, a computer, but it is not necessary) and you all can listen to the class together for one fee of $139. What better, cost effective way do you have to educate your office? This is about having great teachers and timely topics that are worth the time and effort to listen and learn! Get the word out to your colleagues about this great opportunity for education that can be used for compliance and CEU’s. We provide CEU’s from the AAPC, AMBA and HCR (Healthcare Compliance Resources). Stay tuned - this is just getting bigger and better and we are very excited to be bringing it to you. Remember, all you need is a phone to participate. Click here to check it out. Upcoming Events:
Upcoming Speakers - Dates to be set
Interested in becoming a speaker? E-mail me. Join our CEU Notification List to be notified when new topics are added. Join us on CRN CE as we experience the future of coding, compliance, billing and reimbursement education. Go to http://www.CRNShoppe.com/tw to purchase your TeleWebinars. Go to http://www.CRN-CE.com to explore the CRN Continuing Education site. Have a great 2 weeks until we chat again! --Barbara
Institute News
CRN Institute News Do you have a CRN Institute Student Success Story to share? Just drop an e-mail to pam@crn-institute.com. Let us know about your promotions, new jobs and new credentials or anything else you would like to share! If you need college credit E-mail Laureen about how to enroll at Drexel University even if you don't live anywhere near Philadelphia. New classes start in June. Classes are also held at Christina Healthcare in Delaware. E-mail Laureen if you are interested in joining this group. You might want to take a look at our self-study course in Pharmacology if you are planning on sitting for the CCS exam. Most of you are aware that we offer courses in Medical Billing, Physician Coding and Hospital Coding but were you aware that we also offer self-study courses in Pathophysiology and Pharmacology for only $199.00 each. Check back as we announce new courses now under development. Let us know what new courses you would like to see the CRN Institute offer. Don’t forget we offer payment plans $195.00 down and $100.00 a month. Congratulations to Marlene Moffett a Data Abstrator with ARMC for completing the 301 Physician Coding Course. What made you decide to take a course? I wanted to improve my skills. Why did you pick CRN Institute? Because I felt that that it was a good course to take through its reputation. What did you like best about the course? The course was in great detail of all the chapters. What did you like least about the course? The time factor but it was rewarded. Is there anything you would say to someone thinking about taking a course? The course is really a good way to get the knowledge needed to move forward. Are you planning on sitting for a Board exam? I might but I’m not sure when. Do you currently have any coding/medical credentials? RHIT If you are a CRN student and have recently gotten a new credential, job or have something exciting you want to share send it to me so you can be featured in our next issue. Until next time... --Pam CRN Member Highlight
Where are you from? What do you find most exciting about this field? What would you tell someone just starting out in this field? If there was one thing you could change about this field what would it be? Who do you consider a mentor? What is your favorite billing or coding product? What is your affiliation with the CRN and how has that helped you? If you are a CRN student and have recently gotten a new credential, job or have something exciting you want to share send it to me so you can be featured in our next issue. For 2006, BillFlash.com has a fresh new look to continue to provide you the product leadership and marketing support you need to create substantial recurring income. Current users will appreciate the following enhancements and have been notified of such:
The BIG NEWS is the site has been completely redesigned to help you sell more in the following ways:
Congratulations to our newest members of the $5k, $10k, and $20k commission levels and thank you to all who fueled BillFlash’s extraordinary growth in 2005. We look forward to working with you to achieve your goals for establishing recurring income in 2006.
TIP from CRNCodingToday.com: POINT>CLICK>CODE to view CPT section notes. Get it right! Use CRNCodingToday! It is fast! It is easy! It is correct! |
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