Documentation Concerns for ICD-10

AAPC 2014 Seattle Regional
Conference Review
Documentation Concerns for
ICD-10
Presented by Lori Dafoe, CPC
Focus Points From AAPC Seattle
Regional Conference
Presentation drafted from information provided
by:
Documentation Concerns for ICD-10
Presented by Peggy Stilley, CPC, CPB, CPMA,
CPC-I, COBGC
Agenda
• Benefits of Documentation
• Best Approach
• Examples
Benefits of
Documentation
• “Documentation is only
good if the next
physician who treats
the patient can pick up
your record and know
exactly what
happened.”
Benefits of Documentation
• Improves compliance
• Improves patient care
• Improves clinical data for research
and education
• Enables proper reimbursement for
services performed
Best Approach
• “The only
person that
likes change
is the baby
with a wet
diaper.”
Best Approach
* Positive
Attitude
Best Approach
• Introduction of Information in Steps
Best Approach
• Offering
Solutions
ICD-9: 692.9 Eczema NOS
SUBJECTIVE: This patient was sent in for consult for initial
evaluation of a eczema. The patient has been treated with Elidel
cream b.i.d. for six months but apparently this has stopped
working now and it seems to make her more dry and plus she
has been using some baby oil on her skin. Overall health is good.
EXAM: The patient has eczematous changes today on her face,
trunk and extremities.
IMPRESSION: Eczema
ICD-10: L30.9 Dermatitis, unspecified (Eczema NOS)
ICD-10 Documentation Assessment Form
Physician Name: Dr. Crabby
Date of Audit: XXXX
Reviewer (Auditor): Lori Dafoe, CPC
Chart
Patient ID
ICD-10-CM
Description
1
A1234
L30.9
Dermatitis,
unspecified (Eczema
NOS)
In ICD-10-CM, in order to assign a code for dermatitis to the highest level of specificity,
documentation needs to include type and causation.
Dermatitis
SUBJECTIVE: This 10 month old, black female, sent in for
consult for initial evaluation of a lifelong history of atopic
eczema. The patient has been treated with Elidel cream b.i.d.
for six months but apparently this has stopped working now and
it seems to make her more dry and plus she has been using some
baby oil on her skin. Overall health is good.
EXAM: The patient has eczematous changes today on her
face, trunk and extremities.
IMPRESSION: Atopic eczema
ICD-10: L20.83 Infantile (acute) (chronic) eczema
Summary
• Emphasize the need to move away from usage of
unspecified codes.
• Update Templates (EMR or Paper).
• Educate on changes with enough time to become
familiar with them.
• Perform documentation assessments to see
where improvements are needed.
• Provide clear, concise education on noted
weaknesses.
• Re-evaluate after implementation.
The role of your Billing Department
Presented by: Barbara Parker, CPC
Hints from AAPC Regional Conference
•
•
•
•
•
Adapted from two presentations given by
Charitie Horsley, CPC
Owner of a billing service
Yvonne Dailey, CPC, CPC-I, CPB
Owner of Dailey Billing Services
Objectives
• Identify resources available
• Explain how these resources will improve
efficiency
• List some technology that could make the
Billing Department more efficient
• Explain the ways all staff affects claims denials
Does your Billing Department Look
Like This?
Automation
• Don’t underestimate the value of one minute
Times
per day
Day
Week
Month
Year
Total
Hours
1
minute
1
5
20
260
4.3
5
minutes
5
25
100
1300
21.7
10
minutes
10
50
200
2600
45.3
Communications
• http://www.televox.com/wellness-preventivereminders/additional-resources/
• Great resource that Charitie referenced in her
presentation
• Research showed:
• 85% of patents said that e-communications are more
helpful than in-person or phone conversations
• 88% of patients want to receive digital reminders for
preventive or follow up care
• More than 35% of patients who don’t follow
treatment plans exactly said they would be more
likely to do so if they received e-mail, voicemail, or
text reminders
Examples
• Automated patient collections process
• Utilizing Clearinghouse services for denial
corrections, appeal solutions and to analyze
data
• Internet freebies such as WHO, AMA, and
CMS
• MGMA (Book: The Physician Billing Process:
12 Potholes in the Road to Getting Paid)
Key Items to Measure
•
•
•
•
•
•
Timely filing loss
Working Productivity
Coding
Accounts Receivable
Workflow
Denials
One Resource
TITAN-a real-time, web-based application that
provides comparative healthcare analytics on
reimbursement, utilization and productivity for
practices, service providers, and health systems
www.remitdata.com
Sample Analytics
•
•
•
•
•
Denial management
E & M procedure code profile
Payer performance
E & M utilization with analysis
Clearinghouse analysis
Hire the Right People






Pre-Employment Skills Assessments
Writing
Spelling
Basic math
Keyboard
10-key
Special Skills (coding, accounting)
Denials
• Documentation
• Missed charges
• Carrier policies determine billing codes
Common Billing Errors
• Patient cannot be identified
• Address for the place of service, including a valid Zip
Code
• E/M procedure code and place of service do not
match
• NPI missing or invalid
• Diagnosis codes invalid
• Procedure code/modifier invalid
• Information needed when Medicare is a secondary
payer
Claims follow-up
• Don’t set to auto rebill every 30 days
• Run reports from PMS
• Assign staff for claims follow-up and make
them responsible
Other items to watch
•
•
•
•
•
Payment posting
Denial management
Proof of timely filing
Appeals
Reports
Cost for NOT Working Denials
• 90 claims per day at $90 per claim = $8,100
• If 10% denied = $810 in denial per day
• If only 1 in 10 denials are appealed it = $729
per day
• 52 weeks X 5 days – 20 days (vacation, etc.) =
240 working days
• 240 working days X $729 = 174,960 lost per
year
In conclusion
Why Compliance?
Presented by: Marisa Clauson, CPC
Focus Points From AAPC Seattle
Regional Conference
Presentation drafted from information provided
by:
Dan Schwebach and Katherine Abel with AAPC
Physician services
Michael D. Miscoe, PA, CPC
Agenda
• What Is Compliance?
• Elements of Effective Compliance Programs
• Legal Issues to Consider
What is Compliance ?
• It is Creating a Culture in your Organization:
– A Culture of commitment to Correctness
– A Culture of commitment to Consistency
– A Culture of commitment to Communication
Effective Compliance Programs
• Helps to prevent erroneous and fraudulent
claims submission resulting in :
– Minimizing billing mistakes
– Reducing chances of audits
– Avoiding conflicts with laws such as Anti-Kickback
and Self-Referral.
– Education
Effective Compliance Programs
The OIG has defined 7 elements
that should be included
1) Written Policies and Procedure
2) Designate a Compliance
Officer
3) Conduct Appropriate Training
& Education
4) Develop Open Lines of
Communication
5) Conduct Internal Monitoring
and Auditing
6) Respond to Detected Offenses
7) Enforce Disciplinary Standards
Legal Issues to Consider
Our Biggest Challenge??
KEEPING UP WITH ALL THE CHANGES!
• Coding (CPT, ICD-9/ICD-10, HCPC)
• Carrier specific rules with regards to codes
and policies.
What is Coding?
Coding Defined
• Coding is essentially a short hand method of
letting the payer know what happened by
providing alpha numeric codes to translate what
occurred during the encounter.
Correct Coding
• For a code to be correct it must be legally
accurate based on the code set we are given to
follow. It must not mislead the recipient into a
false belief of what services were provided.
What is Coding?
Legal Accuracy
• The representation made must be accurate in the eyes
of the recipient based upon their rules.
Legal Falsity
• must not only contain a misrepresentation, but the
misrepresentation must be material to the decision to
pay.
Coding Rules
• The individual coding rules (AMA/WHO/Payer)
establishes how a service must be represented so that
it is properly understood.
Fraud or Abuse That is the Question
The False Claims Act -31 U.S.C 3729 identifies that the
Government only has to prove that you were wrong not that there was intent to defraud the government.
Mistakes are not fraud as long as your interpretation
was reasonable as viewed by the court.
What If You Have Concerns Within Your
Own Organization?
• Keep your resources updated
• Address mistakes that are made
• Identify Concerns – prove them by using binding
guidance.
• Listen to alternate justifications objectively
• Seek formal guidance if needed
• Take the more conservative approach
• Document efforts to resolve