All posts by david

HIPAA and Mental Health: Answers to Top Doc Questions

Handling young patients who display mental health issues is a challenge for all providers.  While looking out for the patient is always the priority, providers often become confused about the rights and obligations that apply to handling a mental health crisis while complying with HIPAA’s privacy rule.

A good example of this dilemma is a call I received from an internal medicine physician treating a patient who was 18 years of age.  The patient had signed an authorization allowing her parents to be informed of her care.  The patient subsequently displayed disturbing mental health behavior which concerned the provider and family.  The parents wanted to alert the patient’s new out-of-state school and contacted a physician near the school to take over care of the patient.

The parents and treating physician believed they had reason to fear for the safety of the patient and others in her presence.

They asked me how they could share this information with the new physician and school since the patient refused to sign an authorization.  They also asked how they should respond to the patient stating she regretted her original authorization.

Dealing with young adults is a challenge for families and providers, as this is the age when mental health conditions often manifest. Providers must be aware of HIPAA requirements if they confront a similar scenario to the one described above:

1. Did the patient withdraw the authorization verbally by her statement? Once a patient provides an authorization, HIPAA gives individuals the right to revoke it, at any time. The revocation must be in writing, and is not effective until the covered entity receives it. In addition, a written revocation is not effective with respect to actions a covered entity took in reliance on a valid authorization.

2. Does HIPAA permit a doctor to contact a patient’s family or law enforcement if the doctor believes that the patient might hurt herself or someone else?  In addition to family, the HIPAA privacy rule permits a healthcare provider to disclose necessary information to law enforcement or other persons, when the provider believes the patient presents a serious and imminent threat to self or others.  The scope of this permission is described in a letter to the nation’s healthcare providers issued on January 15, 2013. When a healthcare provider believes in good faith that such a warning is necessary to prevent or lessen a serious and imminent threat to the health or safety of the patient or others, the privacy rule allows the provider, consistent with applicable law and standards of ethical conduct, to alert those persons whom the provider believes are reasonably able to prevent or lessen the threat. These provisions may be found in the privacy rule at 45 CFR § 164.512(j).

Under HIPAA provisions, a healthcare provider may disclose patient information to any persons who may reasonably be able to prevent or lessen the risk of harm. For example, if a mental health professional has a patient who has made a credible threat to inflict serious and imminent bodily harm on one or more persons, HIPAA permits the mental health professional to alert the police, a parent or other family member, school administrators, or campus police, and others who may be able to intervene to avert harm from the threat.  In addition to professional ethical standards, most states have laws and/or court decisions which address, and in many instances require, disclosure of patient information to prevent or lessen the risk of harm.

It’s not entirely clear whether these exceptions allow the new physician to receive information.  From my perspective, the parents should speak with the school to formulate an approach.  The institution likely has a medical clinic/provider that will treat the patient as a condition of remaining at the school.  Medical records could easily be transferred at that time and the current and new provider could also then freely speak.

There are not always clear answers under HIPAA, particularly when it comes to mental health issues.  However, all providers should be familiar with the law so as to protect the patient and those around him, as well as to protect their own practice from an unintended violation of HIPAA.

By: Ericka L. Adler

– Source: http://www.physicianspractice.com/law-malpractice/hipaa-and-mental-health-answers-top-doc-questions#sthash.vj7KWUms.dpuf

Yet another new auditor looking at Part B claims

Recovery Audit Contractors (RACs) may be about to take a break while CMS awards new contracts, but don’t rest on your laurels. CMS has handed out yet another auditor contract for a single auditor, known as a Supplemental Medical Review Contractor (SMRC) to do nationwide claims reviews for issues identified as being at risk for high dollar errors.

For Part B providers, the biggest target the new auditor, Strategic Health Solutions of Omaha, Neb., has identified is E/M claims billed with 99214 and 99215. Among the other targets are claims for hyperbaric oxygen therapy services, transformainal epidural injections (64479-64484), MRI of the lumbar spine (72148, 72149 and 72158) and some PET services (78451-78452, 78469 and 78494).

A full list of the open items for auditing by Strategic Health Services is available at http://www.strategichs.com/current-smrc-projects/.

The good news is, the SMRC will post its targets at the link above, which will all be referred by CMS based on issues identified by the OIG Work Plan and the Comprehensive Error Rate Testing (CERT) program, among other areas. In addition, this auditor is not being paid under a contingency fee arrangement, such as the RACs.

That may be where the good news stops. Strategic Health has posted copies of samples of the Additional Documentation Requests (ADRs) on its web site so you can see the type of letter the company will send. You get 30 days to respond, but unlike some auditors, Strategic Health Solutions will not reimburse you for the cost of copying and sending the documentation sought, as the company makes clear that this is part of the cost of doing business with Medicare.

It’s also not as easy to send the documentation. Strategic Health Solutions will accept it via esMD, the electronic submission of medical documentation tool available at www.cms.gov/esmd. You can also fax the documentation to a fax number in the letter. It can be mailed to the contractor either on paper copies or an encrypted CD in paper format. When you use the CD option, the password must be mailed separately.

Author: Scott Kraft

– Source: http://codapedia.com/article_688_Yet-another-new-auditor-looking-at-Part-B-claims.cfm#sthash.auAcPLd9.dpuf

Not Documented, Not Done: Medicare Myth or Rule?

After years of unchallenged recitation, the coding community has virtually canonized the phrase “not documented—not done” into coding scripture. But there are good reasons to question whether the now-famous epigram reflects an actual rule or whether it has simply taken on a life of its own like other “urban myths.”

In a 2008 article that retains relevance to coders today, Michael D. Miscoe, CPC, CHCC, noted that thorough documentation has become the de facto requirement to support claims for reimbursement by government and private payors. But an objective investigation into Medicare rules and their supporting statutes won’t support the common belief that “not documented—not done” is a legitimate rule, he argued in theJournal of Medical Practice Management.

By a strict interpretation of Medicare rules, lacking documentation does not render a medical service noncompensable. The Social Security Act itself mandates no payment “unless there has been furnished such information as may be necessary in order to determine the amounts due” (42 U.S.C. §139(e). A “clean” claim with the proper ICD-9 and HCPCS codes and appropriate fees fulfills this requirement.

Recent case law further supports this conclusion: The federal court ruled against the U.S. in a False Claims Act (U.S. ex rel Sikkenga v. Regence Blue Cross Blue Shield of Utah) case and reasserted that the Medicare statute only imposes an information requirement and “not a particular content requirement.”

Not So Fast!

A wary practice manager may want to hide this information from certain providers within his or her organization. Many group practices include physicians who reluctantly scrawl the briefest of “notes” for office encounters—sometimes inadequate for recording and communicating what happened during the visit. They sometimes hide behind a cavalier attitude summed up with, “ . . . I know what I did!”

Just because a strict interpretation of the law may extract some of the teeth from “not documented—not done,” that doesn’t reduce the need for good, accurate, and thorough documentation. Quality patient care includes maintaining a record that allows anyone with a legitimate reason to pick up the chart to understand the patient’s history of diagnosis and treatment.

Average physicians see thousands of patients each year. Regardless of claims to the contrary, a documentation-averse provider seldom possesses memory skills capable of recalling unwritten details years later.

Although the OIG’s own audit manual names documentation as only one of four types of “evidence” to determine whether a particular service was performed and properly reimbursed, why put auditors, your practice, and yourself through substantial anguish to prove your case? Doesn’t it make much more sense to document well?

Author: Codapedia Staff

– Source: http://codapedia.com/article_673_Not-Documented-Not-Done-Medicare-Myth-or-Rule.cfm#sthash.isMEL6dZ.dpuf

When You Send Patients to Collections

Question: My physicians would like me to retain patients after we send them to a collection agency; however, these patients must maintain a zero balance. Consequently, these patients must pay their copays, deductibles and coinsurances [at the time of service]. I would like to know if you are aware of other practices who have instituted a similar policy, and the result of [such a] policy. Could you share information on the ROI, labor hours associated with this [type of] policy? Additionally, the practice is pain management which means we serve a chronic population, and these patients will need frequent medication refills on a regular basis.

Answer: Being upfront with your patients is key in maintaining your patient balances. They need to understand that ignoring the monthly statements is not part of your practice’s policy. A good rule of thumb is to send three statements (one each month), and if the patient does not make a payment or set up a payment plan, then you should be sending a 15-day pay or go-to-collections letter. This can be a very simply stated letter that says if the practice does not receive payment, or the patient sets up a payment plan, then the result will be collections.

You will need to set up an easy process to monitor these letters. If you do not receive payment then placing patients into collections is your next step. A great collection agency is TransWorld. They have a high recovery percentage, much better than any other I’ve interacted with. The sooner you get patients into collections, the more likely you are to receive payment.

One thing that I’ve learned is that staff in the billing department are not bill collectors. They understand insurance and denials, not collecting monies from your patients. You really should leave that up to the professionals at the collection agency. They have been specifically trained in negotiating, communicating, and understanding the different types of debtors.

So, now you have placed a patient in collections, but they want to continue being treated at your practice. What do you do? Simply set them up on a payment plan. Contact your collections agency and tell them the patient wants to return to your practice for more treatment, and you have agreed upon a specific payment amount that they will pay weekly, bimonthly, or monthly. (See Payment Plan Example.)

I know that it is difficult at times to talk money with patients, but by setting the expectation up front, you are more likely to collect your copays, coinsurances, and deductibles from patients. Being consistent and following your own set policies will also show patients that ignoring your policies is not an option for them. If you tend to pick and choose who you impose your policies on, you will have a much more difficult time collecting patient balances

By: P.J. Cloud-Moulds

– Source: http://www.physicianspractice.com/medical-billing-collections/when-you-send-patients-collections#sthash.D9UtpVMb.dpuf

Three Ways to Increase Physician Income

Increasing revenue and decreasing expenses in a medical practice are often misguided goals. Each is a proxy for the more effective goal of increasing net income, the difference between actual receipts and expenses, e.g., the money you actually get to keep. Here are three principles you can use to substantially and sustainably increase net income.
1. Plug the holes
Earning money can be a bad thing, if you don’t collect it. Providing services incurs expenses. If you never actually receive payment for those services, you have lost money. Revenue holes in a medical practice are regularly the result of failure to:
• Confirm insurance coverage
• Obtain prior approval for procedures
• Collect copays at the time services are provided
• Collect accurate and complete insurance information
• Adequately explain to the patient his financial obligations (Most offices have patients sign an acknowledgment of responsibility, but most patients do not read it and dollar amounts are seldom even estimated.)
• Take advantage of opportunities, through affiliation not buyouts, for better reimbursement schedules
Other revenue holes result from not getting it right the first time:
• Re-filing insurance claims because of errors and omissions in the original submission
• Choosing not to re-file short-paid claims because it is not worth the costs
• Re-filing short-paid claims for an increased payment that does not exceed the cost of the extra work
• Multiple billings and subsequent write-offs of patient balances
2. Reduce operational waste
Operational waste comes in the form of wasted money and wasted effort.
Wasted money comes from spending more than is necessary to get the required result. It is not a function of value, not price: An inadequate product or service is expensive at any price.
Any activity that does not affirmatively serve the objectives of the practice is waste. It can, therefore, be eliminated without negative consequences. The rule of thumb is that 30 percent of the work in any office, medical or otherwise, adds no value. Identify it, eliminate it, and increase the practice’s productive capacity by 30 percent.
Reduced operating costs are a natural side effect of reducing operational waste. The simplistic goal of reducing expenses often impairs both productivity and profitability.
3. Increase revenue
Increasing revenue is the last in the list because that is where it belongs chronologically. It is the best use of practice resources only after the holes have been plugged and operational waste has been minimized.
The practice can use its increased operational capacity to increase revenue by seeing more patients. It can also leverage that productivity by applying the additional capacity to more lucrative services.
More expensive services are not necessarily more lucrative. The net income attributable to a service is a function of both the difference between receipts and expenses, and volume. A high margin service with a small market often yields less eventual net income that a low margin/high volume service.
Be cautious about adding products and services not directly adjacent to current offerings. These always carry higher startup and operating costs because the practice is not already set up for them.
In improving financial performance, the real goal is to increase net income. Do not be distracted by popular proxies.

By: Carol Stryker

– Source: http://www.physicianspractice.com/physician-compensation/three-ways-increase-physician-income#sthash.XVmevDhC.dpuf

ICD-10 Budgeting: What are some of the costs involved?

There are estimates of how much an ICD-10 conversion will cost. But you won’t know until you start adding up the numbers for your medical practice.
The obvious places to start are in IT and medical coding. Next come project and revenue management. Each area requires resources — time and money — to accommodate.
Start adding up:
• Software and hardware
o In house and vendor modifications
o Upgrades
o New software, systems and equipment
• Education
o Coder training
o Clinician education
o Awareness raising
• Testing related costs
• Staff time needed for:
o Implementation planning
o Training
o Testing
o Vendor management
• Temp staffing to assist with extra work resulting from:
o Decreased coding productivity
o Billing backlogs
o Claims denial and rejection management
o IT work on upgrades and systems
o Lost time during training
• Consulting services
• Forms and reports
o Redesign
o Printing costs
• Data conversion
• Dual coding
o Added time
o Maintaining data collection
o Analyzing data

-source: http://www.icd10watch.com/blog/icd-10-budgeting-what-are-some-costs-involved

Family Planning Modifier; NPP Billing; Coding for Multiple Services

Family Planning Modifier 
Q: We get denials when we use the 96372 code for the administration of Depo-Provera. Can we just use a 99211 instead?A: You could be getting denials on these because you are not using the family planning modifier, which is required by some payers. The provider manual for one payer states that “CPT procedure code 96372 (therapeutic, prophylactic, or diagnostic injection; subcutaneous or intramuscular) was a new code effective with date of service January 1, 2009. The FP (family planning) modifier is allowed with this code. However, some claims have been denied with a denial code that states ‘Claim includes family planning diagnosis and no family planning procedure.’ Please resubmit with family planning procedure/modifier or correct the diagnosis.” Watch those Level II HCPCS modifiers.

NPP Billing
Q: If a NPP sees a new problem on one Medicare patient and bills under the NPP’s own ID, then continues management on the next visit following the physician’s plan outlined in the previous visit, would the billing be incident-to in the second visit but not the first visit? Is it OK to go back and forth depending on the situation on the same day?
A: Yes. Although the regulatory side would not express it that way, (that it’s OK to go back and forth on the same day), that is what the regulations come down to if you have the requisite oversight in the incident-to version.
For a new problem, use the NPP NPI and direct bill. For an established problem with oversight, use the MD NPI and bill in the physician’s name. Good distinction!
There has been discussion among carriers and regulators that once a NPP is using his own number, they should not have to pay for the incident-to version, but as long as the incident-to policy is in effect, what you describe is allowed.
Coding for Multiple Services
Q: When I bill an E&M visit along with an AWV, I have been getting some patient complaints about the two charges — even though Medicare patients don’t pay anything on the AWV. Complaints worsen when I bill a regular 99395 or 99396 to a commercial insurer in addition to an E&M office visit. I thought this was allowed.

Q: What am I missing here? I’m really getting some upset patients.
A: If you are billing two codes because you are performing two distinct services then you are doing this correctly. But don’t forget to include the patient in the discussion.
It is really most efficient to combine an AWV for a Medicare patient with a scheduled chronic disease follow-up visit. In fact, some Medicare patients seem disturbed when they show up for an AWV and discover that there is no exam component. Patients like to have someone “kick all the tires” every once in a while.
But to avoid any confusion, be sure to state upfront what the nature of the visit is. State that two services are being provided. Tell the patient, “You are here today for the AWV and management/assessment of X.”
You will of course document the history, exam, and decision making associated with the problem and outline the elements addressed for the AWV.
If you communicate this well during the encounter you will have fewer problems later. Some practices design work flows so that office or nursing staff participates in “prepping” the patient for the “what we are doing today” conversation. But in the end, the provider really should confirm or restate the services that will be provided.
This can be more difficult for commercial plans when using the 99381-99397 preventive codes along with an E&M. Not all plans cover both codes on the same day and this will surely get a rise out of patients.
In this case, it is more important to check the patient’s coverage when the visit seems likely to be one in which multiple services will be provided. But again, the key to avoiding the phone calls and upsets is communicating along the way what you are doing.
The trickiest visit of this sort is when it starts as a well visit only, and a finding is made either on examination or as a result of the ROS which then requires significant problem management. In this case, a problem crops up unexpectedly and no one — neither you nor the patient — was expecting two types of codes.
Once more, the best course is likely to communicate with the patient that you need to account for the tests ordered and work done and that there will be a problem-management component to this visit.
A best practice is to post a policy or guide to combination visits somewhere in the office where patients can see it. No surprises is the goal.
Modifiers and Bundled Codes
Q: I recently started working at an orthopedic practice and I am working on denied claims. I have come across several claims that have been billed with CPT codes 29881 and 29877-59. Different payers are denying the claims stating the payment for 29877 is included with the primary code, even though modifier 59 was used. Is this correct?
A: The first place you should refer to is to CCI. You’ll see that 29887 is a Column II component of 29881. The modifier indicator is “0” — which tells you that no modifier will break the edit.
The modifier you would likely have used is 59, but even that won’t work here. Modifier 59 will break bundling edits in some cases, when indicated by the CCI tables, but it isn’t fairy dust!

By: Bill Dacey

-source: http://www.physicianspractice.com/icd-9/family-planning-modifier-npp-billing-coding-multiple-services

Why traditional billing needs to change

We’re all very much aware — some might feel painfully aware — that payer models are transitioning us away from fee-for-service to a new era in which reimbursement is based on outcomes and provided value. As a result of that transition, effective revenue cycle management (RCM) in the near future will bear little resemblance to traditional billing practices.

That’s because traditional billing is rooted in the fee-for-service model in which information, originally paper-based, advanced directly from the point of care to the back office. Doctors saw patients and made records of procedures. Those records went to the back office for coding and the preparation of bills for services rendered. Billing volume corresponded to clinical transaction volume.

While simple, that method of revenue cycle management had plenty of challenges, most of them resulting when patient information collection and clinical care separated from billing and from the manual processes that linked them — error-inducing workflow that contributed to claim delays and denials. Even as practices moved toward the electronification of patient data by adopting electronic health record systems, there was typically no automated flow of information between a practice’s EHR and RCM systems to address these issues.

That situation began a course correction recently with a new generation of integrated EHR/RCM solutions that deliver more accurate information to the payer for faster, cleaner claims and fewer denials. As consumers take on a larger share of payment responsibilities, EHR/RCM integration has also made it possible to minimize “sticker shock” and improve patient satisfaction by identifying patient financial responsibilities at check-in.

Those advantages in leveraging data flow are just the start, and the move toward clinically driven RCM — in which data captured electronically at the point of clinical decision-making drives revenue cycle management — will provide a solid foundation to accommodate the new payer reimbursement models. Before that can happen, practices will need to move beyond older RCM approaches that merely document services and then assign fees to those services.

Identifying and closing care gaps, managing a patient population within a shared-risk program and contributing to improved care delivery within a region are major initiatives that shift the emphasis from clinical transactions toward population health. Participating in revenue streams associated with that shift will require a broad emphasis on clinically driven RCM. For example, systems will need to identify diabetics who haven’t been in for a foot exam as well as those who have. Practices must also engage patients with monitoring and reminders outside of office visits, and translate that activity into the revenue cycle by effectively managing consumer populations as never before.

The reason is simple: Future revenue streams will reward physicians in part for healthy patients who do not have to come in for frequent treatment along with those who do, as financial performance becomes increasingly tied to the health of the population of healthcare consumers the provider serves.

While it remains to be seen precisely which of the new payer models will eventually dominate in the move away from fee-for-service billing, all emerging models point the way toward rendering traditional billing approaches ineffective. Practices at the forefront of clinically driven RCM today are not only reaping benefits in immediate improvements to billing and patient satisfaction; they are also among those that are best prepared for the new era in value-based reimbursements.

By : Tee Green – CEO of Greenway Health

Why cardiologists’ income is dropping

Following four years of steady increases, heart doctors’ compensation dropped by nearly 8 percent.
That’s according to MedAxiom’s 2014 Provider Compensation & Productivity Report, which also found that cardiologists’ productivity dipped by nearly 5 percent.
The pace of transition from private practice into integrated models — either through hospital employment or professional services agreements — slowed down in 2013, which partially explains the compensation pullback, according to MedAxiom.
[See also: Women doctors on the forefront of care, innovation.]
Physicians in an integrated setting, in fact, continue to out-earn their private peers by more than 30 percent. Indeed, those independent doctors saw overall compensation drop almost 9 percent.
Contrary to the earning figures, however, private physicians in 2013 out-produced their integrated peers by almost 6 percent.
Geography continues to play a role in compensation as well. Physicians in the Midwest hold the top compensation spot ($559,004 median) with those in the Northeast at the bottom ($460,815 median).
Changes to the business
It’s not bad news for everyone. Interventional cardiologists, for instance, still ruled the day, pulling in a median of $558,824.
The cardiology mix of business continues to change as well, but unlike in years past where the trends were all downward, physicians achieved varied results in 2013.
New patients per cardiologist, for instance, increased slightly as did the total number of cognitive encounters. The ratio of work performed in the hospital versus the outpatient setting inched back up for a second straight year — somewhat contradicting conventional wisdom on the migration of inpatient to outpatient nationally.
For other key volumes like catheterizations and Percutaneous Cardiac Interventions, the survey found that declines have hit bottom and are beginning to stabilize, while non-invasive imaging saw further erosion.
MedAxiom’s research is based on data submitted by 134 cardiology programs representing 2,554 cardiologists across the country. Of those responding groups, 97 are integrated and 37 remain private practices.

Author : Frank Irving

Selective catheterization of both renal arteries

Selective renal angiography (left lower renal artery) (Photo credit: Wikipedia)

Coding Selective catheterization of both renal arteries in medical coding
Renal arteries arise directly from the aorta. Renal arteries form a separate vascular family. Vascular families are coded always separately. When we code catheter placement code for renal arteries, we have separate CPT® codes. Selective catheterization of both renal arteries have a single CPT® code. This CPT® code includes everything from taking access to placing the catheter in the renal artery. These are actually new codes used mainly for renal artery catheterization.

CPT® codes for selective catheterization of both renal arteries
The CPT® codes used for coding renal arteries are 36251, 36252, 36253 and 36254. These CPT® codes include all the minor procedure required for catheter placement. The CPT® codes are allocated on the basis of branches of renal artery. So, the main renal artery and it branches have specific CPT® code. The main renal artery is stated as First order renal artery and its branches as second order. We don’t have the third order or any other code for higher order arteries. The main renal artery is given selective catheter placement code and it branches are given superselective catheter placement codes. The arteries of second order or of higher level will be coded second order CPT® Code. The CPT® codes used for first order renal arteries are 36251 and 36252. The CPT® codes used for second order or higher level of renal arteries are 36253 and 36254.
Procedures include in Selective catheterization of both renal arteries
The abdominal aortogram CPT® Code 75625 is included in selective catheterization of renal arteries. The code description states that it includes flush aortogram or abdominal aortogram. Also, the Fluoroscopic or ultrasound guidance codes are included in these CPT® codes. Supervision and interpretation codes are also include in these procedures. So, never code following codes with codes from 36251-36254.
75625- Abdominal aortogram
76937- Ultrasound guidance
77001-Fluoroscopic guidance
Also, conscious sedation is included in these CPT® codes. So, we do not codes conscious sedation separately with CPT® codes from 36251-36254.

Unilateral and bilateral selective catheterization of both renal arteries
The study which includes only selective catheterization of one side of main renal artery is code as 36251. Since, we have renal arteries on both the sides the CPT® codes are divided as unilateral and bilateral. Same, when the study of both sides of main renal arteries is done, the code used is 36252. Never, use a 50 modifier when we are coding these CPT® codes. This modifier denotes bilateral procedure. We have separate code for bilateral procedure so we can avoid using 50 modifier.
Coding for selective catheterization of both renal arteries branches
The renal arteries branches have separate code, 36253 and 36254. These branches come under second order catheterization codes. These codes are similar to CPT® codes for main renal arteries. These codes are used for any higher order or level of arteries. We cannot use first order codes with second order CPT® codes. The second order CPT® codes include the first order code. This is one of the rules for coding vascular families. Second order catheter placement is also stated as superselective catheter placement. They also have separate codes for unilateral and bilateral renal arteries. For unilateral second order renal artery catheter placement we use 36253 CPT® code. For bilateral second order renal artery we use 36254 CPT® code. Also, these procedures include all the minor procedures which are included with the first order CPT® codes.
Hope, now you can easily code catheter placement codes for renal arteries. Please share if you liked the article.

Author: jitendra az

- Source : http://www.codapedia.com/article_731_Selective-catheterization-of-both-renal-arteries.cfm#sthash.sAMD9QFJ.dpuf