Additional Documentation Requests: Don't ignore them
Family physicians in the Medicare J5 MAC region states of KS, MO, NE, and IA providing inpatient care should be prepared to receive and promptly respond to letters from the WPS Medicare Medical Review Department. These will be related to prepayment review of claims for subsequent hospital visits submitted with code 99233. WPS notes that their Comprehensive Error Rate Testing (CERT) reviews of paid claims have shown a significant increase in errors on claims for these services by family physicians. If one of your claims is selected for review, WPS will send an Additional Documentation Request (ADR) for medical records for all dates of service billed with CPT code 99233.
Breathing a sigh of relief because you are not in one of the J5 MAC states? I can see that. No one wants their payments delayed and subjected to prepayment review and potential denial or down-coding. But if your Medicare CERT or one of the myriad other Medicare auditors isn’t looking at your inpatient hospital services, I would bet they are looking at some other evaluation and management (E/M) service that may have been inadequately documented or incorrectly coded. If post-payment review results in a high error rate, you too may find your payments delayed, reduced, or denied.
So what can you do to avoid problems?
First respond promptly and completely to all ADR letters. Many claims are denied and counted as errors due to lack of response to ADR's. See the information previously provided in this blog for details.
Second, be sure that documentation submitted is clear, complete, appropriately signed, and dated. Did you and your partner provide E/M services on the same date and bill the services according to Medicare rules as one E/M service? Will both notes be sent? If not, your 99233 visit may be down-coded to 99231 or 99232. A records request checklist can help your staff submit all of the information necessary to support your charges.
Are you using 99233 only when the patient is unstable or has developed a significant
complication or a significant new problem? If billing based on time, have you
documented counseling and coordination of care for at least half of a visit
(including hospital floor time) of 35 minutes or more?
Are you using 99233 only when the patient is unstable or has developed a significant complication or a significant new problem? If billing based on time, have you documented counseling and coordination of care for at least half of a visit (including hospital floor time) of 35 minutes or more?
Finally remember, code 99233 requires at least two of these three components:
• A detailed interval history – state progress or complications since last visit, if referring to previous history state date of previous history, chief complaint or reason for visit beyond “follow-up,” HPI (4 items or 3 conditions), ROS (2-9 systems), PFSH (none necessary);
• A detailed examination – Extended exam of problem system/areas plus others;
• Medical decision making of high complexity (2 of 3 elements, not risk alone) – established problem(s) worsening; new problems with or without further work-up; changes in treatment, nursing instructions, decisions for palliative care, tests and procedures ordered (note if urgent), tests reviewed and unexpected results, discussions with other physicians, risks of management and treatment.
It is complex and probably annoying but remember, it is necessary to show the work (talking, reviewing, thinking) that you did to support your charges. A 99233 service should not go unpaid due to lack of response to ADRs, unsigned records, or other documentation gaps.
EHR incentives and PQRS can work together
I have written before about the Medicare Physician Quality Reporting System (PQRS) and the advantages of the registry-based or electronic health record (EHR)-based reporting options. Though the incentive payment for successful reporting in 2012 will be only .5% of your total allowed charges for covered Medicare Part B services provided during the reporting period, there are other reasons to report.
First, those of you who are participating in the Medicare EHR incentive program may be able to satisfy the core requirements for reporting clinical quality measures (CQMs) through Medicare's Physician Quality Reporting System – Electronic Health Record (EHR) Incentive Pilot. Beginning in 2012, eligible professionals may satisfy the meaningful use objective to report the 44 CQMs to the Centers for Medicare & Medicaid Services (CMS) in two ways:
1. Using the Medicare and Medicaid EHR Incentive Programs’ web-based Registration and Attestation System, or
2. Participating in the Physician Quality Reporting System – Medicare EHR Incentive Pilot, which utilizes the 2012 Physician Quality Reporting System EHR Measure Specifications.
By submitting specific Physician Quality Reporting EHR Measures through the pilot, participants can focus on the same sample of beneficiaries for the Medicare EHR Incentive Program and for the Physician Quality Reporting System for the 2012 program year. Eligible professionals participating in the Physician Quality Reporting System – Medicare EHR Incentive Pilot are still required to report the other meaningful use objectives through the Medicare and Medicaid EHR Incentive Programs Registration and Attestation System.
Second, beginning in 2013, failure to successfully report PQRS measures will result in an adjustment (penalty) of -1.5 percent on all Medicare payments in 2015.
Third, even those without a qualified EHR system can successfully participate in the PQRS program without the hassles of the claims-based reporting that has proven quite burdensome and unsuccessful for many practices. The registry-based option allows for successful reporting with selection of a measures group for which you will report on 30 Medicare patients using an online registry program such as the AAFP PQRIwizard.
You can find more information on the PQRS program and the
EHR-based and registry-based reporting options on the CMS PQRS Alternative Reporting Mechanisms page.
Don't give up the full amounts allowed under the Medicare Physician Fee Schedule.