3F Auditing Outpatient Surgical Services. Disclaimer. Agenda. 3F Auditing Outpatient Surgical Services November 2013

Similar documents
Technical Component (TC), Professional Component (PC/26), and Global Service Billing

PHYSICIAN FEE SCHEDULE PAYMENT GROUND RULES: A COMPARISON OF THE OMFS AND MEDICARE *

Chapter 9 Section 1. Ambulatory Surgical Center (ASC) Reimbursement

Coding & Reimbursement in an ASC: Both Sides of the Coin. April 5, 2011 Penny Osmon, BA, CPC, CPC-I, CHC, PCS Jen Cohrs CPC, CPMA, CGIC

Presented by: Jodie Edmonds VP Medicaid Revenue Consultant Passport Health Communications

Coding, Corroboration, and Compliance How to assure the 3 C s are met

AWCC TABLE OF DATA REQUIREMENTS

TRICARE Reimbursement Manual M, February 1, 2008 Ambulatory Surgery Centers (ASCs) Chapter 9 Section 1

Supply Policy. 11/15/2017 Approved By Reimbursement Policy Oversight Committee

Compliant Documentation for Coding and Billing. Caren Swartz CPC,CPMA,CPC-H,CPC-I

Chapter 9 Section 1. Ambulatory Surgical Center (ASC) Reimbursement

Reimbursement for Non-Invasive Respiratory Support in Hospital Inpatient, Emergency Department and Other Outpatient Settings 1

Provider-Based RHC Billing June 8, 2018

Billing & Reimbursement Presentation. November 28, 2007

Payment System (OPPS)

Do I Have the Right Credential?

Coding Guidelines for Certain Respiratory Care Services January 2018 (updates in red)

CLINICAL MEDICAL POLICY

Meet the Presenter. HCPCS Reimbursement Impacts the Bottom Line. Welcome to PMI s Webinar Presentation. On the topic:

Advanced Evaluation and. AAPC Regional Conference Chicago 10/27/12

Outpatient Observation Services

Modifiers 54 and 55 Split Surgical Care

Postoperative Sinus Endoscopy and/or Debridement Procedures

ADVANCED MONITORING PARAMETERS 2017 QUICK GUIDE TO HOSPITAL CODING, COVERAGE AND PAYMENT

HC 1930 HC 1930 ICD-9-CM III/CPT Coding II

Independent RHC Billing Introduction Session 3 Spring, 2018

IMPORTANT NOTE ABOUT THIS REIMBURSEMENT POLICY

AHLA. MM OPPS Update. Valerie Rinkle Navigant Consulting Seattle, WA

201 & 202 of the Balanced Budget Refinement Act of 1999 (BBRA), provides authority

Chapter 13 Section 2. Billing And Coding Of Services Under Ambulatory Payment Classifications (APC) Groups

Reimbursement guide. IODOSORB/IODOFLEX are Cadexomer Iodine-based products, available in two forms gel or pad.

Tips for Completing the UB04 (CMS-1450) Claim Form

Optima Health Provider Manual

Payment Policy: High Complexity Medical Decision-Making Reference Number: CC.PP.051 Product Types: ALL

Jaci Johnson, CPC,CPMA,CEMC,CPC H,CPC I President, Practice Integrity, LLC Disclaimer

Chapter 13 Section 2. Billing And Coding Of Services Under Ambulatory Payment Classifications (APC) Groups

Medicare Reimbursement Challenges. Financial Interest. Current Issues. Rose & Associates

Modifiers 80, 81, 82, and AS - Assistant At Surgery

Deleted Codes. Agenda 1/31/ E/M Codes Deleted Codes New Codes Changed Codes

February Jean C. Russell, MS, RHIT Richard Cooley, BA, CCS

Outpatient Hospital Facilities

Anesthesia Policy REIMBURSEMENT POLICY CMS Reimbursement Policy Oversight Committee. Policy Number. Annual Approval Date. Approved By 2018R0032B

VIRGINIA WORKERS COMPENSATION MEDICAL FEE SCHEDULES GROUND RULES JUNE 5, 2017

Hospital-Based Ambulatory Care

Chronic Care Management. Sharon A. Shover, CPC, CEMC 2650 Eastpoint Parkway, Suite 300 Louisville, Kentucky

Medicare Preventive Services

Anesthesia Services Policy

HFMA - Northern California. Otani Consulting Group Inc, Hawthorne Blvd, #216, Torrance, CA 90503

Shared and Incident To Billing of E/M Services in Radiation Oncology Updated November 2017

February Jean C. Russell, MS, RHIT Richard Cooley, BA, CCS

Subject: Updated UB-04 Paper Claim Form Requirements

Objectives. Observation: Exploring the MOON and Charge Capture. Aurora Health Care 10/11/2016

Medicare Desk Reference for Hospitals. Sample page

Reimbursement for Anticoagulation Services

Reimbursement Policy (EXTERNAL)

Procedure Code Job Aid

Medical, Surgical, and Routine Supplies (including but not limited to 99070)

Section: Administrative Subsection: None Date of Origin: 7/25/2011 Policy Number: RPM040 Last Updated: 10/4/2017 Last Reviewed: 10/11/2017

Doris V. Branker, CPC, CPC-I, CEMC

Modifiers 58, 78, and 79 Staged, Related, and Unrelated Procedures

Global Surgery Fact Sheet

2019 Evaluation and Management Coding Advisor. Advanced guidance on E/M code selection for traditional documentation systems

CMNs Chapter 4. Chapter 4 Contents

Important Billing Guidelines

Surgical Assistant DESCRIPTION:

Chapter 1 Section 16

Reimbursement Information for Contrast Enhanced Spectral Mammography (CESM) Services 1

OIG Medicare Compliance Audits: Tactical Tips for Surviving One from the Battlefield

Critical Care, Evaluation and Management Services (99291, 99292)

Chapter 02 Hospital Based Care

Workers Compensation Medical Services Review Committee Meeting Minutes March 16, 2015

Chapter 13 Section 2. Billing And Coding Of Services Under Ambulatory Payment Classifications (APC) Groups

Medical Fee Schedule (MFS) Frequently Asked Questions (FAQs) General FAQs

MLN Matters Number: MM6740 Revised Related Change Request (CR) #: Related CR Transmittal #: R1875CP Implementation Date: January 4, 2010

Observation Services Tool for Applying MCG Care Guidelines

Modifier 53 Discontinued Procedure

Global Surgery Package

Reimbursement Policy. Subject: Modifier Usage

PREVENTIVE MEDICINE AND SCREENING POLICY

Cotiviti Approved Issues List as of February 26, 2018

AMBULATORY SURGICAL CENTERS PROVIDER MANUAL Chapter Twenty-nine of the Medicaid Services Manual

LifeWise Reference Manual LifeWise Health Plan of Oregon

Medical Reimbursement Newsletter

Mid-Level Providers: What You Need to Know to Use Them Successfully in Your Practice

NIM-ECLIPSE. Spinal System. Reimbursement Brief

HOW TO SUBMIT OWCP-04 BILLS TO ACS

Complete Home Health Icd-9-cm Diagnosis Coding Manual 2012

Clinic Specific Coding and Reporting Changes for 2017

Coding for the Outpatient Hospital Setting. Webinar Subscription Access Expires December 31.

Cigna Medical Coverage Policy

Corporate Reimbursement Policy

Empire BlueCross BlueShield Professional Commercial Reimbursement Policy

Florida Medicaid. Ambulatory Surgical Center Services Coverage Policy. Agency for Health Care Administration

9/11/15. Reimbursement for Non- Physician Providers Real Life Practice Objectives

Anesthesia Policy. Approved By 3/08/2017

Tips for Completing the CMS-1500 Version 02/12 Claim Form

Rural Health Clinic Overview

What To Do When An Audit Letter Comes

OBSERVATION CARE EVALUATION AND MANAGEMENT CODES POLICY

Observation Services Tool for Applying MCG Care Guidelines Policy

Transcription:

3F Auditing Outpatient Surgical Services 2013 Regional Conference Baltimore, MD November 18, 2013 presented by Sarah L. Goodman, MBA, CHCAF, CPC H, CCP, FCS All Rights Reserved Disclaimer Every reasonable effort has been taken to ensure that the educational information provided in today s presentation is accurate and useful. Applying best practice solutions and achieving results will vary in each hospital/facility situation. 2 Agenda Overview of Facility Outpatient Auditing Outpatient Chart to Bill Audit Review Purpose Key Elements Forms Utilized Surgery Auditing Tips Examples Discussion 3 2013 AAPC Regional Conference Baltimore 1

Facility Outpatient Auditing There are a number of types of audits that can be performed in the facility outpatient setting. These include: Coding validation (i.e., ICD 9 CM, HCPCS, and occurrence/value/condition codes) These can involve a review of a single codeset or combination of codesets on a claim to ensure they are accurate and supported by documentation. Medical necessity reviews These are performed to determine whether services rendered are appropriate, essential and supported by the diagnosis. 4 Facility Outpatient Auditing Types of facility outpatient audits (continued): Reimbursement audits (e.g., APC, MPFS, etc.) These require comparing the Explanation of Benefits (EOB) to the payment that was expected. Charge capture analyses These entail a review of charge encounter forms, order entry screens, ancillary system interfaces and/or staff charging practices to ensure charges are entered timely and accurately. Chart to Bill (a.k.a. Chart to Charge) audits These will be described in more detail on the next several slides. 5 Chart to Bill Audits Purpose What is the purpose of a Chart to Bill audit, i.e., why would a hospital want to perform one? The answer is simple to ensure billing compliance and appropriate charge capture! A Chart to Bill audit, also sometimes referred to as a Chart to Charge audit, is a review to ensure that all items (i.e., HCPCS, ICD 9 CM, payer type, provider name, etc.) reported on the UB 04, CMS 1500 and/or detail bill have been properly documented in the chart and vice versa, and that such services do not elicit NCCI, device to procedure, and other payer edits. 6 2013 AAPC Regional Conference Baltimore 2

Chart to Bill Audits Key Elements What are some key elements that one should one look out for when performing a hospital chart to bill audit? Charges for medications/supplies or tests/services that were not ordered or that were not performed or provided Charges for certain services that were performed by nurses or technicians, such as equipment monitoring, that should be included in the accommodation, surgery time, procedure or visit 7 Chart to Bill Audits Key Elements Key elements of a hospital chart to bill audit (continued): Separate charges for tests that together comprise a panel for which there should be a single charge, i.e., unbundling Duplicate charges, i.e., more than one charge for the same item or service Likely to happen when same/similar services are performed by multiple departments, e.g., venipunctures, CPR, and EKGs 8 Chart to Bill Audits Key Elements Key elements of a hospital chart to bill audit (continued): Separate charges for services and supplies that should be included in the charge for another item, e.g., NCCI edit issues Charges for routine supplies and equipment such as surgical gloves, drapes, urinals, bedpans, irrigation solutions, ice bags, IV tubing, pillows, towels, gauze, oxygen masks, oxygen supplies, syringes, blood pressure cuffs, heating pads, and monitors 9 2013 AAPC Regional Conference Baltimore 3

Chart to Bill Audits Key Elements Key elements of a hospital chart to bill audit (continued): Incorrect dates of service Charges for tests and services that had to be repeated because they were performed incorrectly the first time, the results were lost, mislaid, or not properly documented, etc. 10 Chart to Bill Audits Key Elements Key elements of a hospital chart to bill audit (continued): Documented items and services that were not charged, but are separately billable Units of service match what is charted Appropriate use of modifiers Rounding of timed charges is accurate when applicable 11 Chart to Bill Audits Key Elements Key elements of a hospital chart to bill audit (continued): Orders and results present for all billed services Physician orders must be: Legible Complete, i.e., identify the patient, support the diagnosis/ condition, etc. Dated and timed Authenticated in written or electronic form Retained in the chart and available for audit purposes 12 2013 AAPC Regional Conference Baltimore 4

Forms Utilized In addition to analyzing elements in the chart, a chart to bill audit entails a review of the UB 04 (or in some cases, the CMS 1500) and a comparison to the itemized bill. The UB 04 is maintained by the National Uniform Billing Committee (NUBC) and the CMS 1500, by the National Uniform Claim Committee (NUCC). 13 UB 04 http://www.nubc.org/ 14 UB 04 Pertinent Fields UB 04 Form Locators (FL 42 48) 42 Revenue Code Required This field contains applicable revenue code(s), i.e., 4 digit for the services rendered. There are 22 lines available and should include the total line for revenue code 0001. 44 HCPCS / Rate / HIPPS Code Conditional This field is used to report the appropriate HCPCS codes for ancillary services, the accommodation rate for bills for inpatient services, and the Health Insurance Prospective Payment System (HIPPS) rate codes for specific patient groups. 46 Service Units Required This field is used to report units such as pharmaceutical base dosage dispensed, pints of blood used, miles traveled, or the number of inpatient days utilized. 47 Total Charges Required This field reports the total charges covered and non covered related to the current billing period. 48 Non Covered Charges Conditional This field indicates charges that are noncovered by the payer as related to the revenue code. https://www.cms.gov/mlnproducts/downloads/ub04_fact_sheet.pdf 15 2013 AAPC Regional Conference Baltimore 5

UB 04 Example 16 CMS 1500 http://nucc.org/ 17 CMS 1500 Pertinent Fields CMS 1500 Fields (selected) 21 Diagnosis or nature of illness or injury Required This field is used to list up to four ICD 9 CM diagnosis codes. Relate lines 1,2,3,4 to lines of service in 24E by line number. Use the highest level of specificity. Do not provide narrative description in this box. 23 Prior authorization number Required if This field is used to enter the prior applicable authorization or service agreement number as assigned by the payer for the current service. 24D Procedures, services or supplies Required This field is used to enter HCPCS Level I codes (CPT), Level II codes and modifiers. Up to four modifiers may be submitted. 24E Diagnosis pointer Required This field is used to enter diagnosis pointer(s) referenced in field 21 to indicate which diagnosis code(s) apply to the related HCPCS code. Do not enter ICD 9 CM codes or narrative descriptions in this field. Do not use slashes, dashes, or commas between reference numbers. 24J Rendering provider ID Required if applicable This field is used to enter the ten digit NPI. http://www.cms.gov/mlnproducts/downloads/form_cms 1500_fact_sheet.pdf 18 2013 AAPC Regional Conference Baltimore 6

Detail (Itemized) Bill 19 What should one look for when auditing for Surgical services? Correct date(s) of service Orders and results for services rendered 20 What should one look for when auditing for Surgical services? Appropriate HCPCS, ICD 9 and revenue code assignment 21 2013 AAPC Regional Conference Baltimore 7

What should one look for when auditing for Surgical services? Correct use of modifiers, i.e., 59 (Distinct Procedural Service), etc. Be wary of modifier 59 for bypassing edits always go back to the documentation Responsibility for appending varies significantly from hospital to hospital So much misuse and confusion exists that the OIG has published guidance on its use: http://www.oig.hhs.gov/oei/reports/oei 03 02 00771.pdf 22 What should one look for when auditing for Surgical services? (continued) Documentation for procedures, e.g., surgery, anesthesia and recovery start/stop times, etc. 23 What should one look for when auditing for Surgical services? (continued) Legibility 24 2013 AAPC Regional Conference Baltimore 8

What should one look for when auditing for Surgical services? (continued) Proper reporting of supplies, DMEPOS items and pharmaceuticals dispensed by department, including review of Device to Procedure Edits and/or Procedure to Device Edits 25 CMS Procedure to Device Edits Table Example CPT/ HCPCS Description CY 2013 APC Device A Device A Description Implementation Termination Device Effective Date of Edit Termination Date B* (See Date of Edit (if different from Date (Implementat note) Device B Description (DOS) effective date) (Effective) ion) 37188 Mechanical Thrombectomy 0088 C1757 Cath, thrombectomy/e mbolect 1/1/2006 Icar ischm mntrng No edit; no suitable 0302T sys compl 0089 device code Insertion of heart Pmkr, dual, rateresp 10/1/2005 33206 pacemaker 0089 C1785 Insertion of heart Pmkr, single, Lead, pmkr, 33206 pacemaker 0089 C1786 rate resp C1779 transvenous VDD 10/1/2005 Insertion of heart Pmkr, dual, non 33206 pacemaker 0089 C2619 rate resp 10/1/2005 Insertion of heart Pmkr, single, non Lead, pmkr, other 33206 pacemaker 0089 C2620 rate resp C1898 than trans 10/1/2005 Insertion of heart Pmkr, single, non 33206 pacemaker 0089 C2621 rate resp 10/1/2005 Insertion of heart Pmkr, dual, rateresp 10/1/2005 33207 pacemaker 0089 C1785 Insertion of heart Pmkr, single, Lead, pmkr, 33207 pacemaker 0089 C1786 rate resp C1779 transvenous VDD 10/1/2005 Insertion of heart Pmkr, dual, non 33207 pacemaker 0089 C2619 rate resp 10/1/2005 * Device B can be reported with any Device A for the same code. For example, C1898 can be reported with C1785 for procedure code 33206. 26 When it comes to billable supplies, consider whether the items would be noted by name, size, type, use, etc., in the chart. If not, then they are routine and should not be charged separately. Implantable devices, DMEPOS and those items assigned to HCPCS C code categories should be captured when appropriately documented. 27 2013 AAPC Regional Conference Baltimore 9

Non routine items and services may be reported separately to Medicare when they are: directly identifiable items and services provided to individual patients furnished under the direction of a physician because of specific medical needs not reusable or represent a cost for each preparation 28 Routine Supplies Example 29 DMEPOS refers to: Non implanted prosthetic and orthotic devices (typically L coded items with a Status Indicator of A in Addendum B) are paid under the orthotics/prosthetics fee schedule, and should be billed to the FI/MAC under revenue code 0274 and the appropriate HCPCS code when provided for home use. DME items such as crutches (typically E coded items with a Status Indicator of Y or E in Addendum B) are billed to the DME MAC, and require a separate provider number (Medicare PM A 03 035, May 2, 2003). Minimal cost take home items without specific HCPCS coding may be reported under revenue code 0273. 30 2013 AAPC Regional Conference Baltimore 10

DMEPOS (continued): When a prosthetic or orthotic device is provided by hospital staff, and the HCPCS code that describes that device includes the fitting, adjustment, or other services necessary for the patient s use of the item, an E/M visit or other HCPCS procedure code should not be reported in addition. For example, if the hospital outpatient staff provides the orthotic device described by HCPCS code L1830 (KO, immobilizer, canvas longitudinal, prefabricated, includes fitting and adjustment), the hospital should only bill HCPCS code L1830 and should not bill a visit or procedure HCPCS code to describe the fitting and adjustment. [CMS Manual System Pub 100 04 (Transmittal 1702)] 31 Observation is often billed in conjunction with surgical services. However, observation should not be reported: for routine post operative monitoring during a normal (4 6 hours) recovery period as a substitution for a medically appropriate inpatient admission when not medically necessary for diagnosis or treatment for routine recovery procedures and services provided prior to outpatient diagnostic testing via standing orders following outpatient surgery 32 The physician orders on the next slide were written and timed prior to the procedure. Unless the patient ultimately had an adverse event, charging for observation is not warranted. 33 2013 AAPC Regional Conference Baltimore 11

Order for 23 hour Observation Written in Advance of Surgery Example 34 On the next slide, we have an example of provider progress notes that are virtually unreadable. How many words you can decipher? 35 Multidisciplinary Progress Notes Example 36 2013 AAPC Regional Conference Baltimore 12

On the next slide, there are time charges for surgery, recovery, general anesthesia and desflurane anesthesia gas. In the facility setting, anesthesia charges represent the supplies, equipment and gases utilized by the anesthesiologist or CRNA. What seems awry here? 37 Time Charges Detail Bill Example 38 This next slide is supposedly the documentation to support the anesthesia time charges reported on the previous detail bill example; however, it is totally illegible. 39 2013 AAPC Regional Conference Baltimore 13

Illegible Anesthesia Record Example 40 Of the supplies on the next slide, how many do you think are separately billable? 41 Surgery Supplies Detail Bill Example 42 2013 AAPC Regional Conference Baltimore 14

Now we have a very complex surgery case reflected on a UB 04. The patient had bilateral breast implant rupture and cancer of her left breast with removal and implant replacement. What do you observe? 43 UB 04 Coding Example 44 The correct codes that should have been reported per the documentation are: 38500 38792 LT 19301 LT 19371 50 19340 50 15777 None of the 59 modifiers reported were needed. 45 2013 AAPC Regional Conference Baltimore 15

Questions? Thank you! Discussion 46 2013 AAPC Regional Conference Baltimore 16