Wednesday, August 7, 2013

Accuchecker Bulletin for August 07, 2013


HPP – Accuchecker

Health Plans Path, Corp

ACK Bulletin

 

Provider Operations                                                                                                                                                                            hppaccuchecker@gmail.com                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                            

07/August/2013

 

 

Reporting place of service (POS) codes

Physicians are required to report the place of service (POS) on all health insurance claims they submit to Medicare Part B contractors. The POS code is used to identify where the procedure is furnished. Physicians are paid for services according to the Medicare physician fee schedule. This schedule is based on a payment system that includes three major categories, which drive the reimbursement for physician services:

• Practice expense

• Physician work

• Malpractice insurance

 

It is important to know that practice expense reflects the overhead costs involved when providing a service.

To account for the increased practice expense physicians incur by performing services in their offices, Medicare reimburses physicians a higher amount for services performed in their offices (POS code 11) than in an outpatient hospital (POS 22-23) or an ambulatory surgical center (ASC) (POS 24).

Therefore, it is important to know the POS also plays a factor in the reimbursement.

The POS code is entered in the 2400 Place of Service Code loop (segment SV105) of the 837P electronic claim (Item 24B on the CMS-1500 paper claim form). This is a required field. Always ensure you are using the correct POS code to identify the service location for each item used or service performed and billed on the claim.

Medicare claim completion instructions specifically state that each provider or practitioner is responsible for becoming familiar with Medicare coverage and billing requirements. Some physician offices submit their own claims to Medicare contractors; other offices hire billing services to submit their claims. Physicians are responsible for all Medicare payments generated to them, regardless of claim submission choice (electronic or paper).

All carriers are stressing to physicians and their billing agents the importance of reporting the correct POS code. For example, billing physician's office (POS 11) for a minor surgical procedure that is actually performed in a hospital outpatient department (POS 22) and collecting a higher payment is inappropriate billing and may be viewed as program abuse.

It is imperative that you have internal control systems in place to prevent Medicare billings with incorrect place of service codes.

 

 

ELECTROCARDIOGRAM (ECG OR EKG)

Payment for electrocardiograms as indicated below.

Electrocardiograms are indicated in the evaluation of disorders of cardiac rhythm, anatomy,

coronary blood flow, myocardial function; of symptoms related to such disorders; as an adjunct in the assessment of certain drug toxicities and metabolic disorders.

 

However, there are no data that show that routine EKGs performed as a screen for coronary

heart disease (CHD) during a preventive visit, or during an office visit when there are no

cardiovascular symptoms, is of benefit. The United States Preventative Services Task Force has

studied this issue, and recommends against routine screening with resting EKG in adults at low

risk for coronary heart disease (CHD) events. The USPSTF found at least fair evidence that a

routine screening EKG for this population is ineffective or that harms outweigh benefits. The

USPSTF states that the consequences of false-positive tests may potentially outweigh the

benefits of screening. False positive tests are common among asymptomatic adults, especially

women, and may lead to unnecessary diagnostic testing, over-treatment, and labeling.

 

The USPSTF found at least fair evidence that EKG can detect some asymptomatic adults at

increased risk for CHD independent of conventional CHD risk factors. The USPTF concluded that there was insufficient evidence to recommend for or against routine screening with EKG in adults at increased risk for CHD events.

 

Major independent risk factors for CHD are (1) Cigarette smoking (2) Elevated blood pressure (3) Elevated serum total (and LDL) cholesterol (4) Low serum HDL cholesterol (5) Diabetes mellitus, and (6) Advancing age. According to the risk stratification data, the presence of advanced or advancing age alone, without at least one of the Major independent risk factors, does not take a patient out of the low risk category. Therefore, a Member, at any age, without symptoms or a diagnosis reflecting one of the 6 risk factors listed above, will be in a low risk category. Codes for all of these risk factors are found in the list of ICD9 diagnostic codes below.

 

Patients who have no cardiac symptoms or history of cardiac events, but with a family history of premature cardiovascular disease (first-degree relative with an event earlier than age 55) should have an appropriate cardiovascular work-up. Testing should include evaluation of all cardiac risk factors. A resting EKG alone is not an adequate evaluation for such a patient. Depending on the results of a resting EKG, coronary artery evaluation is done by a standard treadmill stress test, a nuclear perfusion imaged stress test, or a stress echocardiogram test.

 

Patients with a family history of premature cardiovascular disease, who also have either cardiac

symptoms or the presence of one independent risk factor other than age (placing them in the

intermediate or high-risk group), will have the EKG reimbursed when coded with the risk factor or symptom that they have.

 

Those patients with a family history of premature cardiovascular disease, with no symptoms,

and no independent risk factors, other than age, who are therefore in the low-risk group according to the Framingham criteria, will have an EKG reimbursed under the following circumstances:

 

If used to determine which type of stress test a patient should undergo, a resting EKG will be

reimbursed with a family history of premature cardiovascular disease.

There is no ICD 9 code specific for a family history of pre-mature cardiovascular disease.

Providers should code the EKG with the diagnostic ICD 9 code of V17.3, Family history of

ischemic heart disease, or V17.49, Family history of other cardiovascular diseases. EKGs for

Patients with these diagnoses will be reimbursed assuming that the appropriate stress test is

performed within four (4) months.

 

Furthermore, CMS has a non-coverage policy for a routine screening EKG:

 

ICD-10 Codes (Preview Draft)

 

In preparation for the transition from ICD-9 to ICD-10 medical coding on October 1, 2014, a

sample listing of the ICD-10 CM and/or ICD-10 PCS codes associated with this policy has been

provided below for your reference. This list of codes may not be all inclusive and will be updated

by Accuchecker to reflect any applicable revisions to the ICD-10 code set and/or clinical guidelines outlined in this policy.

 

Diagnosis Code (Effective 10/01/14) and Description


FOR LISTING OF DIAGNOSIS - CONTACT Accuchecker Support at:

hppaccuchecker@gmail.com





Other News:                          {Updates from CMS}

 

 

Final ICD-9-CM Code Set Update

CMS announces the final updates to ICD-9-CM codes will take effect on October 1, 2013. These updates will be in effect until the ICD-10 transition takes place on October 1, 2014.

 

 

CMS imposes first Affordable Care Act enrollment moratoria to combat fraud

Agency targets high-fraud areas while ensuring patient access to care

Building on strong anti-fraud efforts already underway, Centers for Medicare & Medicaid Services’ (CMS) Administrator Marilyn Tavenner today announced temporary moratoria on the enrollment of new home health provider and ambulance supplier enrollments in Medicare, Medicaid and the Children’s Health Insurance Program (CHIP) in three fraud “hot spot” areas of the country.   The goal of the temporary moratoria is to fight fraud and safeguard taxpayer dollars, while ensuring patient access to care.  Authority to impose such moratoria was included in the Affordable Care Act, and CMS is exercising this authority for the first time.

Under the moratoria, existing providers and suppliers can continue to deliver and bill for services, but no new provider and supplier applications will be approved in these areas for all three programs.  The temporary enrollment moratoria apply to newly-enrolling home health agencies in the Miami and Chicago metropolitan areas; and newly-enrolling ground ambulance suppliers in the Houston metropolitan area (see list of affected counties below).  CMS announced the temporary, six-month moratoria in a notice issued today in the Federal Register.

“CMS is using all available tools, including these moratoria, to combat fraud, waste and abuse in these vital health care programs,” said Administrator Tavenner.  “While maintaining patients’ access to care, we are putting would-be fraudsters on notice that we will find and stop them before they can attempt to bill Medicare, Medicaid and CHIP.”

CMS carefully examined Medicare beneficiary access to home health and ambulance services in the Miami, Chicago and Houston areas, and concluded that the moratoria will not affect access to care. The agency also worked closely with the states of Florida, Illinois and Texas to evaluate patient access to care, and these states reported that Medicaid and CHIP beneficiaries will continue to have access to services.  During the moratoria period, CMS and states will continuously monitor access to care to ensure Medicare, Medicaid and CHIP beneficiaries are receiving the services they need.

In consultation with the Health and Human Services Office of Inspector General and the Department of Justice, CMS reported that fraud trends warranted a moratorium on home health providers and ambulance suppliers in three geographic areas.  CMS also reviewed key factors which are indicators of potential fraud risk including a disproportionate number of providers and suppliers relative to beneficiaries, a rapid increase in enrollment applications from providers and suppliers, and extremely high utilization.  All three areas ranked near the top across the nation on all of these fraud risk factors.  Federal law enforcement agencies have also pursued and prosecuted a large number of cases of health care fraud in these areas. CMS is working with its partners to monitor the impact of the moratoria, such as the anticipated movement of fraud schemes to different services or geographic areas.

 

 

The moratoria begin Tuesday, July 30.  CMS may lift the moratoria earlier or extend it another six months by issuing another notice in the Federal Register. The affected counties in each of the three metropolitan areas are:

·         Miami:   Miami-Dade and Monroe

·         Chicago:  Cook, DuPage, Kane, Lake, McHenry and Will

·         Houston:  Brazoria, Chambers, Fort Bend, Galveston, Harris, Liberty, Montgomery and Waller

The Affordable Care Act has enabled CMS to expand efforts to prevent and fight fraud, waste and abuse.  Over the last four years, the Obama administration has recovered over $14.9 billion in healthcare fraud judgments, settlements, and administrative impositions, including record recoveries in 2011 and 2012. 

In addition, CMS has revoked 14,663 providers and suppliers’ ability to bill in the Medicare program since March 2011. These providers were removed from the program for a variety of reasons, such as felony convictions, not being in operation at the address CMS had on file, or otherwise not being in compliance with CMS rules.  In 18 states, the number of revocations has quadrupled since CMS put the Affordable Care Act screening and review requirements in place.

 

Can plagiarism detection tools catch EHR upcoding?

 

Software that verifies the originality of written work is de rigueur in academic settings. Upon submission of a document, the tool quickly identifies original author, date, and color-codes portions of the submitted electronic document. Conceptually, the same software that detects when students submit a cut-and-paste class paper could also detect “cloning” within an individual’s electronic health record. 

Might academic detection software create an opportunity for both healthcare organizations and the government to determine if the record is original? 

Importance of detecting cloned records


On September 24, 2012 the Obama administration
provided a warning letter to CEO’s of various hospital and healthcare organizations, signed by the attorney general, Eric H. Holder Jr. and the secretary of health and human services, Kathleen Sebelius. The letter discussed suspicions that the electronic record capabilities of cloning assist some organizations in defrauding the government by way of upcoding evaluation and management (E/M) service codes.

 The American Health Information Management Association (AHIMA), February 13, 2013,testified to the  Hearing on Clinical Documentation on the issue of cloning/copy-paste practices: “Cloned documentation continues to be a significant problem in EHRs creating unnecessary redundancy and at time inaccurate information in the EHR. Many organizations have developed policies, but non-compliance remains an issue.”

Further testimony by Dougherty indicated some EHR systems are designed to facilitate cloning with options such as “make me the author” to assume the content of another person’s entry or “demo recall” to copy and forward vital signs. Default documentation populating fields on a template allow documentation to be generated indicating “all systems reviewed and normal” when all systems may not have been reviewed and results may not have been normal.

RAC audits, request for records, appeals


The Department of Health and Human Services (HHS) Office of Inspector General, (OIG) issued a report; that correlated an increase in higher-level CPT codes for evaluation and management services with those providers who also used an EHR at their primary practice location. As a direct response to the study, the Centers for Medicare and Medicaid Services, (CMS) alerted the American Medical Association (AMA) to begin conducting audits in 15 states, primarily in Region C, and others in  the near future.

Medical record submissions are required if a Recovery Audit Contractor (RAC), on behalf of CMS, requests them. The RAC Region B Medical Record Submission Instructions encourage providers to submit medical records via Electronic Submission of Medical Data (ESMD); however paper records, faxed, and medical records  submitted on a CD/DVD will be accepted. It is presumed that cloned entries can easily be detected upon audit when subjected to similarity detection software. Audits of paper records to detect “cut and paste” features, however, produce voluminous files that would be more difficult for auditors to challenge. Progression to the EHR, in combination with advanced software and data analytics, will make audits looking for cloned records potentially easier in the future. 

Cloned records can be a concern if the RAC auditor’s decision is challenged. Medicare providers and beneficiaries may appeal certain decisions related to claims for health care services and items. The Medicare Administrative Appeals Process involves four levels of appeals, with level one administered by the CMS Medicare Administrative Contractor, level two administered by CMS Qualified Independent Contractors, level three administered by Administrative Law Judges (ALJ’s), and level four administered by the Medicare Appeals Council. In a November 2012 report conducted by OIG, several ALJs explained that they decide against appellants if the evidence lacks credibility and they suspect fraud. One ALJ reported he denied claims because all the medical records look suspiciously similar.

How payment is determined


Physicians, qualified non-physician practitioners (NPP), outpatient facilities, and hospital outpatient departments report CPT codes to bill for E/M services furnished in an encounter. ICD-9-CM diagnosis and procedure codes are limited to billing for inpatient E/M services on inpatient claims. Payment based on E/M codes considers patient type, setting of service, and level of service performed. According to CMS 2010
 E & M Service Guide three (3) key components — history, examination, and medical decision-making —assist in determining the proper level of service performed and thereby proper payment.  Thus, reimbursement is tied to the complexity of the provider’s assessment.

 AHIMA members report commonly finding cloned documentation in the following types of content: history and physical (particularly social, medical and family history), visit/clinic notes, and inpatient progress notes, consults, vital signs, and review of systems / physical exam.) Alignment of increases in cloning detection with criteria that determines proper level of service performed provides support for government suspicion that cloning of records appears to align with potential upcoming.   

OIG work plan 2013


Since the publication of the September 24, 2012 letter, OIG has identified the “identical documentation across services” and “identify fraud and abuse vulnerabilities in the EHR systems” in its Work Plan for 2013
.

From part 1: Medicare Part A and B; Evaluation and Management Services — Potentially Inappropriate Payments in 2010, OIG specifically notes, “We will determine the extent to which CMS made potentially inappropriate payments for services in 2010 and the consistency of medical review determinations. We will also review multiple services for the same providers and beneficiaries to identify electronic health records (EHR) documentation practices associated with potentially improper payments. Medicare contractors have noted an increased frequency of medical records with identical documentation across services.”

Presented by Electronic Health Records, “We will identify fraud and abuse vulnerabilities in electronic health records (EHR) systems as articulated in literature and by experts and determine how certified EHR systems address these From part VII: Other HHS-Related Reviews; Fraud Vulnerabilities.”

 

 

 

Current tools to detect fraud and abuse


HHS and the Department of Justice published the Health Care Fraud and Abuse Control Program Annual Report for Fiscal Year 2012 describing several database and data analytical and mining tools being utilized to uncover fraudulent billing such as the Fraud Prevention System, One Program Integrity, the Next Generation Desktop, SAS statistical programming software, CMS Integrated Data Repository (IDR) and the Command Center.

If the same plagiarism detection software is not currently used by auditors, we can anticipate that it will be soon.

 

 

ALERTS

 

 

The Centers for Medicare & Medicaid Services (CMS) issues the “Medicare Quarterly Provider Compliance Newsletter,” an educational product, to help providers understand the major findings identified by Medicare Administrative Contractors (MACs), Recovery Auditors, Program Safeguard Contractors, Zone Program Integrity Contractors, the Comprehensive Error Rate Testing (CERT) review contractor and other governmental organizations, such as the Office of Inspector General.

 

The following findings are being alerted to providers. Understanding the correct way to bill will avoid:

 

Ø  DENIALS

Ø  AUDITS

Ø  OVERPAYMENTS

 

 

 

Recovery Audit Finding: Pulmonary Procedures and Evaluation & Management Services

Provider Types Affected: Physicians and non-physician practitioners

 

Recovery Audit Finding: Cataract Removal, Part B Number of Units Incorrectly Billed

Provider Types Affected: Physicians and Non Physician Practitioners (NPP)

 

Recovery Audit Finding: Mohs Surgery Pathology Billed by Separate Provider

Provider Types Affected: Physicians

 

Recovery Audit Finding: Dose versus Units Billed - Bevacizumab (HCPCS J9035) and Rituximab (HCPCS J9310)

Provider Types Affected: Hospitals and Physicians

 

Recovery Audit Finding: Pre-admission Diagnostic Testing Review

Provider Types Affected: Inpatient Hospitals

 

 

 

 

 

For more information, on any of the articles posted in this bulletin, please contact Accuchecker


 

Subject:  please indicate   ACK BULLETIN INFO

 

 

 

 

 

 

Paul G. Silverio-Benet

Director of Operations

HPP – Accuchecker

Phone: 305-227-2383

Toll Free: 1-877-938-9311
Fax: 786-364-7356