Transcript COMPLIANCE

DOCUMENTATION
REQUIREMENTS
E/M Codes
Targeted Codes
99214 : established patient, outpt. visit – presenting
problems are usually moderate to high severity
99212: established patient, outpt. Visit – presenting
problems usually self limited or minor
99233: subsequent hospital care – usually patient is
unstable, developed a significant complication or
a significant new problem
99231: subsequent hospital care – usually a stable,
recovering, or improving patient
Codes accounting for the errors
What codes should have been used
Principles of
Documentation:
• MR should be complete & legible
• Documentation for each patient encounter
should include:
–
–
–
–
–
–
–
–
Reason for encounter & relevant history
Physical exam & findings
Prior diagnostic test results
Assessment
Clinical impression or diagnosis
Plan for care
Date
Legible identity of the observer
Principles of
Documentation Cont.
• If not documented, the rationale for ordering
diagnostic & ancillary services should be easily
inferred
• Past & present diagnosis should be accessible to
the treating/consulting physician
• Appropriate risk factors should be identified
• Pt’s progress, response to & changes in treatment
& diagnosis revision should be documented
• CPT & ICD-9 codes on claim must be supported
by MR documentation
Evaluation and
Management Codes
-Developed jointly by HCFA & the AMA
How to stay on the good side of HCFA
MEDICAL NECESSITY
– Inpatient : Does the diagnosis code
support the medical need for the
service performed?
If not, does the documentation in
the record support the necessity?
– Outpatient : Level of Visit Codes
The 7 Components:
KEY
1) History
2) Examination
3) Medical Decision Making
4) Counseling
5) Coordination of Care
6) Nature of Presenting Problem
7) Time
E & M Determination
Level
History
Examination
Med. Decision
Making
I
Prob. Focused
Problem Focused
Straightforward
II
Expanded Prob.
Focused
Expanded Problem
Focused
Straightforward
III
Detailed
Detailed
Low Complexity
IV
Comprehensive
Comprehensive
Moderate
Complexity
V
Comprehensive
Comprehensive
High Complexity
The 7 Components:
KEY
1) History
2) Examination
3) Medical Decision Making
4) Counseling
5) Coordination of Care
6) Nature of Presenting Problem
7) Time
Documentation of History:
Level of service is based on 4 types:
1) problem focused
2) expanded problem focused
3) detailed
4) comprehensive
History elements (some or all):
 chief complaint, CC
 history of present illness, HPI
 review of systems, ROS
 past, family and/or social
history, PFSH
ROS & PFSH obtained Earlier
w/o any change:
• Do not have to re-record if there is
evidence that a physician had
reviewed & updated the previous one
• How to documented the review:
– Describe any new information,
– not that there has been no change, or
– note the date & location of the earlier
entry
DG 1
•ROS & PFSH may be recorded by ancillary
staff or by the patient - physician must
supplement or confirm the information
received for documentation
• If not able to obtain information - note in
chart the patient’s condition & the
circumstances that preclude obtaining a
history
DG 2 & 3
HPI Elements
1) location
Brief:
1-3
2) quality
3) severity
Extended:
4) duration
at least 4 or the status
of at least 3 chronic or
5) timing
inactive conditions
6) context
7) modifying factors
8) associated signs & symptoms
DG 4 & 5
ROS Elements
•
•
•
•
•
•
•
constitutional symptoms •
•
eyes
ears, nose, mouth, throat •
•
cardiovascular
•
respiratory
•
gastrointestinal
•
genitourinary
musculoskeletal
integumentary
neurological
psychiatric
endocrine
hematologic/lymphatic
allergic/immunologic
ROS Definitions
• PROBLEM PERTINENT - inquires about
the system directly related to the problem in
HPI
• EXTENDED - directly related system + 2 - 9
systems documented
• COMPLETE - directly related system + all
additional body systems
DG 6, 7 & 8
PFSH • Pertinent - review of history areas directly
related to problem in HPI
• Complete - review of 2 or all 3, depending
on the category on E&M code (required for
comprehensive assessments)
DG 9
PFSH requirements for:
Initial Patients
Est. Patients
• requires 1 item from
the 3 areas
• requires 1 item
from the 2 areas
• applies to outpt/office,
consults, observation
pts, nursing home
assessments, domiciliary
care, home care
• applies to outpt/office,
ER services,
domiciliary care, home
care
DG 10 & 11
Level of Service Determination
Expanded
Problem
History
Prob.
Detailed Comprehensive
Focused
Focused
Brief
Brief
Extended
Extended
HPI
ROS
N/A
Problem
Pertinent
Extended
Complete
PFSH
N/A
Detailed
Pertinent
Complete
* Must have all 3 in column or choose lowest
The 7 Components:
KEY
1) History
2) Examination
3) Medical Decision Making
4) Counseling
5) Coordination of Care
6) Nature of Presenting Problem
7) Time
Documentation of Examination:
Level of service is based on 4 types:
1) problem focused
2) expanded problem focused
3) detailed
4) comprehensive
Exam Types:
 cardiovascular, ENT & mouth, eyes, male & female
genitourinary, hematological/lymphatic/immunologic,
musculoskeletal, neurological, psychiatric, respiratory, skin
Documentation Guidelines:
• Elements w/ mult. components require
documentation of at least 1 component
• “abnormal” can be used for exams of the
affected or symptomatic body area
• abnormal/unexpected finding in
asymptomatic areas should be described
• “negative” or “normal” is sufficient for
unaffected or asymptomatic areas
General Multi-System Exams:
PROBLEM FOCUSED:
1-5 elements in  1 body areas/systems
EXPANDED PROBLEM FOCUSED:
 6 elements in  1 body areas/systems
DETAILED:  2 elements in 6 ore
more body areas/systems (or  12
elements in  2 areas)
COMPREHENSIVE: allelements in
selected areas,  9 body areas/systems
Single Organ Exams:
PROBLEM FOCUSED:
1-5 elements in any box
EXPANDED PROBLEM FOCUSED:
 6 elements in any box
DETAILED:  12 elements in any box (eye &
psychiatric  9 elements)
COMPREHENSIVE: allelements ( document
every element in bold boxes & at least 1 in normal
boxes)
The 7 Components:
KEY
1) History
2) Examination
3) Medical Decision Making
4) Counseling
5) Coordination of Care
6) Nature of Presenting Problem
7) Time
Documentation of Medical
Decision Making:
Level of service is based on 4 types:
1) straight - forward
2) low complexity
3) moderate complexity
4) high complexity
-complexity of establishing a diagnosis and/or
selecting a management option
Complexity factors….
• Pt’s # of diagnoses
• the amount and/or complexity of MR,
tests, & other information that must be
obtained, reviewed, & analyzed
• risk of significant complications,
morbidity/mortality as well as comorbidities associated with the presenting
problem(s)
DG for # of Diagnoses
or Mgmt. Options….
• Established dx. - state if improved/well
controlled/ resolving or worsening/failing to
change as expected
• new diagnosis - stated in form of differential dx.
possible/probable/rule out
• initiation or changes in treatment
• to whom or where referrals or consults are made
or from whom the advice is requested
DG for amount & complexity
of data to review….
• Types of service ordered at the time of encounter
• reviewed results, initial & date report w/ the results
• any further history or information obtained from
MR, patient, etc.
• relevant findings from above
• results of discussions w/ physicians
associated w/ reviewed results
• direct visualization or independent interpretation of
tests/films interpreted by another physician
Risk DG...
• Any factor that would increase the risk of
complications, morbidity, mortality
• procedures planned at that time
• specific procedure performed at time of
encounter
• need for an urgent procedure to be done
Table of Risk
Level of
Risk
minimal
low
Presenting
Problem
Diagnostic Procedure
Ordered
Management Options
Selected
• one self limited •Lab tests w/ venipuncture
or minor problem •Chest x-rays
•EKG/EEG
•Urinalysis
•Ultrasound
•KOH Prep
• rest
•Gargles
•Elastic bandages
•Superficial dressings
• 2 or more self
limited problems
• 1 stable chronic
illness
•Acute
complicated
illness
• over the counter
drugs
•Minor surgery w/ no
identified risk factors
•PT or OT
•IV fluids w/o
additives
•Physiologic tests not
under stress
•Non-cardiovascular
imaging studies w/
contrast
•Superficial needle
biopsies
•Clinical lab test
•Skin biopsies
Table of Risk
Level of
Risk
Presenting Problem
Moderate • one or more
Diagnostic Procedure
Ordered
•Physiologic test under
chronic illness w/ stress
mild exacerbation •Diagnostic endoscopies
• 2 or more stable w/ no identified risk
chronic illnesses
factors
• undiagnosed new •Deep needle or
problem w/
incisional biopsy
uncertain
•Cardiovascular imaging
prognosis
studies w/ contrast & no
•Acute illness w/
identified risk factors
systemic
•Obtain fluid from body
symptoms
cavity
•Acute
complicated injury
Management Options
Selected
• minor surgery w/
identified risk factors
•Elective major
surgery w/ no
identified risk factors
•Prescription drug
management
• Therapeutic Nuclear
Med.
•IV fluids w/ additives
•Closed treatment of
fracture or dislocation
w/o manipulation
Table of Risk
Level of
Risk
Presenting Problem
Diagnostic Procedure
Ordered
Management Options
Selected
High
• one or more
chronic illness w/
severe
exacerbation
• acute/chronic
illness/injury that
pose a threat to life
or bodily function
• Diagnostic
endoscopies w/
identified risk factors
•Cardiovascular imaging
studies w/ contrast &
identified risk factors
•Cardiac
electrophysiological
tests
•Discography
• Emergency major
surgery
•Elective major
surgery w/ identified
risk factors
•Parental controlled
substances
•Drug therapy
requiring intensive
monitoring for toxicity
•Decision not to
resuscitate
Medical Decision Making
Determination
Type of
Decision
Making
# of dx. or
mgmt
options
Data
Reviewed
Risks
Straight
Forward
Low
Moderate
High
Minimal
Limited
Multiple
Extensive
Minimal
Limited
Moderate
Extensive
Minimal
Low
extensive
High
* 2 of 3 elements must be met or exceeded
E & M Determination
Initial Patients must have 3 of 3
Level
History
Examination
Med. Decision
Making
I
99201
Prob. Focused
Problem Focused
Straightforward
II
99202
Expanded Prob.
Focused
Expanded Problem
Focused
Straightforward
III
99203
Detailed
Detailed
Low Complexity
IV
99204
Comprehensive
Comprehensive
Moderate
Complexity
V
99205
Comprehensive
Comprehensive
High Complexity
E & M Determination
Initial Patients must have 3 of 3
Level
History
Examination
Med. Decision
Making
I
99201
Prob. Focused
Problem Focused
Straightforward
II
99202
Expanded Prob.
Focused
Expanded Problem
Focused
Straightforward
III
99203
Detailed
Detailed
Low Complexity
IV
99204
Comprehensive
Comprehensive
Moderate
Complexity
V
99205
Comprehensive
Comprehensive
High Complexity
NEW PATIENTS
99201-99205
One who has NOT received any
professional services from the
physician or any other physician of
the same specialty who belongs to
the same group practice within the
past 3 years.
36
E & M Determination
Established Patients must have 2 of 3
Level
History
Examination
Med. Decision
Making
I
99211
Prob. Focused
Problem Focused
Straightforward
II
99212
Expanded Prob.
Focused
Expanded Problem
Focused
Straightforward
III
99213
Detailed
Detailed
Low Complexity
IV
99214
Comprehensive
Comprehensive
Moderate
Complexity
V
99215
Comprehensive
Comprehensive
High Complexity
ESTABLISHED PATIENTS
99211-99215
One who HAS received professional
services from the physician of the
same specilaity who belongs to the
same group practice within the last
3 years.
38
EST. PT Billing - 99211
Can be billed by the nursing staff when a
chief complaint exists.
Normally Required Care:
Blood pressure, weight, reactions to current meds, additional
services not usually provided by a physician
NOT: finger sticks & injections
*physician must be on the premises
39
Observation Care
99218-99220
Report encounters by the supervising MD
Characteristics of Observation Pts:
• not been admitted as an inpatient
• may be physically detained in ER
• clinical condition is being observed
• additional time needed to clarify condition
• to determine if hospitalization is needed
40
Observation to Inpatient• MD admits pt to both w/in 24 hours – bill
as initial hospital visit
• Do NOT bill for an initial hospital visit &
initial obs. code
• Can NOT bill for an obs. discharge
mgmt when admitting to inpt.
41
Global Surgical Period
• Fee includes obs payment
• Must use modifiers with the CPT code to receive
payment
• –57 indicates that the decision for surgery was
made while the patient was in obs.
• -24 denotes observation services are unrelated
to the surgery
• -79 subsequent surgical procedure
• -25 separately identifiable service
42
MODIFIER -25
Indicates that E/M
codes reported on the
same bill are for
significant and
separately identifiable
services
43
One last thing…
If using a template to dictate your
note DON’T FORGET to state
that it was “normal” or
“negative”