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January 2011 Your Opinion Matters AAPC National Advisory Board Plus: Vertebroplasty • ED MDM • Hospital Work Plan • 2011 OPPS • COPD contents 14 26 44 [contents] January 2011 In Every Issue 7Letter from the President and CEO 8 Coding News 10 Letters to the Editor 13 Letter from Member Leadership Special Features 13 Features 14 Are You Aboard the EHR Revolution? Stephen C. Spain, MD, FAAFP, CPC 16 Don’t Let PHI Become TMI Robert A. Pelaia, Esq., CPC 20 Health Care Reform: The Assault on Waste, Fraud, and Abuse David Behinfar, JD, LLM, CHC, CIPP 22 Accurately Score MDM in the ED Sarah Todt, RN, CPC, CEDC 26 Vertebroplasty Is Not Vertebral Augmentation G. John Verhovshek, MA, CPC 30 Prepare for 2011 OPPS Final Rule Denise Williams, RN, CPC, CPC-H 42 Road Map to ICD-10: Get on Board for the Next 1000 Days Angela “Annie” Boynton, BS, RHIT, CPC, CPC-P, CPC-H, CPC-I, CCS, CCS-P 44 COPD: Frequently Used, Frequently Misreported Jill M. Young, CPC, CEDC, CIMC Online Test Yourself – Earn 1 CEU go to www.aapc.com/resources/ publications/coding-edge/archive.aspx 18AAPCCA: Make a Lasting First Impression Melissa Brown, RHIA, CPC, CPC-I, CFPC 49Acquire Coding Instructor Skills Geanetta Johnson Agbona, CPC People 37Repair Relationships: Approach Providers from Their Viewpoint Lynn S. Berry, PT, CPC 38 Newly Credentialed Members 50 Minute with a Member Coming Up ENT 46 Evaluate Your Performance When ED Leveling Sleep Medicine Jim Strafford, CEDC, MCS-P Subpoenas and Search Warrants On the Cover: Every fall, AAPC’s National Advisory Board (NAB) meets in Salt Lake City to represent members throughout the country. See the NAB president’s message for more. Cover photo taken by Rachel Minson. Vascular Surgery Remote Billers www.aapc.com January 2011 3 Serving 100,000 Members – Including You Serving AAPC Members The membership of AAPC, and subsequently the readership of Coding Edge, is quite varied. To ensure we are providing education to each segment of our audience, in every issue we will publish at least one article on each of three levels: apprentice, professional and expert. The articles will be identified with a small bar denoting knowledge level: APPRENTICE Beginning coding with common technologies, basic anatomy and physiology, and using standard code guidelines and regulations. PROFESSIONAL More sophisticated issues including code sequencing, modifier use, and new technologies. EXPERT Advanced anatomy and physiology, procedures and disorders for which codes or official rules do not exist, appeals, and payer specific variables. January 2011 Chairman Reed E. Pew [email protected] President and CEO Deborah Grider, CPC, CPC-I, CPC-H, CPC-P, COBGC, CPMA, CEMC, CPCD, CCS-P [email protected] Vice President of Marketing Bevan Erickson [email protected] Vice President, Business Development Rhonda Buckholtz, CPC, CPC-I, CPMA, CGSC, CPEDC, COBGC, CENTC [email protected] Directors, Pre-Certification Education and Exams advertising index Raemarie Jimenez, CPC, CPMA, CPC-I, CANPC, CRHC [email protected] Katherine Abel, CPC, CPMA, CPC-I, CMRS [email protected] American Medical Association .............p. 33 www.amabookstore.com Vice President, Post Certification Education American Society of Health Informatics Managers . ....................... p. 5 http://ashim.org Director of Editorial Development David Maxwell, MBA [email protected] John Verhovshek, MA, CPC [email protected] Directors, Member Services Brad Ericson, MPC, CPC, COSC [email protected] Danielle Montgomery [email protected] The Coding Institute, LLC ................... p. 36 www.supercoder.com/guides The Coding Institute, LLC ................... p. 41 www.SuperCoder.com Senior Editors Michelle A. Dick, BS [email protected] Production Artist CodingWebU . ...................................... p. 51 www.CodingWebU.com Contexo Media .................................... p. 6 www.contexomedia.com HeathcareBusinessOffice LLC ............ p. 25 www.HealthcareBusinessOffice.com Ingenix . ............................................... p. 12 www.shopingenix.com Medicare Learning Network® (MLN)...... p. 11 Official CMS Information for Medicare Fee-For-Service Providers www.cms.gov/MLNGenInfo NAMAS/DoctorsManagement ............ p. 52 www.NAMAS-auditing.com ZHealth Publishing .............................. p. 2 www.zhealthpublishing.com Renee Dustman, BS [email protected] Tina M. Smith, AAS Graphics [email protected] Advertising/Exhibiting Sales Manager Jamie Zayach, BS [email protected] Address all inquires, contributions and change of address notices to: Coding Edge PO Box 704004 Salt Lake City, UT 84170 (800) 626-CODE (2633) © 2010 AAPC, Coding Edge. All rights reserved. Reproduction in whole or in part, in any form, without written permission from the AAPC is prohibited. Contributions are welcome. Coding Edge is a publication for members of the AAPC. Statements of fact or opinion are the responsibility of the authors alone and do not represent an opinion of AAPC, or sponsoring organizations. Current Procedural Terminology (CPT®) is copyright 2010 American Medical Association. All Rights Reserved. No fee schedules, basic units, relative values or related listings are included in CPT®. The AMA assumes no liability for the data contained herein. CPC®, CPC-H®, CPC-P®, and CIRCC® are registered trademarks of AAPC. Volume 22 Number 1 January 1, 2011 Coding Edge (ISSN: 1941-5036) is published monthly by AAPC, 2480 South 3850 West, Suite B. Salt Lake City, Utah, 84120, for its paid members. Periodical postage paid at the Salt Lake City mailing office and others. POSTMASTER: Send address changes to: Coding Edge c/o AAPC, 2480 South 3850 West, Suite B, Salt Lake City, UT, 84120. 4 AAPC Coding Edge HEALTHiITiProfessional ONLINE TRAINING PROGRAM Job-proof your skills with Health IT Training ASHIMTM Health Information Technology Professional is an online course that gives you the flexibility to learn at your own pace and from the comfort of your home or office. ASHIM programs are specifically designed to give you the skills you need for a career in today's fastest growing field: Health Information Technology. • • • Expertise in the new right-now technology can make you irreplaceable Study online at any time and at your own pace Be prepared to pass the rigorous Certified Health Informatics Systems Professional (CHISP™) exam In 12 weeks you can be on your way to a new career, higher pay or that promotion you've been waiting for. Students entering the program with previous clinical experience (i.e. CPC®, CCS, and RN) may work in health IT job roles such as: Clinical Software Trainers, EHR Implementation Specialists, Health Systems Integration Professionals, Practice Work Flow Analysts, and more. ashim.org 877.263.1261 American Society of Health Informatics Managers™ 2480 South 3850 West, Suite D Salt Lake City, UT 84120 61 Introducing the new and improved CodeItRightOnline, the most user-friendly online medical coding and billing application available in the market today. Subscribe today and you’ll be able to take advantage of the following features and benefits: A more robust and intuitive CodeItRightOnline Search CPT® codes, HCPCS Level II codes and ICD-9-CM codes Full access to ICD-10-CM/PCS code sets and descriptions NCCI Edits Validator™ – keep codes clean to avoid denials Automatic code updates Personalization – customize your own searches, notes, fee schedules and more Click-A-Dex™ – a tool for easier index searching Build-A-Code™ – find the appropriate code even with limited information More Medicare contractor information Medicare providers (with contact information) Medicare PQRI Information Hundreds of new illustrations ABC codes and descriptions and much more. For more information, please call us at 1-800-334-5724 or visit www.CodeItRightOnline.com. Contexo Media ✉ P.O. Box 25128 Salt Lake City, UT 84125-0128 Fax 801.365.0710 ☎ PHone 800.334.5724 onLine www.codingbooks.com 18271 letter from the president and CEO Face ICD-10 Challenges Together While watching my favorite football team, the Indianapolis Colts, the other night, I thought about how it’s important for teams to follow their quarterback’s instructions when playing the game. I watched Peyton Manning call the plays and how the entire team worked side by side with him—and, of course, they won the game. I’m confident that by Super Bowl XLVII, we will be ready to block and tackle any obstacles we face during the ICD-10 transition Oct. 1, 2013. All we have to do is work together as a team—a very large team with over 100,000 AAPC members—and listen for when the plays are called. Implementation Kick-off It’s 2011, and it’s time to get serious about the national implementation of ICD-10. Providers, hospitals, health plans, and anyone who is mandated under Health Insurance Portability and Accountability Act (HIPAA) must comply with the Oct. 1, 2013 implementation deadline. For those of you who are involved in your organization’s ICD-10 implementation process, now is the time to become familiar with how the codes translate to documentation and how they map from ICD-9-CM to ICD-10-CM. These are critical steps. Learn these steps and incorporate them into your practice so you will be ready for this important transition. Wait for the Final Code Set Release As for learning the new code sets, AAPC is recommending coders wait until the fourth quarter of 2012 or the beginning of 2013. Why wait when other organizations are saying the time is now? AAPC doesn’t believe creating a sense of urgency to learn ICD-10 code sets is a good play. The ICD-10 code sets and guidelines are still in draft format until the codes are finalized and there is a code “freeze.” The last regular update will be Oct. 1, 2011 for ICD-9-CM and ICD-10-CM code sets. Only limited updates will be made to capture new technology and diseases for ICD-9-CM and ICD-10 in 2012. In 2013, ICD-9-CM will not be updated and only limited updates will be made to ICD-10. Regular ICD-10 updates will resume Oct. 1, 2014, at which point ICD-9-CM will no longer be used. It simply doesn’t make sense to spend time, effort, and money on learning codes and guidelines that might change. If you only need to learn the codes, be patient and wait for the right time. Here’s the Game Plan AAPC plans to continue in 2011 to offer on-site boot camps and distance learning modules for anyone involved in the implementation process. These courses are designed to help a medical practice and/ or health plan implement ICD-10 within their organization. We also have 15-minute webinars for providers and managers to explain what elements go into ICD-10 planning and provide guidance on where to begin. In 2012, AAPC will begin to offer code set training on both ICD-10 CM and ICD10-PCS (for inpatient coders) in various venues including boot camps, workshops, conferences, distance learning, and webinars. There will be general and specialtyspecific opportunities for education. In 2013, boot camps, workshops, distance learning, and webinars will continue and there also will be up to 10 regional conferences across the country dedicated to ICD-10 training. We think this will provide everyone with the training necessary to move ahead. Train for the Big Day Don’t wait to learn about ICD-10. Visit AAPC’s website at www.aapc.com/ICD-10 to read ICD-10 articles and information. Start the implementation process in your organization right away. You can log into your member area and use the benchmark tracker to track your organization’s imple- mentation progress. Begin code set training in 2012-2013. Get the right training at the right time so you will be ready to score when the big day comes in 2013. I hope you all had a wonderful holiday season and that we all have a happy and productive new year. Until next month, my friends… Sincerely, Deborah Grider, CPC, CPC-H, CPC-I, CPC-P, CPMA, CEMC, COBGC, CPCD, CCS-P AAPC President and CEO www.aapc.com January 2011 7 coding news coding news AMA Releases 2011 CPT® Errata With your new 2011 CPT® in your hand, you’re ready and anxious to start coding this year’s procedures. Before you get into the thick of coding claims, however, update your book with new information from the American Medical Association (AMA). Evaluation and Management (E/M) Prolonged Services The parenthetical note for add-on code 8 AAPC Coding Edge 99356 Prolonged physician service in the inpatient setting, requiring unit/floor time beyond the usual service; first hour (List separately in addition to code for inpatient Evaluation and Management service) splits the 99221-99233 code range to no longer include 99224-99226 as subsequent observation codes. Its parenthetical note now reads “(Use 99356 in conjunction with 99221-99223, 99231-99233, 99251-99255, 99304-99310, 90822, 90829).” Surgery Bone Marrow or Stem Cell Services/Procedure codes 38205 and 38240 and parenthetical note following 38230 are corrected to revise the erroneous term “allogenic,” which now reads “allogeneic.” In the Digestive System, Biliary Tract, surgery section, the parenthetical note, “(For radiological supervision and interpretation, use 75989),” following 47490 Cholecystostomy, percutaneous, complete procedure, including imaging guidance, catheter placement, cholecystogram when performed, and radiological supervision and interpretation, is deleted because it is now a bundled service. More Parenthetical Note Revisions There are several other changes to CPT® parenthetical notes. They are: • Revise the parenthetical note following code 76513 referencing deleted code 0187T and include 92132. • Revise the parenthetical note following 82013 to “gastric acid” not “acid gastric.” • Delete the parenthetical note preceding code 90862 that references deleted codes 0160T, 0161T. • Delete the parenthetical note following the Neurology and Neuromuscular Procedures guidelines referencing deleted codes 0160T, 0161T. • Revise the third parenthetical note following 95806 to include the term “a minimum.” Appendix B AMA has made a few changes to Appendix B. Most notable is that 99365 has been rescinded and is deleted from Appendix B. Other changes to Appendix B are the reference to deleted code 91000 should be moved to follow code 90868 rather than 90670; and 93268 is revised to retain the phrase “24-hour attended monitoring” in the code descriptor. Index In the Index, under Atherectomy, add “or Percuatenous” to the “Open” subheading and delete duplicate references: Femoral … 37225, 37227 Popliteal … 37225, 37227 Tibioperoneal … 37233, 37235 Other changes to the Index are: Evaluation and Management • Work-Related and/or Medical Disability - Delete reference code 99450 and replace with 99455. CT Scan/Guidance • Visceral Tissue Ablation - Delete reference code 76362 and replace with 77013. Urethra • Pressure Profile - Delete reference code 51772 and replace with 51727, 51729. Short Descriptors Short Descriptors 22900, 22901, 74176, 74177, 74178, and 99218 have been revised. See the complete AMA errata “Corrections Document—CPT® 2011” located at www.ama-assn.org/ama1/pub/ upload/mm/362/cpt-2011-corrections.pdf for details. 2011 NATIONAL CONFERENCE LONG BEACH, CA APRIL 3 - 6 LO N G B E A C H - C A L I F O R N I A REGiSTER BY JANUARY 14! E V A S ! EARLy BIRd PRICE: $695 FOR MEMBERs 0 0 1 $ April 3 - 6 | Up to 18 CEUs | 70+ sessions www.aapc.com/longbeach PHOTOS COURTESY OF DESTiNATiONS MAGAziNE letters to the editor Letters to the Editor More on Changing the Code Complex Catheter Coding, Simplified I would like to “put my two cents in” regarding the articles “Just Change the Code” by Simone Tessitore, CPC, COBGC, (May 2010) and “Don’t Change the Code” by Pam Brooks, CPC, PCS, (November 2010) on requests to change codes. From the viewpoint of not only a coder but also a billing and reimbursement specialist, I can easily identify with the dilemma of dealing with the treatment of coding discrepancies that result in claim denials. Frequently, our patient account managers would get angry calls from patients telling us about receiving a bill because a claim was coded incorrectly. As an off-site billing service, we did not have professional coders on staff, and had to essentially rely on information entered by the provider on the encounter forms as we processed the data into our practice management system. Altering codes with the sole intent to obtain or increase coverage or to benefit patients is clearly fraud. In fact, many billing software programs have hooks in them to prevent code changes when resubmitting the same claim. For example, our billing software allowed the changing of an ICD-9-CM code in the event of a later confirmed disease, but it was programmed to not permit changing of a CPT® code. Besides getting requests from patients to change codes, we’d also get requests from doctors, and yes, even suggestions from payers to resubmit claims with different CPT® codes. I and my staff were caught between a rock and a hard place with these situations, and the conflict in client communication would sometimes cause the relationship to be severed—for the better, in my opinion, especially when considering AAPC’s motto of “Upholding a Higher Standard.” Regarding medical bills being negotiable, this is only true from the standpoint that if a doctor has a self-paying patient or one who is on a non-contracted (fee-for-service) plan, the patient may be able to do some research based on the CPT® or HCPCS Level II code and see what the Medicare rate is for that service and use that as a guideline in the attempt to get a balance reduced. For example, if a physician’s fee is $900 for a service which the payment schedule on the corresponding CPT® code indicates $637.22, perhaps the patient could offer $650 as a settlement— however, the code itself is not negotiable! Thank you so much for publishing the article entitled “In the Journey Through Vessels, Code Destinations, Not Waypoints,” by Kimberly Engel, CPC, in the November 2010 edition of Coding Edge. I have never had the pleasure of reading such a clear explanation about how to assign codes for catheter placement. Ms. Engel’s mention that there are 60,000 miles of vessels in the human body (2.5 times around the equator) truly provides a visual of just how complex coding catheter placements can be. Thank you for publishing Ms. Engel’s article. I also express my appreciation to AAPC staff and an author of a recent Coding Snapshot article who helped me understand an ICD-10-CM code assignment. As a coding instructor and textbook author, I just had to “get it” and everyone was so patient with my persistence when attempting to understand. Thank you! Ken Camilleis, CPC, CPC-I, CMRS 10 AAPC Coding Edge Michelle A. Green, MPS, RHIA, FAHIMA, CPC SUNY Distinguished Teaching Professor Alfred State College, Alfred, N.Y. Stay Current for Accurate Coding I want to commend AAPC’s Coding Edge for the timeliness of articles. On more than one occasion I have found and used articles for my clients exactly when I needed them. It is uncanny how these articles seem to appear when I am in need of a reference. Thank you for quality work. Jules Enatsky, RT, BSN, CPC-H J.A. Thomas & Associates Please send your letters to the editor to: [email protected]. R Official CMS Information for Medicare Fee-For-Service Providers Get Accurate Answers About Medicare Reimbursement. You can find plenty of answers to your Medicare questions. Find the accurate ones from the Centers for Medicare & Medicaid Services’ (CMS) Medicare Learning Network® (MLN). Get nationally consistent, accurate, timely and free information that will help providers correctly submit claims the first time. Please visit our website today. http://www.cms.gov/MLNGenInfo letter from member leadership COVER AAPC Is All About Members This month’s Coding Edge cover photo of AAPC’s National Advisory Board (NAB) isn’t to glorify the NAB, it is to remind you AAPC is here on your behalf, helping you and your profession chart a course through the stormy seas of the future. As the NAB—and as coders—we never forget what we are here for. We’re here to represent you. NAB includes 16 member coders serving two years who are appointed by AAPC to represent eight geographical regions of the United States and four officers elected by the NAB including president, presidentelect, member relations, and secretary. Every fall, the NAB meets in Utah for several days to share what we’re hearing from our colleagues, seeing in the field, and perceiving about the future. This meeting is our annual culmination of monthly phone meetings, dozens of phone calls, and countless e-mail messages. Coders are not shy, and the organization not only learns from when you contact AAPC, but from when we and the AAPC Chapter Association (AAPCCA), an independent board, visit chapters. We learn what each area faces and we consider what is pertinent to coders’ success. Look Ahead to the New Year A new NAB will take the helm this year at the AAPC National Conference, April 3-6, in Long Beach, Calif. The incoming members work in the field, and they see the daily ups and downs all members face. They are aware of the inevitable changes ICD-10, electronic health records (EHRs), and health reform will bring; and they know it’s essential to roll with the punches and provide colleagues with the resources to not only help make coding grow professionally, but be vital to the changes afoot. Prepare for the Future As 2011 starts, we all face an uncertain future; but it is no more uncertain than in the past. This upcoming year promises to be exciting for AAPC. More ICD-10 training will be available, helping you prepare for October 2013 when the nation stops using ICD-9. ICD-10 will change everything we do. Don’t wait until the last minute to take advantage of this training, as your practice or facility inevitably will look to you for guidance once its clear new software won’t solve all of the implementation problems. AAPC promises more interesting and applicable educational programs for various facets of coding. Plus, we are expanding our training and certification in compliance as health reform and federal budget tightening means more scrutiny not only by Medicare, but by state programs and commercial payers. We need to keep looking forward without forgetting what is best for coders. The NAB and AAPC Is You We see what you see. We hear what you are telling us about your day-to-day victories, frustrations, and fears. We want you to know that a group of coders is helping to keep AAPC and the field of coding forward-moving and afloat. Best wishes, Terrance C. Leone, CPC, CPC-P, CPC-I, CIRCC President, National Advisory Board NAB on Front Cover: Back row: Terri Scales, CPC, CCS-P; Janice G. Jacobs, CPA, CPC, CCS; Linda Farrington, CPC, CPC-I; Trina Cuppett, CPC, CPC-H Third row: David B. Dunn, MD, FACS, CIRCC, CPC-Cardio, CPC-H, CCS, RCC; Cynthia Stahl, CPC, CPC-H, CCS-P; Robert A. Pelaia, Esq., CPC; Julie A. Leu, BS, CPC, CPC-I; Julia Croly, CPC, CPC-P, CPC-I; Jacqueline J. Stack, AAB, CPC, CPC-I, CEMC, CFPC, CIMC, CPEDC, CCP-P Second Row: Marge Carney, CPC, CGCS; Donna SanGiovanni, CPC, CASCC, CHI; Stacie Hannah, LPN, CPC, CPC-I, CHCC; Sandra Kunze, CPC, CPC-I, CHC-H; Kerin Draak, MS, RN, WHNPBC, CEMC; Corrie Alvarez, CPC, CPC-I, CEDC; Melody S. Irvine, CPC, CEMC, CPC-I, CCS-P, CPMA, CMRS Front Row: Beverly Welshans, CPC, CPC-I, CPC-H, CCS-P; Barbara Scott, BSN, RN, CPC, CFE; Terry Leone, CPC, CPC-P, CIC www.aapc.com January 2011 13 feature By Stephen C. Spain, MD, FAAFP, CPC Are You Aboard the EHR Revolution? Find out if you stand to benefit from adopting electronic health record technology. APPRENTICE H ealth care providers are facing significant changes in the years ahead, and the adoption of the electronic health record (EHR) is one change that many providers have yet to embrace. For large practices and institutions, the move to electronic records is a “no-brainer.” The need to share information and patients within a group mandates that patient information be accessed easily and evaluated among members of the provider group. Unfortunately, the benefits are not as clear cut for small practices. Solo and two provider groups represent about one-third of all medical providers in the United States, and so it is important to address EHR concerns for this subset of health care providers. Because the adoption of the EHR is a difficult decision for small practices, it should not be undertaken lightly. Several factors, besides the obvious incurred expenses, will affect the final decision. Despite the costs and difficulties associated with moving to the EHR, most providers should be anticipating the conversion. Depending on circumstances, however, certain practices may wish to forgo the EHR. How Long Do You Plan on Sticking Around? One of the first considerations is the age of the provider—or, more precisely, how long the provider intends to keep practicing. Moving to an EHR system is an arduous and labor-intensive process for even the most computer-literate providers. Making that commitment may not be in the best interest of a doctor who is only five or 10 years from retirement. Given that these older providers often are less adept with computers, the move to the EHR may be more stressful and result in greater productivity loss than for their younger colleagues. For many doctors at the threshold of retirement, the financial incentives simply will not justify 14 AAPC Coding Edge the emotional toll and the disruption to their practice routine. Conversely, for those providers with 10 or more practicing years in their future, the arguments in favor of adopting the EHR are strong. Those advantages include tracking of disease markers, measuring practice benchmarks, improved legibility, portable information that is shared easily, electronic prescribing, drug interaction information, and allergy alerts. All Medicare and Medicaid providers for whom retirement is not in the foreseeable future should strongly consider embracing an EHR. That decision should be made in the next two years, to take full advantage of available government subsidies. The electronic revolution is clearly the way to the future of medicine, and for many younger providers, it makes little sense to delay reaping the benefits derived from the EHR. The expenses and disruptions currently associated with EHR adoption are improving with each new generation of software. Make a Calculated Decision Cost is a frequently cited reason for not entering the EHR arena. To help providers make this move, the American Recovery and Reinvestment Act of 2009 (ARRA) has provided cash incentives to defray costs associated with adopting EHR technology. These incentives are only for health care providers who receive a significant percentage of their income from participation in Medicare and/or Medicaid. ARRA stimulus payments, although not likely to offset completely the costs associated with the transition, certainly will make the process more affordable. Depending on a provider’s Medicare/Medicaid practice mix, subsidies of $44,000 (Medicare) to $63,000 (Medicaid) are available (but not both). These subsidies are paid feature To discuss this article or topic, go to www.aapc.com For many doctors at the threshold of retirement, the financial incentives simply will not justify the emotional toll and the disruption to their practice routine. out over four to six years, and likely will not offset the total purchase price of an EHR system with the first incentive installment. Many EHR vendors are structuring their pricing creatively, to help customers minimize the initial negative cash flow. There are a growing number of web-based EHR alternatives that are priced as a monthly service, thereby minimizing the need for a large, initial cash outlay, as well. EHR adoption also will avoid the looming penalties for non compliance, which could be substantial over a long career. ARRA establishes penalties for Medicare and Medicaid providers who do not adopt the EHR, beginning as a 1 percent Medicare or Medicaid payment reduction in 2015 and reaching a maximum of 3 percent in 2017. To add insult to injury, a penalty for not using electronic prescribing, a common EHR feature, begins in 2012, and reaches a maximum of 2 percent in 2014. To illustrate the effect of these penalties, consider a practice that generates $500,000 in annual revenues, of which 30 percent of the total comes from Medicare or Medicaid. In this case, $150,000 could be subjected to penalties, for an annual loss in 2017 of 5 percent, or $7,500. As the penalties are phased in, for the 10-year period from 2011 to 2020, a non adopter, using our example practice, would be fined about $47,000 for the decade (the “net expense’). An adopter paying $8,500 annually for his or her system would pay $85,000 over that same decade. Subtract the government incentive of $44,000 from the EHR expense, and the adopter has a net expense of $41,000—$6,000 less than the penalty the non-adopter in our example would pay. The numbers change as individual circumstances change, so every practice struggling with an EHR decision should scrutinize its bottom line, weigh the financial incentives and penalties, and plan accordingly. For example, an adopting provider who qualifies for the Medicaid (rather than Medicare) incentive could qualify for $63,750—which over our decade-long example nets about $25,000 more than the non-adopter. Purchase options and payment methods for EHR systems vary widely, and the level of incentive funds available will differ greatly between practices (several vendors have online calculators that allow site visitors to input their specific practice information to see what their incentive could be). The actual cash outlay for a given system also may vary widely from the examples above. Likewise, penalties will vary widely because of the differences in each practice’s level of Medicare and Medicaid revenue. Where Does Your Practice Stand? Our country is in the midst of a health care revolution that will have far reaching effects upon all aspects of medical care. Change is at the heart of every revolution, including our present health care overhaul. The EHR is an integral part of these challenges that now confront providers. While every participant cannot be expected to embrace the changes that are forthcoming, certainly each can, and should, evaluate and plan for these changes. Preparing for this revolution is a vital step in protecting the viability of small practices, as well as the livelihood of these health care providers. Stephen Spain, M.D., has been engaged in the full-time practice of family medicine for over 25 years. In 1998 he founded Doc-U-Chart, a practice management consulting firm specializing in medical documentation. Dr. Spain can be reached at [email protected]. www.aapc.com January 2011 15 feature Don’t Let PHI Become TMI Know when protected health information (PHI) may be too much information (TMI) in social media. By Robert A. Pelaia, Esq., CPC S APPRENTICE 16 AAPC Coding Edge ignificant progress in information technology has brought social media in health care to the mainstream. Consider these four examples: 1. According to its website, the Mayo Clinic recently launched a Center for Social Media with the intention of training physicians and hospitals to use Facebook, Twitter, YouTube, and other popular social media outlets. Mayo’s Center for Social Media claims the Mayo Clinic has “the most popular medical provider channel on YouTube” and more than 80,000 followers on Twitter, as well as over 25,000 Facebook friends. The Mayo Clinic even offers a special Twitter training camp, or “Tweetcamp,” where participants can be trained on using social media tools to improve health care, promote health, and fight disease. 2.Recently, physicians at Henry Ford Hospital in Detroit broadcast live surgical procedures via Twitter, a social-networking site, to give short, real-time updates (of less than 140 text characters each) about certain complex or unique procedures. 3. Nov. 8, 2010, the American Medical Association (AMA) adopted a new social media policy designed to encourage physicians to better manage their online presence while protecting patient privacy and maintaining professionalism. AMA policy acknowledges that social media outlets foster collegiality and camaraderie and provide opportunity to widely disseminate public health messages and other health communication. AMA policy also stresses the importance of appropriate conduct on social networks, the use of strong privacy settings, and the separation of personal and professional content online to preserve the integrity of the patient-physician relationship. 4.As an AAPC member, you have access to AAPC’s website, where countless questions are posted in discussion forums by coders throughout the country. These informative and educational postings often contain specific coding scenarios, diagnoses, and medical information. Popular Avenues for Sharing Knowledge Social networks and websites such as Facebook, Flickr, MySpace, Second Life, Twitter, and YouTube are popular avenues through which knowledge is shared, creativity is expressed, and connections are made. In addition to the Internet, cell phones frequently are used for text messaging and taking photos and videos. Such use is considered a catalyst of “social media” because these photos and video clips often are posted immediately on social media sites to share with others. Although there are many benefits to the social networking revolution and advantages to the use of social media in the health care environment, social media used in the health care world poses more risk than when social media is used in other industries. If you participate in these social networks, discussion forums, or blogs, it is important that you—as a participant in the health care delivery system—be careful to maintain the privacy and confidentiality of your patients and co-workers. Consider HIPAA Appropriateness Patients also may use social media while receiving services from a health care provider (e.g., a patient “tweets” from the operating room or takes pictures of the ultrasound monitor with a cell phone). To further complicate the issue, there is a debate on the appropriateness of health care providers using social media to relate medical advice or information with their patients (e.g., physicians and patients being Facebook friends). Health care providers need to exercise extreme caution when giving patient-specific medical advice in an online environment because sharing thoughts feature The social media world is moving at such a fast pace that it’s impossible to address the many questions and issues that arise when providers and patients use it in the health care environment. publicly about a patient can easily turn into a Health Insurance Portability and Accountability Act (HIPAA) privacy breach. Unlike informal comments made at a casual dinner party, a tweet or a Facebook message leaves a permanent record of a potential privacy violation. Privacy Policies Try to Keep Up with Technology Social media is moving at such a fast pace that it’s impossible to address the many questions and issues that arise when providers and patients use it in the health care environment. Today, the trend is for health care entities to move towards adopting policies that attempt to regulate employees’ social media use. Some health care employers ban access to social media outlets or other personal Internet use while at work. Although it is difficult for health care employers to monitor employees’ activities on social media websites outside of work, there are a few basic “common sense” ideas to keep in mind when you enter the cyber world. Protect Yourself and Patients Use good judgment when participating in a blog or discussion forum, or when submitting content to a social media site. Embarrassing, obscene, or inappropriate material—including photos, videos, or written comments—that you submit to these sites may reflect poorly on you, your employer, or, worse yet, violate patient confidentiality and privacy. To protect yourself (and your patients and fellow employees), remember that cell phones with camera capabilities should not be used to take pictures of patients, regardless of whether the pictures are stored internally on a memory card or sent electronically to any social media or website. Taking unauthorized pictures or videos of patients is a violation of patient confidentiality and privacy. Any information about a patient’s medical history, medical condition, demographics, diagnostic data or finances always is considered confidential and never should be shared in a social media outlet. If you submit a question on an AAPC discussion forum, make sure you do not disclose confidential or protected patient information. Such information should only be disclosed to authorized personnel in a manner consistent with state and federal law. Access and use of patient information and images must be provided only on a “need to know” basis to fulfill your professional job duties. Confidential patient information never should be shared when you submit content to any social media site. You’ll Be Held Accountable for Your Actions We have all heard horror stories about social media posts that contain just enough information to allow the reader to identify the patient’s identity. A quick online search reveals that the media is full of examples where health care employees were terminated or disciplined for using social media to post personal discussions concerning patients. You do not want to have this happen to you. The bottom line: If you use social media at all, even when you are not at work, always protect your patients’ privacy rights and always safeguard and manage patient information and images appropriately. Disclaimer: Information published in this article is the personal view of the author and not that of the University of Florida. Information published in this article is not intended to be, nor should it be considered, legal advice. Readers should consult with an attorney to discuss specific situations in further detail. Robert A. Pelaia, Esq., CPC, is senior university counsel for health affairs at the University of Florida College of Medicine, Jacksonville, Fla. Pelaia is certified as a Health Care Law Specialist by the Florida Bar Board of Legal Specialization and Education. He is also a member of the AAPC National Advisory Board (NAB). www.aapc.com January 2011 17 AAPCCA Make a Lasting First Impression Chapters should initiate the first contact and make it positive. By Melissa Brown, RHIA, CPC, CPC-I, CFPC I t’s been said, “You never get a second chance to make a first impression.” The same may hold true for local chapter meetings. We hear stories of chapters struggling for attendance numbers, even when there are hundreds of members assigned to a particular chapter. With the start of a new year, there’s renewed opportunity for chapters to make a lasting impression. Your First Chance Starts Online The first chance to make a lasting impression for many chapters is on AAPC’s website. When a member is new to a city or new to the organization, one of the first things they do is search the website for a local chapter. When they pull up your chapter’s web page: Are there officers in every slot? Is there current contact information for each officer? Are there upcoming events listed? These are all important items that show a proactive group of leaders. If you have numerous officers, this gives the impression of a dynamic group of leaders with involved members. Be sure to have current contact information for each leader so prospective members can get more information about your meetings, and have several meetings listed to show you are actively addressing member needs. You may feel you only have a limited amount of control over what shows on the website, but in reality, what isn’t posted may say as much about your chapter as what is there. Make sure your meetings are planned and posted online well in advance, and be sure to submit continuing education unit (CEU) approval for chapter meetings and exams as soon as you have all the required information. When your year is planned in advance, the chances of making a good first impression are exponentially increased. First Contact Is Critical Remember how exciting it was when you first became an AAPC member or moved to a new chapter? As an officer, you can make a lasting impression on a new member when you initiate the first contact. This lets 18 AAPC Coding Edge the new member know you care about him or her, the members of your chapter, and AAPC. When you are notified of a member joining your chapter, or of newly credentialed members, you have the perfect opportunity to make the members feel welcome by sending out an e-mail or card that tells about the chapter meeting dates and times, and that congratulates them on their accomplishment (as appropriate). The impression you make with the first contact is remembered, so make it a great one. There are times when a member contacts you first. If the first contact is a phone conversation or e-mail initiated by the member, use the same rules of engagement. Be friendly, courteous, informative, and welcoming in your tone and be in-depth with information you provide. Short “yes” and “no” answers may provide the information sought but may send a negative impression about the concern you have for your chapter and members. Anticipate follow-up questions and provide helpful information to make the new member feel valued. Respond to these contacts in a timely manner. If it takes you more than a week to respond to a message, the member will have the impression that you are too busy to care about their questions. A good rule of thumb is to respond within 24 hours. Despite your best efforts at having a proactive approach to meeting members, the first contact is often face-toface at an actual meeting. Even in this setting, there are many opportunities to make a positive impression that encourage new members to return. Consider positioning the new member development officer and other greeters throughout your meeting area, such as at the doorway entrance, directing the way to the sign-in table, near the refreshment area, and other areas where your members may be before the meeting. A great way to make someone feel welcome is to introduce yourself, make eye contact and say something as simple as, “We are glad you are here!” During opening remarks, it is recommended for the president to recognize all firsttime members, visitors, and guests. Encourage everyone to introduce themselves at some point during or after the meeting. AAPCCA Short “yes” and “no” answers may provide the information sought but may send a negative impression about the concern you have for your chapter and members. Keep Them Coming Back Here’s Your Second Chance Helpful hints for a great meeting and to make a great lasting impression: Have an agenda—and follow it Start on time and end on time Welcome everyone—all members should know their presence is appreciated Be aware of special needs and ensure those needs are met (eg, hearing-impaired members) Have a positive attitude Be organized Properly introduce speakers Announce the next meeting time and subject Have FUN! This is a new day in a new year with excited new officers. What better time to “turn over a new leaf” and make a positive impression on your new and existing chapter members? Melissa Brown, RHIA, CPC, CPC-I, CFPC, is vice-chair of the AAPCCA board of directors and manager of education and reimbursement at the University of Florida Jacksonville Physicians, Inc. Melissa’s areas of expertise include budget analysis, Physician Quality Reporting Initiative (PQRI), and a wide variety of billing/coding-related topics—expertise that has been shared with a wide audience through classes and seminars. Melissa’s talents as a public speaker have been honed through Toastmasters International, with which she holds the highest status of Distinguished Toastmaster (DTM). After 18 years in the health care industry, she still enjoys researching complex coding queries and tackling difficult reimbursement issues. Introducing AAPC’s newest credential… Certified Professional Compliance Officer (CPCO) Exam registration opens January 15. Voluntary Today, Mandatory Tomorrow – while compliance programs for individual and small group practices are not federally mandated today, the Patient Protection and Affordable Care Act will require providers and suppliers to adopt, as a condition of enrollment, compliance programs. www.aapc.com/cpco 1-800-626-CODE (2633) www.aapc.com January 2011 19 coding compass Health Care Reform: The Assault on Waste, Fraud, and Abuse Understand how Patient Protection and Affordable Care Act of 2010 effects your practice’s liability. By David Behinfar, JD, LLM, CHC, CIPP H EXPERT ealth care reform became a reality on March 23, 2010 when President Obama signed into law the Patient Protection and Affordable Care Act of 2010 (PPACA). A number of the law’s provisions are aimed at reducing and eliminating waste, fraud, and abuse in health care. We’ll highlight several of the law’s provisions that require thoughtful response from the health care community. Repay Government Overpayments Within 60-days PPACA requires health care providers to report and return overpayments from governmental payers within 60 days from the time the provider discovers the overpayment. If an overpayment is retained beyond 60 days, it becomes an “obligation” sufficient for reverse false claims liability under the False Claims Act, and may become subject to triple damages and penalties if there is “knowing and improper” failure to return the overpayment. Health care entities that receive reimbursement from government payers need to address this time-sensitive reporting requirement by examining their current process for auditing charges and returning overpayments. Although this sounds like a simple task, the time pressure—combined with possible penalties—may cause discomfort to those departments involved in the revenue stream. Many parties must address the practical improvements necessary to identify, report, and repay the government within the 60-day limit. Coding specialists are likely to assume a key role in reviewing claims to help avoid overpayments on the front end. Whistleblowers Gain Incentives To identify fraud, PPACA expands the class of potential whistleblowers in false claims actions. Typically, whistleblowers are encouraged to come forward through an opportunity to participate in the recovery of any fine imposed upon a health care entity in violation of the False Claims Act. 20 AAPC Coding Edge Prior to PPACA, to qualify successfully as a whistleblower (or “relator,” as the term is defined in the False Claims Act), the individual must be the original source of information that implicated false claims activity. This generally meant the whistleblower was an insider, or someone with close ties to an organization and access to their non-public documents, who stepped forward with this information and exposed the fraud. The government did not allow an individual to share a portion of the recovered amount if the whistleblower provided publicly available information (information available in media reports, state and federal civil administrative, and criminal proceedings, etc.). PPACA now allows whistleblowers to act based on information disclosed publicly in a state or local proceeding. PPACA takes this small step to recognize that it is more important to encourage people with fraud knowledge to step forward, than to worry about how or where they obtained the information. This is another incremental move in favor of the government, which potentially increases the prosecution of health care fraud. Stark Violation – Medicare Self-Referral Disclosure Protocol for Providers In March 2009, the Office of Inspector General (OIG) announced it would focus on potential violations of the anti-kickback statute. Because of this new priority, the OIG no longer would accept provider self-disclosures of Stark Law violations unless those violations also implicated a “colorable” violation of the anti-kickback statute. Consequently, since March 2009, providers have been unable to self-report violations of the Stark Law. PPACA fills this void and allows providers once again to self-report Stark violation through a newly designed protocol. The new self-referral disclosure protocol for providers was announced on the Centers for Medicare & Medic- coding compass The new self-referral disclosure protocol is a welcome tool for providers to prove they mean well but sometimes make mistakes, and to demonstrate to the government they have an active compliance program and own up to those mistakes. aid Services (CMS) website Sept. 23, 2010 (www.cms. gov/PhysicianSelfReferral/Downloads/6409_SRDP_ Protocol.pdf). The self-referral disclosure protocol presents an important opportunity for physicians to reduce their risk exposure. By allowing physicians to report Stark violations voluntarily, CMS expects (except in extreme scenarios): ll Payments made for designated health services that violate Stark will be refunded to the government, but ll punitive-based penalties to be unlikely, especially in cases of technical violations. CMS Offsets Stark Violation Payments with SelfReferral Disclosure Protocol As part of the aforementioned new self-referral disclosure protocol, CMS has the option of recouping payments made to a provider by reducing or offsetting any Medicare payments that otherwise would be made to the provider. The secretary must take the following into account when determining the amount of any reduction: ll The nature and extent of self-disclosed improper or illegal conduct ll The timeliness of the provider’s self-disclosure ll Cooperation when CMS requests additional information during the investigation/reporting ll The litigation risk associated with the disclosed matter ll The disclosing party’s financial position Self-reporting typically is viewed as a positive opportunity for providers to identify and admit to mistakes, pay any resulting amounts owed for the mistake, and move on without fear of further repercussions. The new self-referral disclosure protocol is a welcome tool for providers to prove they mean well but sometimes make mistakes, and to demonstrate to the government they have an active compliance program and own up to those mistakes. Anti-Kickback Statute and False Claims Liability Implications Change The federal anti-kickback statute provides civil and criminal penalties to individuals who knowingly offer, pay, solicit, or receive bribes or kickbacks or other remuneration to induce business reimbursable by federal health care programs. PPACA has introduced a provision to eliminate the well-recognized Hanlester defense, which interpreted the statute as requiring proof that the defendant: (1) had specific knowledge of the anti-kickback statute; and (2) engaged in prohibited conduct with the specific intent do disobey the law (Hanlester Network v. Shalala, 51 F.3d 1390 (9th Circ. 1995)). PPACA also contains a provision stating health care claims for reimbursement that include items or services in violation of the anti-kickback statute constitute false claims for False Claims Act purposes. Providers now face a lower threshold for anti-kickback violations, and may incur possible False Claims Act liability with fewer defenses to avoid this liability. PPACA has made it easier to prove an anti-kickback violation and establish the carry-over effect as a false claims violation. The PPACA may cause providers who have legitimate errors in billing, or contractual deficiencies with third party contractors or suppliers, to find themselves in violation of federal fraud statutes. Address PPACA Initiatives PPACA provides clear insight into the government’s intent to tighten the reins on health care waste, fraud, and abuse. Although the well meaning and law-abiding segment of the health care community appreciates the elimination of waste and fraud in health care, providers who fail to recognize that the government can ensnare those who make unintentional billing errors and other compliance-related mistakes are caught in the middle of this battle. Physicians and coders must be proactive in addressing the waste and fraud initiatives in the PPACA, and work with their compliance, legal, and revenue departments to help avoid liability associated with these new provisions. David Behinfar, JD, LLM, CHC, CIPP, has been employed as privacy manager at the University of Florida College of Medicine in Jacksonville for the past eight years. David has worked in health care compliance both as an attorney and in his current role for more than 14 years. He also has written a number of articles on health care compliance and privacy and has spoken at several national and state level conferences. www.aapc.com January 2011 21 facility Accurately Score MDM in the ED Make smart decisions about your physicians’ medical decision making (MDM). By Sarah Todt, RN, CPC, CEDC D etermining MDM using the 1995 Documentation Guidelines for Evaluation and Management Services and directions from CPT® Evaluation and Management (E/M) Services Guidelines poses unique challenges when coding emergency medicine E/M services. The three key components used in the emergency department (ED) for assigning E/M services include: history, exam, and MDM. MDM dictates the highest service level that may be reported and the history and physical exam documentation needed to support the choice. EXPERT MDM: The Driving Force There are four levels of MDM to support the five ED E/M codes: ll Straight forward (99281) ll Low (99282) ll Moderate (99283 and 99284) ll High (99285) Determine the MDM level by reviewing three distinct components. The entire record must be reviewed and all information considered. CPT® references the following three components for MDM: 1. Number of diagnosis and management options 2.Amount and complexity of data 3. Risk Many coders or auditors reference MDM scoring modeled after a Marshfield Clinic-type audit tool. The scoring is not part of official documentation guidelines, with the exception of the Table of Risk. The audit tool gives some components a numerical value to help the coder or auditor determine the appropriate level. For more information on assigning E/M ED leveling, see the article “Evaluate Your Performance When ED Leveling” by Jim Strafford, CEDC, MCS-P, in this issue of Coding Edge. Number of Diagnosis and Management Options The “number of diagnosis and management options” component of MDM considers the range of diagnoses and the treatment that may be required. Audit tools score this component based on if a patient is established or new, and if there is addi22 AAPC Coding Edge tional work-up planned. CPT® does not distinguish between new and established patients for ED E/M service codes. Most ED patients are considered new. Scoring for number of diagnosis or management options: New patient no additional work-up planned 3 points New patient with additional work-up planned 4 points The definition of “additional work-up planned” has not been defined clearly within the audit tool, and there are many interpretations available. Most audit tools reference (at a minimum) admissions, transfers, and scheduled diagnostics or physician follow-up for additional work-up planned. Amount and Complexity of Data The “amount and complexity of data” component is referred to as the “data point” component of MDM. This component gives value to diagnostic tests and other information essential for determining the management of the patient’s illness. Components to consider include: diagnostic tests, obtaining or reviewing old records, discussion with other providers, independent visualization of image or tracing, and obtaining history from someone other than the patient. The components have a numeric value of one or two points. The points obtained are added for a final score in this area. Amount and Complexity of Data Points Clinical labs test ordered or reviewed CPT® Medicine section test—ordered/reviewed CPT® Radiology section test—ordered/reviewed Discuss patient results with performing physician Decision obtain old records or additional hx other than pt Review/summarize data old records/add hx other than pt 1 1 1 1 1 2 Independent interpretation of an image, tracing, specimen 2 Table of Risk The Table of Risk is an official part of the 1995 Documentation Guidelines for Evaluation and Management Services and is applicable to all specialties. Coders are instructed to assign risk based on the highest intervention in any category of the risk table. The three categories include: facility The “amount and complexity of data” component is referred to as the “data point” component of MDM. This component gives value to diagnostic tests and other information essential for determining the management of the patient’s illness. 1. Presenting Problem 2.Diagnostic Procedure(s) Ordered 3. Management Options Selected Generally, for ED coding, the interventions listed in the “diagnostic procedure(s) ordered” will not lead to the highest element for risk. Example of risk elements typically used for ED MDM: MINIMAL LOW MODERATE HIGH Suture removal (placed at other facility) OTC med only; Rx management; Abrupt neuro change; acute uncomplicated injury or illness Acute illness with systemic symptoms; Acute complicated injury; Exacerbation of chronic condition Potential life threatening illness; Severe exacerbation of chronic illness; Medications requiring monitoring; Parenteral controlled medications Overall Scoring of MDM Each of the three MDM areas should be scored. The level is determined by selecting the highest two of the three distinct areas. Number of Dx and Mgt Options Amount and Complexity of Data Risk Level of MDM 1 1 Minimal Straight forward 2 2 Low Low 3 3 Moderate Moderate 4 4 High High Nature of Presenting Problem The nature of the “presenting problem” is not considered a key component of scoring MDM; however, it may provide essential information needed to determine appropriate levels of service. In the current environment of electronic health records (EHRs) and templated records, documentation tools are engi- neered to encourage optimal documentation. To ensure proper code assignment, take the nature of the presenting problem into consideration—especially with moderate MDM supporting both 99283 and 99284. CPT® provides the following language: 99283Emergency department visit for the evaluation and management of a patient, which requires these 3 key components: An expanded problem focused history; An expanded problem focused examination; and Medical decision making of moderate complexity. Counseling and/or coordination of care with other providers or agencies are provided consistent with the nature of the problem(s) and the patient’s and/or family’s needs. Usually, the presenting problem(s) are of moderate severity. 99284Emergency department visit for the evaluation and management of a patient, which requires these 3 key components: A detailed history; A detailed examination; and Medical decision making of moderate complexity. Counseling and/ or coordination of care with other providers or agencies are provided consistent with the nature of the problem(s) and the patient’s and/or family’s needs. Usually, the presenting problem(s) are of high severity, and require urgent evaluation by the physician but do not pose an immediate significant threat to life or physiologic function. Cases scoring as moderate MDM may range from an illness that requires a prescription at discharge to an illness that requires labs, X-rays, and parenteral medications. For example, a patient diagnosed with conjunctivitis and discharged with a prescription for eye drops, and a patient with abdominal pain treated with parenteral medication after diagnostic evaluation including a computed tomography (CT) scan and lab work, would both support moderate MDM. If both cases are documented with a detailed history and exam, the coder will now need to consider the nature of presenting problem to assign the appropriate level: 99283 or 99284. Final Level Assignment As mentioned, MDM dictates the highest level that may be assigned and the history and exam must support the assignment. With a good understanding of the components, you can assign the MDM level accurately and appropriately. Consider these two cases as examples: www.aapc.com January 2011 23 facility Case History 1 History of Present Illness The patient is a 9-year-old female who presents with dry cough that started last night with low grade fever and malaise. Pt. also complains of right ear pain, duration lasting one day(s). The course is constant. Cough quality: moderate, dry and barking cough. Pt. otherwise active and talkative, and sounds happy. The degree of severity is mild. Tylenol® given for fever with relief. Review of Systems Genitourinary symptoms: Negative. Musculoskeletal symptoms: Negative. Neurologic symptoms: Negative. Lymphatic symptoms: Negative. Skin symptoms: Negative, but no rash. Other review of systems: All systems reviewed as documented in chart. Past medical history: Negative. Physical Examination General appearance: No acute distress, alert, smiling, interactive and body habitus is well-nourished. Skin: Warm. Dry. No pallor. Ears, nose, mouth, and throat: Oral mucosa moist. No pharyngeal erythema or exudate. Ear: Right tympanic membrane red. Neck: Supple, no tenderness. Heart: Regular rate and rhythm, no extra heart sounds. Respiratory: Respirations non-labored. Lungs: Clear to auscultation. equal bilateral, no stridor no wheezes. Chest wall: No tenderness. Abdominal: Soft. Neurological: Alert. MDM Differential diagnosis: Wheezing, upper respiratory infection, otitis Impression and Plan Diagnosis: URI, otitis media Discharge plan Condition: Stable. Dispositioned: To home. Prescriptions: Prescription order. Pharmacy: amoxicillin 250 mg/5 mL oral liquid (Ordered): 5 mL, PO, BID, 7 day(s), 70 mL MDM Scoring Number of diagnosis and management options: New patient, no additional work-up = 3 points Amount and complexity of data: none = 0 points 24 AAPC Coding Edge Risk: Prescription management = moderate Total MDM: Moderate History and exam: Detailed This case could support either a 99283 or 99284 based on moderate MDM. The coder needs to evaluate the nature of the presenting problem. This case would be more consistent with the moderate severity, supporting a 99283. Case Example 2 History of Present Illness The patient is a 4-year-old female who presents with dry cough that started last night with fever of 104 and malaise. She has not voided in 12 hours and parents report that she has decrease in PO intake. Pt. also complaining of right ear pain, duration lasting 1 day(s). The course is constant. Cough quality: Moderate, dry and barking cough. The degree of severity is mild. Tylenol® given for fever with relief. Review of Systems Genitourinary symptoms: Negative. Musculoskeletal symptoms: Negative. Neurologic symptoms: Increased tiredness. Lymphatic symptoms: Negative. Skin symptoms: Negative, but no rash. Other review of systems: AIl systems reviewed as documented in chart. Past medical history: Negative. Physical Examination General appearance: No acute distress, slightly lethargic, and body habitus well-nourished. Skin: Warm. Dry. No pallor. Ears, nose, mouth, and throat: Oral mucosa moist. No pharyngeal erythema or exudate. Ear: Right tympanic membrane red. Neck: Supple, no tenderness. Heart: Regular rate and rhythm, no extra heart sounds. Respiratory: Respirations non-labored. Lungs: Clear to auscultation. Equal bilateral, no stridor no wheezes. Chest wall: No tenderness. Abdominal: Soft. Neurological: Alert. MDM Differential diagnosis: Wheezing, upper respiratory infection, otitis Orders Labs: CBC, Chem 7, UA Chest X-ray IV NS 250 cc bolus facility Cases scoring as moderate MDM may range from an illness that requires a prescription at discharge to an illness that requires labs, X-rays, and parenteral medications. Reassessment Pt. much improved after bolus. Afebrile. Parents agree to discharge. Impression and Plan Diagnosis: Bronchitis, otitis media, mild dehydration Discharge plan Condition: Stable. Dispositioned: To home. Prescriptions: Prescription order. Pharmacy: Amoxicillin 250 mg/5 mL oral liquid (Ordered): 5 mL, PO, BID, 7 day(s), 70 mL MDM Scoring Number of diagnosis and management options: New patient, no additional work-up = 3 points Amount and complexity of data = 2 pts Risk: Prescription management = moderate Total MDM: Moderate History and exam: Detailed The nature of presenting problem for this case appears much higher than in Case 1. Both cases would be scored with moderate MDM and detailed history and exam; however, Case 2 would support the higher code choice 99284, based on an urgent nature of presenting problem. Sarah Todt, RN, CPC, CEDC, is the director of compliance and physician education for MRSI, Inc., an industry leader in emergency medicine coding and reimbursement. Sarah has served on AAPC’s National Advisory Board (NAB) and Emergency Department Specialty Exam Steering Committee and has published several ED-related articles in Coding Edge. Spend time w/ family and earn CEUs! Need CEUs to renew your CPC®? 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Easily affordable with EasyPayments! www.HealthcareBusinessOffice.com/easypay.htm (Some courses also have CEU approval from AHIMA. See our Web site.) Continuing education. Any time. Any place. ℠ www.aapc.com January 2011 25 feature Vertebroplasty Is Not Vertebral Augmentation One difference helps you tell these procedures apart. EXPERT By G. John Verhovshek, MA, CPC 26 AAPC Coding Edge Percutaneous vertebroplasty is a minimally-invasive procedure during which a “bone cement” (methylmethacrylate) is injected into one or more fractured vertebra(e) to fill fractures, treat pain associated with fractures, and restore spinal integrity. CPT® provides three codes to describe vertebroplasty: 22520Percutaneous vertebroplasty, one vertebral body, unilateral or bilateral injection; thoracic 22521 lumbar +22522each additional thoracic or lumbar vertebral body (list separately in addition to code for primary procedure) When reporting vertebroplasty, select a single, initial-level code based on location (thoracic or lumbar). For each additional thoracic or lumbar level treated during the same session, report one unit with add-on code 22522. For example, the patient has fractures of the second, third, and fourth lumbar vertebrae (L2, L3, and L4). The physician applies a local anesthetic, places the needle over L2, and injects methylmethacrylate to fill the fracture. He repeats the process at L3 and again at L4. In this case, report 22521 (for the initial lumbar level) and 22522 x 2 (for each of the additional lumbar levels). You need not append modifiers (e.g., modifier 51 Multiple procedures or modifier 59 Distinct procedural service) to report the additional levels. Note also that 22520-22522 cover unilateral or bilateral procedures. Do not append modifier 50 Bilateral procedure or expect additional reimbursement if the physician injects the same vertebral body multiple times. feature Kyphoplasty includes the use of an inflatable balloon to jack up the damaged vertebra(e) prior to injection of the bone cement. Stick With a Single Primary Code for Cross Region Injections If the physician treats multiple spinal levels, beginning in the thoracic region and crossing into the lumbar region, you should select a single, initial-level code. Code 22520 is assigned a greater number of relative value units (RVUs) than 22521 under the Medicare Physician Fee Schedule (MPFS). You should report the initial level using the thoracic code. For example, osteoporosis, a common condition for which physicians use percutaneous vertebroplasty, often occurs at the thoracic/lumbar junction. If the surgeon treats the final thoracic vertebra (T12) and the first lumbar vertebrae (L1), report 22520, 22522. Turn to Temporary, Unlisted Codes for Cervical Vertebroplasty CPT® does not include codes to describe cervical vertebroplasty. If your payer accepts HCPCS Level II Temporary National Codes, you may report S2360 Percutaneous vertebroplasty, one vertebral body, unilateral or bilateral injection; cervical and S2361 Percutaneous vertebroplasty, one vertebral body, unilateral or bilateral injection; each additional cervical vertebral body, as appropriate. For example, for vertebroplasty at C5, C6, and C7, report S2360, S2360 x 2. For those payers who do not accept S codes (including Medicare payers), you must code cervical vertebroplasty using CPT® unlisted procedure code 22899 Unlisted procedure, spine. As always, when reporting an unlisted procedure code, include a full description of the procedure so the payer can make an appropriate payment determination. Kyphoplasty Is Vertebroplasty, With a Difference Percutaneous vertebral augmentation, more commonly called kyphoplasty, resembles vertebroplasty in every detail, but adds one very important step. Kyphoplasty includes the use of an inflatable bal- loon to jack up the damaged vertebra(e) prior to injection of the bone cement. For this reason, kyphoplasty sometimes may be referred to as “balloon-assisted percutaneous vertebroplasty.” The physician first creates a working space within the fractured vertebral body. She then places an inflatable bone tamp (the balloon) in the enlarged cavity. She inflates the bone tamp, further enlarging the cavity and restoring height to the damaged vertebral body. She removes the balloon and fills the remaining cavity with bone cement. You often can identify kyphoplasty by searching the operative note for the words “ balloon,” “bone tamp,” “KyphX” (a common brand name for the bone tamp) or “IBT” (inflatable bone tamp). CPT® includes three dedicated codes for kyphoplasty, which mirror the vertebroplasty codes: 22523Percutaneous vertebral augmentation, including cavity creation (fracture reduction and bone biopsy included when performed) using mechanical device, one vertebral body, unilateral or bilateral cannulation (e.g., kyphoplasty); thoracic 22524 lumbar +22525each additional thoracic or lumbar vertebral body (list separately in addition to code for primary procedure) Like the vertebroplasty codes, the kyphoplasty codes represent either unilateral or bilateral procedures. Select a single, initial-level code (using 22523 as the initial level if physician crosses from the thoracic to lumbar regions). When appropriate, report one unit of add-on code 22525 for each additional level beyond the first that the physician treats. For example, if the physician documents kyphoplasty at levels T10, T11, and L1, report 22523, 22525 x 2. No CPT® or HCPCS Level II codes describe cervical kyphoplasty. To report cervical kyphoplasty, turn to unlisted procedure code 22899. www.aapc.com January 2011 27 feature To discuss this article or topic, go to www.aapc.com Radiologic Supervision and Interpretation Is Separate Needle placement for both vertebroplasty and kyphoplasty often takes place under imaging guidance. If the physician personally performs the service, you may report it separately with either 72291 Radiological supervision and interpretation, percutaneous vertebroplasty, vertebral augmentation, or sacral augmentation (sacroplasty), including cavity creation, per vertebral body or sacrum; under fluoroscopic guidance or 72292 Radiological supervision and interpretation, percutaneous vertebroplasty, vertebral augmentation, or sacral augmentation (sacroplasty), including cavity creation, per vertebral body or sacrum; under CT guidance), as appropriate. Append modifier 26 Professional service to show that the physician provided only the professional component (supervision and interpretation) of the imaging service. Bundle Same-Location Bone Biopsy When reporting 22520-22522 or 22523-22525, do not report separately bone biopsy (20225 Biopsy, bone, trocar or needle; deep (e.g., vertebral body, femur) at the same location(s). Kyphoplasty code descriptors specifically include bone biopsy, while National Correct Coding Initiative (NCCI) edits bundle bone biopsy to vertebroplasty and kyphoplasty codes. If the physician performs bone biopsy at a level not addressed by the vertebroplasty or kyphoplasty, you may report the biopsy separately with modifier 59 Distinct procedural service appended to indicate the unrelated nature and separate locations of the two procedures. For instance, if the physician documents kyphoplasty at L2 and performs vertebral bone biopsy for a different reason at T5, report 22524, 20225-59. [ G. John Verhovshek, MA, CPC, is director of editorial development/managing editor at AAPC. ] Category III Codes Describe Sacral Procedures Vertebroplasty (22520-22522) and kyphoplasty (22523-22525) codes apply only to thoracic and lumbar regions of the spine. As elsewhere described, cervical procedures may be reported using HCPCS Level II Temporary National Codes S2360 and S2361 (vertebroplasty, for payers who accept S codes) and/or unlisted procedure code 22899 (vertebroplasty, for payers who do not accept S codes, and kyphoplasty for all payers). As of July 2009, you may select two new Category III codes specifically for sacral procedures: 0200TPercutaneous sacral augmentation (sacroplasty), unilateral injection(s), including the use of a balloon or mechanical device, when used, 1 or more needles 0201TPercutaneous sacral augmentation (sacroplasty), bilateral injections, including the use of a balloon or mechanical device, when used, 2 or more needles These codes apply regardless of whether balloon-assist is used to support the bone prior to injection (that is, these codes describe both sacral vertebroplasty and sacral kyphoplasty, with no distinction between the two). Unlike 2252022525, the sacral codes differentiate between unilateral (0200T) and bilateral (0201T) procedures. If fluoroscopic or computed tomography (CT) guidance is performed with sacroplasty, additionally report 72291 or 72292, as appropriate (see below for more detail). CPT® allows you to report bone biopsy (20225) separately, when performed. When provided, moderate sedation is included with 0200T and 0201T. 28 AAPC Coding Edge MARCH WORKSHOP AdvAnced SurgicAl chArt Auditing Surgical Chart Auditing is a skill that requires practice. In addition to assuring the proper coding was assigned, other legal aspects found in a surgical record must also be considered. Don’t find your practice in the middle of a payer audit feeling unprepared and vulnerable. Learn how to completely and accurately review and validate surgical services from a compliance perspective. You’ll Learn To: • • • • 6 CEUs Outline the process for correctly dissecting an operative note Evaluate the key elements of surgical procedures Design an auditing report and/or corrective action plan based on results Apply surgical chart auditing hands-on skills working with multiple surgical cases NEW THIS YEAR Workshops are four hours and include interactive, hands-on exercises. Please bring your core coding books (CPT®, ICD-9-CM, HCPCS Level II). Find a workshop location near you and register today! www.aapc.com/surgicalaudits uPcOMing wOrkShOPS MAY AUGUST NOVEMBER Advanced E/M Chart Auditing Modifiers – The Rest of the Story RACs, MRACs, MICs and ZPICs What Codes Are Being Targeted Now? www.aapc.com/surgicalaudits | 1-800-626-CODE (2633) PHOTOS COURTESY OF DESTinaTiOnS MagazinE EXPERT facility Fees, observation, number of codes are some of the changes for 2011. Prepare for 2011 OPPS Final Rule By Denise Williams, RN, CPC, CPC-H F or the 2011 Outpatient Prospective Payment System (OPPS) Final Rule, the Centers for Medicare & Medicaid Services (CMS) based payments on claims data submitted by hospital providers during 2009. Let’s highlight some of the rule to prepare you for the changes in the year ahead. You can download the CMS display copy of the rule and all preamble tables and addenda at: www. cms.hhs.gov/HospitalOutpatientPPS/HORD. Select CMS-1504-FC to access the Final Changes to the Hospital Outpatient Prospective Payment System and CY 2011 Payment Rates files and final rule documents. 2X Rule Violation Exceptions Increase As in the past couple of years, CMS made changes to the ambulatory payment classification (APC) assignment this year based on the “2X rule violation.” Prospective payment involves an inherent grouping of services requiring comparable resource usage. A 2X rule violation happens when the highest cost item’s median cost is twice that of the lowest cost item within the same APC. The secretary of Health and Human Services (HHS) has the discretion to allow exceptions to this rule (such as for low-volume procedures and services), and has approved 22 APCs as exceptions to the 2X rule for 2011 (seven more than in 2010). These are listed in Table 22 in the Final Rule. Composite APCs Remain the Same CMS made no changes to existing composite APCs, nor did they create new composite APCs for 2011. The Multiple Imaging composites were implemented in 2009, and the first claims data for monitoring the impact were available for this year’s rate setting. The APC panel and rule commenters recommended additional composites that could be created in the future. CMS continues to “consider the development and implementation of larger 30 AAPC Coding Edge payment bundles, such as composite APCs (a longterm policy objective for the OPPS), and continues to explore other areas” where this model could be utilized, according to the Final Rule. Outlier Fixed-Dollar Thresholds Updated CMS annually updates the formula for calculating outlier payments. Just like in 2010, an outlier payment is triggered in 2011 when costs for providing a service or procedure exceed both: ll 1.75 times the APC payment amount ll The APC payment plus $2,025 fixed-dollar threshold (decreased by $150 from 2010) CMS made no changes to the outlier reconciliation policy for outpatient services provided based on cost reporting periods beginning in 2009. Pass-through Payment Changes There is one device that became eligible for passthrough payment in October 2010. Described by HCPCS Level II code C1749 Endoscope, retrograde imaging/illumination colonoscope device (implantable), this item will continue with pass-through status for 2011. There are additional applications for pass-through items under consideration. Drugs and biologicals with pass-through status that expired Dec. 31, 2010 are listed in Table 27 of the Final Rule. The cost of 13 of these drugs is above the packaging threshold, which is $70 for 2011, and separate payment will continue. Payment for separately-payable drugs without passthrough status will increase for 2011 to average sale price (ASP) plus 5 percent. For the 42 drugs and biologicals having pass-through status for 2011, payment is ASP plus 6 percent. These drugs are listed in Table 28. There are HCPCS Level II code changes for several of these drugs. New vs. Established Definitions Continue CMS notes that 2009 claims data continues to reflect a cost difference between new and estab- facility lished patient visits. The agency continues to define “new” and “established” patients based on whether the patient was an inpatient or outpatient of the hospital within the past three years. E/M Guidelines Are Passed By No new national evaluation and management (E/M) guidelines are established for 2011. Claims data continues to reflect stable distribution of billed visits. CMS instructs hospitals to keep using their individual internal guidelines, being sure that the guidelines meet the 11 criteria specified in the 2008 Final Rule. Fiscal intermediaries (FIs) and Medicare administrative contractors (MACs) are encouraged to use the individual hospital’s internal E/M guidelines when an audit occurs. New CPT® Instruction, New Edit CMS instructs facilities to follow CPT® guidelines. Beginning in 2009, this included the introductory guidelines for services contained in critical care services (CPT® 99291 Critical care, evaluation and management of the critically ill or critically injured patient; first 30-74 minutes and +99292 Critical care, evaluation and management of the critically ill or critically injured patient; each additional 30 minutes (list separately in addition to code for primary service). For 2011, the American Medical Association (AMA) has added language to the Critical Care instructions noting that, “Facilities may report the above services separately.” CMS has provided packaged payment for critical care services based on the CPT® definition for the past two years. CMS notes, “Beginning in CY 2011, hospitals that report in accordance with the CPT® guidelines will begin reporting all of the ancillary services and their associated charges separately when they are provided in conjunction with critical care.” In response to this change, CMS will institute a new Outpatient Code Editor (OCE) edit that will package the services for the separately-reported procedures into the payment for critical care services. Instituting “automatic packaging” via the OCE will ease a huge operational burden on facilities who have had to use an internal, usually manual, process to remove the HCPCS Level II codes from the claim and roll the charges into one line item for critical care services. Inpatient-only Procedures Shrink The “Inpatient Only” list specifies procedures typically provided in an inpatient setting due to the invasive nature of the procedure; the need for at least 24 hours of post-procedure monitoring before the patient can be safely discharged; or the underlying physical condition of the beneficiary; and therefore, these procedures are not reimbursable under the OPPS. For 2011, CMS removed three procedures from the inpatient-only list, which allows hospitals to be reimbursed when these procedures are performed on an outpatient basis. 21193Reconstruction of mandibular rami; horizontal, vertical, C, or L osteotomy; without bone graft 21395Open treatment of orbital floor blowout fracture; periorbital approach with bone graft (includes obtaining graft) 25909Amputation, forearm, through radius and ulna; reamputation These procedures, their corresponding CPT® codes, and APC assignments are found in Table 46. Direct Supervision for Outpatient Therapeutic Services In 2010, there was a lot of discussion regarding the requirements under the conditions of participation versus the definition requirements of direct physician supervision. CMS delayed enforcement of direct supervision for therapeutic services provided in critical access hospitals (CAHs) as of March 2010. In the Final Rule, CMS extended this nonwww.aapc.com January 2011 31 facility No new national evaluation and management (E/M) guidelines are established for 2011 … CMS instructs hospitals to keep using their individual internal guidelines, being sure that the guidelines meet the 11 criteria specified in the 2008 Final Rule. enforcement period through 2011 and extended the exception to small rural hospitals with 100 beds or fewer located in a rural area or paid under OPPS with a rural wage index. CMS listened to providers during the year and made some changes to the definition of direct supervision. The updated definition requires the practitioner to be “immediately available” and “interruptible,” but specific references to where the practitioner must be physically located are removed. The removal of reference to geographical location is applicable for both on-campus and off-campus provider-based departments and applies to cardiac rehab, pulmonary rehab, and intensive cardiac rehab. The agency created a list of 16 services, called “non-surgical extended duration services,” for which direct supervision is required at the initiation of the service. Once the patient is stable, general supervision may be provided for the duration of the service. These services are identified in Table 48a. The included services must meet four criteria: 1. May last a significant time 2.Have a low risk of requiring direct supervision once initiated 3. Have a significant monitoring component typically provided by nursing/auxiliary staff 4.Are not surgical services that include recovery time Initiation of these services requires direct supervision; once the treating practitioner deems the patient to be medically stable, general supervision is acceptable. CMS expects the transition from direct to general supervision to be documented in the medical record, but does not specify what this documentation must look like. The agency acknowledges that “the statute does not explicitly mandate direct supervision,” but believes that direct supervision is the most appropriate level for services provided incident-to a physician service. CMS proposes to establish a committee and independent review process to assess the appropriate supervision level for hospital outpatient therapeutic procedures. For the 2012 rule-making cycle, CMS most likely will establish 32 AAPC Coding Edge a timeframe for receiving requests, develop criteria for evaluation of each service, and create or designate a committee. CMS has requested public comment on this proposal. Additional Notable Changes The Patient Protection and Affordable Care Act (PPACA) waives the Part B deductible and coinsurance for certain preventive services payable under the OPPS. Based on classification by the U.S. Preventive Services Task Force (USPSTF), covered preventive services graded as A or B mean the beneficiary coinsurance is waived and, for many of the services, the Part B deductible also is waived. Table 48b contains specific information regarding these services. Changes to the 2011 Medicare Physician Fee Schedule (MPFS) (CMS-1503-FC, found at: www. cms.gov/PhysicianFeeSched/PFSFRN/list.asp) also impact OPPS facilities related to laboratory requisitions and rehabilitation services with payment based on the fee schedule. Beginning in 2011, requisitions for clinical laboratory services paid under the laboratory fee schedule must be signed/authenticated by the physician/non-physician practitioner (NPP). CMS discussed the history of lab requisitions vs. orders in the MPFS proposed rule. CMS also is instituting a “multiple procedure payment reduction” for outpatient therapy services paid under the MPFS. The reduction is 25 percent of the second and subsequent “always therapy” services’ practice expense component. The first unit of the highest valued service is payable at 100 percent; all additional units of the same service or different service are paid at 75 percent. The payment reduction is based on services provided on a single date of service, even if the services are provided by different therapy disciplines. Table 21 in the 2011 MPFS Final Rule lists the services subject to this policy. Denise Williams, RN, CPC, CPC-H, is the director of revenue integrity services for Health Revenue Assurance Associates, Inc. She has been involved with APCs since their initiation. She has worked as corporate chargemaster manager for two health care systems, heavily involved in compliance and coding/billing edits and issues. Achieve HIPAA and HITECH compliance nsure your practice is compliant with the updated HIPAA privacy and security regulations that accompany the American Recovery and Reinvestment Act of 2009 (ARRA) and the Health Information Technology for Economic and Clinical Health Act (HITECH). Stepped-up enforcement includes new breach notification laws with monetary penalties if not enforced, stricter accountability for business associates, and use and disclosure of Protected Health Information (PHI). HIPAA Plain & Simple, second edition, eases your administrative burden by explaining the increased importance the federal government is placing on PHI so that you can conduct your own risk assessment and ensure your physician office staff is appropriately trained. Updated from the bestselling 2003 first edition, this invaluable resource includes: • The popular “What to Do” and “How to Do It” section • Sample business associate agreements • Graphics and charts, timelines, checklists and forms • Health IT company profiles and 12-month HIPAA training ideas • Crisis communication management guidelines • A foreword by Louis W. Sullivan, MD, president emeritus, Morehouse School of Medicine, former secretary, U.S. Department of Health and Human Services • An additional foreword by David Brailer, MD, the nation’s first National Coordinator for Health Information Technology Visit www.amabookstore.com or call (800) 621-8335 to learn more. facility PROFESSIONAL Keep Your Hospital Compliant with OIG’s Work Plan Get a facility’s perspective of what’s in store for 2011. By Jillian Harrington, MHA, CPC, CPC-P, CPC-I, CCS-P I n December’s Coding Edge, we examined the 2011 OIG Work Plan from the perspective of the physician practice (“Center a Work Plan Around 2011 OIG Activities,” pages 44-45). This month, we’ll take a look at items affecting the hospital setting. There are several new items in the hospital section of this year’s Work Plan, as well as returning items from prior years. Although we won’t review these “returning items” in depth, it is important for you to keep them in mind. Determine if they are risk areas for your facility, and decide if you should include them in your own compliance auditing and monitoring plan. Most hospital-related reviews can be found within the Centers for Medicare & Medicaid Services (CMS) portion of the Work Plan. You should focus most of your effort in that section. If you are involved in academic or research medicine, however, be sure to review the Public Health Agencies section; the included information from the National Institutes of Health (NIH) and the U.S. Food and Drug Administration (FDA) usually is helpful when developing your compliance audit plans. Hospital Payments for Nonphysician Outpatient Services This item is specific to hospitals not paid under the Prospective Payment System (PPS). Based on the appropriate regulations, all diagnostic services and other admission services provided one day prior to the admission are considered part of that admission. The OIG will review all outpatient claims paid for that one day time period prior to admission to see if they meet these criteria. As a non-PPS facility, have edits built into your system to check for these services before the claim goes to the payer. If you do not have these types of edits currently built into your systems, adding this to your audit plan for the year is a great start. Then, work with your 34 AAPC Coding Edge software vendor and/or your clearinghouse to get these edits built into your systems. Although this is not an item for PPS hospitals, this is a good reminder of the three day window, and the recent changes there. Statutory changes were made to the three day window in June 2010, and the Inpatient Prospective Payment System (IPPS) rule for 2011 also includes rules on those changes. In basic terms, the payment window is now broken into two separate time frames: the day of admission, and the three days prior to admission. On the day of admission, all services, diagnostic and non-diagnostic, provided by the admitting hospital or any of its entities must be bundled to, and billed as part of, the inpatient admission. Under the old rule, only diagnostic and related non-diagnostic services had to be bundled into that hospital bill. The definition of “related” now is redefined by CMS to include any outpatient service “clinically associated with the reason for a patient’s inpatient admission.” There is an established item in the 2011 OIG Work Plan dealing with the three day window, although it’s uncertain how these new rules will interact with this already established review. Be sure you’re aware of what the current rules are, and that your systems are programmed to edit based on those guidelines. Medicare Excessive Payments In general, the biggest errors seen in HCPCS Level II coding are units of service errors. The OIG is concerned that there are excessive payments being made due to such coding errors. Hospitals wishing to review for this easily can incorporate this into an existing coding auditing plan. Because much of this coding is charge master driven, hospitals not only should examine the individual claims, but also review the process of how a claim is coded. This may provide insight on if, and how, claims are being miscoded. facility … all deaths within 24 hours of when a patient is removed from a restraint or seclusion, must be reported to CMS … There is some concern by the OIG as to whether all deaths are being reported, and that the reporting process might somehow hinder the investigation process. Hospital Occupational Mix Data The federal government implemented an occupational mix program to create more accuracy in the wage index, due to a lack of confidence in those figures. Now, there appears to be some concern about the accuracy of the data being submitted to CMS to create the more accurate wage index data. Examine your process for putting together your data for submission for the occupational mix. Are you aware of this process? How much effort is your facility putting into making sure good quality data is submitted? Hospital Reporting for Restraint and Seclusion Related Deaths Conditions of Participation state that all restraint- and seclusion-related deaths, as well as all deaths within 24 hours of when a patient is removed from a restraint or seclusion, must be reported to CMS. The agency then will determine if an investigation is warranted. There is some concern by the OIG as to whether all deaths are being reported, and that the reporting process might somehow hinder the investigation process. Determine first who is currently handling this process for your facility. The process needs to be reviewed to verify that you are, in fact, reporting all appropriate deaths to CMS. All deaths occurring within 24 hours of the removal of the restraint or seclusion should be reported as such. Medicare Brachytherapy Reimbursement This is a general review of brachytherapy services in the hospital setting to determine whether services were paid in accordance with Medicare requirements. Does your facility perform the placement of these radioactive sources? If so, your facility should conduct reviews to verify that requirements as put forth under Medicare Improvements for Patients and Providers Act (MIPAA) are being met. MIPAA extended the cost to charge payment methodology for brachytherapy devices through the beginning of 2010, thereby avoiding the planned change in 2008 to the Outpatient Prospective Payment System (OPPS) payment methodology. Although these changes focused on the devices themselves, don’t focus your review solely on the device. Make sure you review the entire service to catch any potential errors because the OIG surely will during its reviews. Replacement of Medical Devices There are many instances when a device is replaced in a patient, and that device is received at a reduced cost, or at no cost. This must be reflected in billing to the program. This item from the Work Plan focuses on that area, reviewing inpatient and outpatient claims to determine if they were submitted properly when the device was received at a reduced cost. Your facility should have a process in place where your purchasing (or appropriate) department works closely with your billing staff to make sure billing is done properly when the facility does not pay full price for any medical device. Hospital Inpatient Outlier Payments Outliers have been an issue for years, showing up on the Work Plan for a year or two and then going off. They have shown up here again in 2011, with a specific focus on the inpatient realm. There appears to be some new concern because of an upswing in outlier payments in 2009, as well as a large number of whistleblower suits on the same topic. If you are a facility with a high number of outlier payments, take a look at your processes. You also may wish to put a pre-submission process in place for any outlier claim to verify that coding and charges are accurate. www.aapc.com January 2011 35 facility To discuss this article or topic, go to www.aapc.com Medicaid The Medicaid section of the Work Plan does not have any new hospital-related items, and the established hospital-related items seem to be related more to “controls” than to items for which hospitals can prepare. As mentioned in December’s OIG article, your state Medicaid integrity official may have released a work plan of its own. Research your state to determine the status of the Medicaid Integrity Program, and to determine whether they’ve released a work plan. It could be a good companion to the OIG document. Be Prepared To avoid scrutiny from the OIG, be prepared. Have an active compliance program, and not simply a written program that sits on a shelf. Audit and monitor regularly throughout the year. Educate based on what you find in that auditing. Review the OIG 2011 Work Plan—and not simply the new aforementioned items, but also the items that have appeared previously, such as observation services, hospital re-admissions, and provider based entities. Examine what types of services are risk areas for your organization, and incorporate all of these issues into your own work plan for the year. By using the governments own roadmap to their work, you can make your organization more compliant and, hopefully, a more efficient and effective facility. Jillian Harrington serves as president and CEO of ComplyCode, a health care compliance consulting firm based in Binghamton, N.Y., and has more than 17 years of experience in the health care industry. She is the former chief compliance officer and chief privacy official. She teaches CPT® coding as an approved AAPC instructor and is a member of AAPC’s ICD-10 curriculum development team. She holds a bachelor’s degree in health care administration from Empire State College and a master’s degree in health systems administration from the Rochester Institute of Technology (RIT). 2011 Coding Books and Guides: Everything you need to maximize your practice’s reimbursement at your fingertips. Choose the specialties that you want to order! (choose as many as desired) Cardiology Coder’s Survival Guide Radiology Coder’s Survival Guide Coding & Reimbursement Survival Guide Urology Coder’s Survival Guide CPT® Survival Guide Gastroenterology Survival Guide General Surgery Survival Guide ICD-9 2010 Survival Guide E/M Survival Guide Modifier Survival Guide Orthopedic Survival Guide Ob-Gyn Coder’s Survival Guide Otolaryngology Survival Guide Part B Survival Guide Path/Lab Survival Guide Procedural Coding Survival Guide Pediatrics Survival Guide To order, call (866) 228-9252 Make sure you are on top of the latest coding changes with our survival guides tailored to your specialty. These easy-to-read how-to manuals will help you eliminate coding confusion and select the correct code for every claim. Every chapter is packed with practical tips and expert strategies to ensure that your practice gets every penny it deserves. Choose one or more! Online version: otolaryngology $69 Print version: $99 Coder’s Survival Guide-2011 Or log on to http://www.supercoder.com/ guides today! The Coding Institute • P.O. Box 933729, Atlanta, GA 31193-3729 • (866) 228-9252 • Fax: (800) 508-2592 Email: [email protected] 36 AAPC Coding Edge a coder's view Repair Relationships: Approach Providers from Their Viewpoint By Lynn S. Berry, PT, CPC Find out what a typical day in the life of a physician is like. As a coder, you strive to help physicians and other health care providers document more clearly so you can code correctly and ensure claims are paid. To that end, you may need to query a provider regarding a particular medical record entry. You may be met with resistance or told there is no time to talk at the moment. The encounter may be pleasant or it may not, depending on the physician and the day. Over the years, I have heard many coders and others complain about their “treatment” by providers. Perhaps it would help to see things from their viewpoint. “The Vanishing Oath,” a film from Crash Cart Productions, LLC, does just that. In the documentary, a physician and a social worker spend several years going around the country interviewing other physicians, economists, professors, and average citizens. The physician tries to determine if the burnout he feels personally is prevalent in the medical community, and how it affects the practice of medicine and patient perceptions. The film describes a typical day in the life of an emergency department (ED) physician and the stresses he encounters as he tries to provide quality patient care. It brings out the emotions felt by physicians as they meet administrative, government, and other obstacles that prevent them from caring for patients the way they envisioned when they started their careers. It even speaks about the coders’ role in medicine. This film is eye-opening for non-clinicians who think of physicians as highly paid and revered individuals, when really they are ordinary people who are feeling economically, physically, and emotionally pressured on a daily basis. Think about the number of physicians who are looking at changing their roles, getting away from private practice, changing their hours, or leaving medicine altogether. This film explains why. Watch this 90-minute documentary for an uncommon educational presentation at a local chapter meeting. Perhaps it will help you better understand the physicians’ point of view and allow you to develop a more empathetic approach to dealing with the providers you encounter every day. A copy of “The Vanishing Oath” may be obtained at: www.crashcartproductions. com/vanishing-oath/. Lynn Berry, PT, CPC, had over 35 years of clinical and management experience before beginning a new career as a coder and auditor and, later, a provider representative for a Medicare carrier. She now has her own consulting firm, LSB HealthCare Consultants, LLC, furnishing consulting and education to diverse provider types. She has held a variety of AAPC local chapter offices and continues as one of the directors of the St. Louis West Chapter. www.aapc.com January 2011 37 newly credentialed members newly credentialed members Tonia Melissa Deacon, CPC Aniak AK Angie Meade, CPMA Harvest AL Monica Bragg, CPC Huntsville AL Lee Horton, CPC, CPMA Huntsville AL Gina Pieczynski, CPC Laceys Spring AL Ashley Carr, CPC Montgomery AL Sara Thomas, CPC Montgomery AL Amanda Shaffer, CPC Prattville AL Rebecca Hatcher, CPC Wetumpka AL Nancy Spaulding, CPC Bella Vista AR Lisa Deleta Davis, CPC Jonesboro AR Donna Lou St. John, CPC Lonoke AR Jana Phillips, CPC White Hall AR Swee-Ai Milne, CPC Cottonwood AZ Laura V Saldivar, CPC, CPC-H Gilbert AZ Susan Swapp, CPC Gilbert AZ Helena B Polk, CPC Pinon AZ Catiria Isla, CPC Somerton AZ Debra K Borden, CPC Tucson AZ Stephanie D Encinas, CPC Tucson AZ Eileen M Jacobson, CPC Tucson AZ Kathleen J Lampert, CPC Tucson AZ Annette Ramirez, CPC Tucson AZ Susan Faye Vien, CPC Tucson AZ Dana Hasten, CPC, CPC-H Winslow AZ Henry Bonner, CPC Altadena CA Linda Joyce Williams, CPC, CPC-H Canyon Country CA Marynel Cruz, CPC Clovis CA Rebecca Hill, CPC-H Clovis CA Artemiss L Pourmand, CPC Glendale CA Rena L Pacheco, CPC La Habra CA Rosa Lazcano, CPC La Jolla CA Regine Monfette, CPC Long Beach CA Diana Peykar, CPC, CPC-H Northridge CA Karen Amador, CPC Oakley CA Diana Napolitano, CPC Pomona CA Larry Impson, CPMA Rio Linda CA Tashina Trimble, CPC Sacramento CA Annabelle Perez Jaballa, CPC San Francisco CA Yinna Zhou, CPC Santa Clara CA Martin Rambaud, CPC Simi Valley CA Sue Leamons, CPC, CPMA, CEMC Stanford CA Jason Michaels Truitt, CPC Stockton CA Marsha P McRorie, CPC, CPC-H, CIRCC Sunnyvale CA Julie Papa, CPC Temple City CA Lisa Wurzer, CPC Tustin CA Sheh-Jiuan Tay, CPC, CPC-H Valencia CA Marriym Lateefah Lofton, CPC Vallejo CA Valerie Madison, CPC West Hills CA Julia Lea Hatcher, CPC Aurora CO Patricia J Abila, CPC Colorado Springs CO Mindy Helm, CPC Colorado Springs CO Kerry K Ochoa, CPC Colorado Springs CO Naomi Pennington, CPC Colorado Springs CO Kathryn A. Rountree, CPC Colorado Springs CO Vicki L Faris, CPC, CPMA, CEMC Durango CO Cynthia Kay Glefke, CPC Durango CO Sherry E Holt, CPC, CPMA Durango CO Linda K Peterson, CCS-P, CPMA Durango CO Nancy Price, CPC Thornton CO Michele Marie Krpata, CPC, CPMA East Hartford CT Sharon S Donelli, CPC, CPC-H, CPMA Kensington CT Jean Carusone, CPC Northford CT Sandra Onate, CPC Norwich CT Laura Brown-Johnston, CPC New Castle DE Alice Ramey, CPC New Castle DE Janice M Jones, CPC Townsend DE Peggy Cauthen, CPC Bradenton FL Efrain Duarte, CPC Bradenton FL Erin Nigro, CPC-A, CPMA Clearwater FL Sherrie Wilhelm, CIRCC Clearwater FL Elizabeth Fuentes, CPC Coral Springs FL Arleene Mahadeo, CPC Coral Springs FL Leslie Beaman, CPC Crestview FL Jan C Harris, CPC Dania FL Philip R. DeLuca, CPC Deerfield Beach FL Cynthia H Blanton, CPC Ft Lauderdale FL Linda K Reid, CPC Ft Lauderdale FL Rae Lynn Bailey, CPC Gainesville FL Diane Barco, CPC Gainesville FL Leticia A. Cohens, CPC Gainesville FL Julian Dashan Smith, CPC Gainesville FL 38 AAPC Coding Edge Linda M Beeman, CPC, CPMA Hampton FL Natalie Hernandez, CPC Hialeah FL Donna G O'Hern, CPC, CPMA, CEMC Lake Butler FL Ann Marie Marks, CPC Lake Worth FL Lois M Smith, CPC Lakeland FL Maria Emily Guzman, CPC-H Largo Mar FL Beverly A Greenidge, CPC Lauderhill FL Amy Hendon, CPC Lutz FL Ambreen Khan, CPC Miami FL Katrina Lymon, CPC Miami FL Eduardo Porras, CPC, CPMA Miami FL Alexi Ruiz, CPC Miami FL Guerda Louissaint, CPC Miramar FL Patricia Dickenson, CPC Ocala FL Jennifer Jean Ehlke-Jotch, CPC Odessa FL Gredel Ann Buzbee, CPC Old Town FL Lisa Ridgley, CPC Oldsmar FL Nicole Newton, CPC Panama City FL Heidi Philbrick, CPC Pembroke Pines FL Richard Rohlehr, CPC Port Charlotte FL Amanda Mullikin, CPC Port Saint Lucie FL Christmarie Camacho, CPC Riverview FL Lesley Dingman, CPC Sarasota FL Simone Roberts, CPC Sunrise FL Michael Bach, CPC Tampa FL Keicia Tamara Cornwall, CPC, CPC-H, CPC-P Tampa FL Amy Diane Lawrence, CPC Tampa FL James Pfeiffer, CPC Tampa FL Joanne Long, CPC Titusville FL Idolka Zoe Mesa, CPC, CPMA, CEMC West Palm Beach FL Jodi Mazzone, CPC, CPMA, CEMC Weston FL Deborah Ann Eason, CPC, CPC-H Augusta GA Karen Varnedoe, CPC Brunswick GA Sherion Nettles, CPC Douglasville GA Genieve R Nottage, CPC, CPMA, CPC-I Locust Grove GA Henry Asemota, CPMA Marietta GA Zadie Lee Pressley, CPC Newnan GA Samantha Stensland, CPC Powder Springs GA Elizabeth D Westbrooks-Steed, CPC Stockbridge GA Rose Gibbs, CPC Suwanee GA Janice Ann May, CPC Ankeny IA Chelsey Storey, CPC Urbandale IA Mariah Courtright, CPC Boise ID Aimee Webb, CPC Boise ID Tamie Chapman, CPC Donnelly ID Carol J Gilbert, CPC, CPMA Downey ID Kathy Arreola, CPC New Plymouth ID Amy K Webster, CPC Rexburg ID Cynthia Burley, CPC Twin Falls ID Kristy L Verthein, CPC Beecher IL Kathleen Ellingson, CPC-H Chicago IL Maria Andrea Vega, CPC Chicago Heights IL Brenda Wilson, CPC Chicago Heights IL Sharon L Thompson, CPC Country Club Hills IL Paige McWhorter, CPC Effingham IL Angie Henson, CPC Highland IL Mindi J Marcum, CPC, CIRCC Le Roy IL Jessica Eccles, CPC Loves Park IL Brenda Pichon, CPC-H Monticello IL Angie M Craig, CPC Olympia Fields IL Stephanie Annette Garland-Lloyd, CPC Robbins IL Ciarra Montoya Davis, CPC Swansea IL Heather O'Dell, CPC Toledo IL Rhonda K Moegerle, CPC Brownsville IN Sherri Brasher, CPC Chandler IN Roy Arnold, CPC-P Evansville IN Andrea R Winfield, CPC Evansville IN Debbie Hight, CPC Franklin IN Beth Ann Lahman, CPC Greens Fork IN Nataya Austin, CPC Indianapolis IN Sandra Chapman, CPC Indianapolis IN Amy Jointer, CPC Indianapolis IN Becky Ann Younger, CPC Indianapolis IN Jacqueline Kay Baker, CPC Martinsville IN Nicole Koehler, CPC Richmond IN Kimberly Sue Schroeder, CPC Richmond IN Melissa Ann Edwards, CPC, CPMA Shelburn IN Cynthia Baumgardner, CPC Overbrook KS Pat Ann Rentfro, CPC St Marys KS Kari Deters, CPC Topeka KS Tama Haggard, CPC Topeka KS Tammy Lynn Poore, CPC Bowling Green KY Julie Meiers, CPC Brandenburg KY Amy Hyman, CIRCC Brooks KY Julie Ann Rauch, CPC California KY Carol Ann Walerius, CPC California KY Anita C Sabelhaus, CPC Dayton KY Kim Lynn Perry, CPC Ewing KY Tonya Renee Mitchell, CPC Florence KY Andrea G Quillen, CPC, CPC-H, CIRCC Florence KY Marcia Lynn Waite, CPC Ft Thomas KY Cathy Lynn Wise, CPC Glendale KY Rhonda Robinson, CPC Hillsboro KY Janice Gabbard, CPC London KY Julie F Pope, CPC, CPC-H, CPMA, CPC-I Louisville KY Teri Lynn Trail, CPC Louisville KY Tammy Ann Smith, CPC Union KY Lisa Jett, CPC Vanceburg KY Donna R Duhon, CPC Abbeville LA Ronada Shelton, CPC Baton Rouge LA Tiffany Richard, CPC Bunkie LA Marie Brown, CPC Andover MA Michelle M Chmura, CPC Belchertown MA Kerri Jo Rauschmier, CPC Belchertown MA Stacey Robinson, CPC Franklin MA Jennifer L Calkin, CPC Ludlow MA Jodi Hermanski, CPC Pittsfield MA Andrea Brown-Thomas, CPC Sandwich MA Jo Ann Cabral, CPC Waltham MA Sonja Fraser, CPC Columbia MD Madhavi Surapaneni, CPC Gaithersburg MD Angela Tablada, CPC Germantown MD Blanche Missinga-Mahop, CPC Lanham MD Laxmi Tankala, CPC N Potomac MD Denise Huber, CPC Sykesville MD Lisa D Nile, CPC Bowdoinham ME Tina Ann Cook, CPC Brunswick ME Faith H Poulin, CPC Portland ME Erin Mann, CPC-H Battle Creek MI Raquel M Saari, CPC Dollar Bay MI Tracy Lynn Marschke, CPC Eau Claire MI Nicole Payne, CPC Grosse Pointe Woods MI Jodi Vaughn, CPC Williamsburg MI Lucinda Lylan Suonvieri, CPC Floodwood MN Faith Ellen Bauer, CPC, CPC-H, CPC-P Woodbury MN Kelli LeAnn Thompson, CPC Camdenton MO Danne Ryan, CPC Ozark MO Todd G Beedy, CPC St Charles MO Phyllis Britton, CPC Waynesville MO Barbara James Newsome, CPC Jackson MS Erica Whipps, CPC Jackson MS La-Keisha Michelle White, CPC Raymond MS Pamela Gabel, CPC Billings MT Jewel Ann Lahr, CPC Browning MT Dawna Raiser, CPC Butte MT Alliz Parsons, CPC Kalispell MT Melissa Horner, CPC Lolo MT Karla Murphy, CPC Missoula MT Sherry Simcox, CPC Boone NC Robin Leguillow, CPC Cary NC Justine Baker, CPC Charlotte NC Loretta Robinson, CPC, CPC-H Charlotte NC Amber Ayers, CPC Clemmons NC Catherine H Erickson, CPC, CPC-H Durham NC Kim Walsh, CPC Durham NC Jennifer M S Edwards, CPC Fletcher NC Tina Dixon, CPC Grimesland NC Kelley Wade, CPC Henderson NC Rhonda Walker, CPC High Point NC Rebecca Woodward, CPC, CPMA, CEMC High Point NC Brittany Branam, CPC Mooresville NC Kristin Langley, CPC Morrisville NC Lora Chamblin, CPC Mt Airy NC Bill W Battershall, CPC Raleigh NC Theresa Somerville, CPC Raleigh NC Trikina Williams, CPC Raleigh NC Ellen Grataski, CPC Snow Camp NC Alberta Purvis, CPC Wagram NC Jenny Ann Carver, CPMA Waynesville NC Donna Helgeson, CPC, CPMA Bismarck ND Stacey Slaymaker, CPC Albion NE Anne Harvey, CPC Lincoln NE Pamela Johnson, CIRCC Lincoln NE Connie L Anderson, CPC Oakland NE Becky Bellin, CPC Odell NE Cynthia (Cindee) Ann Reichert, CPC Scottsbluff NE Rhonda R Schafer, CPC Scottsbluff NE Janine Crawley, CPC-H Alton Bay NH Kathleen C Blanchard, CPC Ashland NH Katie Sylvain, CPC Fremont NH Carole Jutras, CPC Hookset NH Gayle Edlund, CPC Portsmouth NH Barbara Richer, CPC Berlin NJ Gloria A Miller, CPC, CPMA Cherry Hill NJ Lana Juskin, CPC East Hanover NJ Anu Koshy, CPC East Windsor NJ Samantha Nardolillo, CPC Freehold NJ Maria P Sanchez, CPC, CPC-P Jackson NJ Adelina Spektor, CPC-H Matawan NJ Josephine Portis, CPC Morristown NJ Shahita Baker, CPC Pennsauken NJ Andrea Langston, CPC Pennsauken NJ Deborah R Petrosky, CPC Ridgewood NJ Steven Alan Wahl, CPC, CPMA Roseland NJ Beverlyjean K Jenkin, CPC South Plainfield NJ Olaya Delgado, CPC Artesia NM Tammy D Baugh, CPC Farmington NM Amy K Carlson, CPC, CPC-H, CPC-P Farmington NM Sheryll J Turner, CPC-H Farmington NM Maureen DeArmond, CPC Las Cruces NM Yvonne Pina, CPC Las Vegas NM Michelle Kimbrell, CPC Tucumcari NM Betsy Priest, CPC, CPC-H Avon NY Vyacheslav Kurdov, CPC Brooklyn NY Anne Augustyn, CPC Depew NY Sandra Verry, CPC Maine NY Christopher Holder, CPC Poughkeepsie NY Elizabeth Dimino, CPC Staten Island NY Mercedes Rivera, CPC-H Wappingers NY Aprille Marie O'Hara, CPC Westdale NY Katy Elaine Davis, CPC, CPMA Amanda OH Char Cihon, CPC Ashtabula OH Elaine Gregory, CPC Avon Lake OH Kathryn A Mayer, CPC Avon Lake OH Yara G Roman, CPC Bedford OH Marlene Harris, CPC Bedford Heights OH Bonny J Kubicki, CPC Brook Park OH Theresa Lynn Paukert, CPC Brunswick OH Sara Davis, CPC Canal Winchester OH Michelle Simpson, CPC Canton OH Yvonne K Shaffer, CPC Chippewa Lake OH Kim Hassard, CPC Cincinnati OH Clara Yvonne Johnson, CPC Cincinnati OH Jacqueline Kay Winslow Davis, CPC Cincinnati OH Stephanie L Gross, CPC Cleveland OH Barbara Joyce Stiner, CPC Cleveland OH Joyce Thomas, CPC Cleveland OH Barbara A Petro, CPC Columbia Station OH Vicki Blawut, CIRCC Columbus OH Cynthia Evans, CPC Delaware OH William Haines, CPC Eastlake OH Peggy Campbell, CPC Eaton OH Kristie A Atkins, CPC Elyria OH Clarissa Edwards-Wallace, CPC Euclid OH Amy Dale, CPC Grafton OH Melissa Huffman, CPC Harrison OH Alice Yessayan, CPC Highland Heights OH Cathy Ann Richman, CPC Liberty Township OH Staci Booth, CPC Lockland OH Melanie Rene Leonardi, CPC Medina OH Danielle Lutz, CPC New Albany OH Candy James, CIRCC Pataskala OH Taylor McHale, CPC Powell OH Diane Marie Moorman, CPC-H Spencerville OH Nicole Kinney, CPC Vermilion OH Katherine J Goodell, CPC Cleveland OK Denice R Finch, CPC, CPC-H Hobart OK Adrienne Brandenburg, CPC Oklahoma City OK Bobbie Davis, CPC-H Oklahoma City OK Arleen Moss, CPC Oologah OK Francine Esche, CPC Tulsa OK Lisa Souza, CPC Tulsa OK Kimberly Boyd, CPC Tuttle OK Penny Vaughn, CPC Wayne OK Carley E Spangler, CPC Beaverton OR Kimberly Smith, CPC Bend OR Belinda C Baldwin, CPC, CPMA Eugene OR Rebecca O'Dell, CPC Hillsboro OR Keiva Bartel, CPC La Grande OR Spring Cook, CPC Midland OR Chanda Arscott, CPC-H, CPC-P Oakland OR Lindi Moore, CPC-P Roseburg OR Heather Kofoid, CPC Springfield OR Connie Esther, CPC Tillamook OR Tina Potter, CPC Veneta OR Patricia McKinstry, CPC Warm Springs OR Bernadette Potetz, CPC Allentown PA Wendy Weigand, CPC Allentown PA Lisa H Zamora, CPC Allentown PA Jennifer Boyer, CPC Auburn PA Cathie J Fruit, CPC Bloomsburg PA Nicole Hammerly, CPC Breinigsville PA Pamela Kunselman, CPC Brookville PA Sandra Newstein, CPC, CPC-H, CPC-P, CPMA Chadds Ford PA Rhonda Kay Gayman, CPC Chambersburg PA Danielle Louise Mills, CPC Chambersburg PA Catherine Eileen Stobo, CPC Danville PA Doris C Mulligan, CPC-H Erie PA Kelly L Harmon, CPC Fayetteville PA Linda A Johnston, CPC Folcroft PA Karen S Sweesy, CPC, CPMA Freedom PA Christine Powell, CPC Hanover PA Diane Greco, CPC Hatboro PA Lisa Crumling, CIRCC Hellam PA Debra Zimnoch, CPC Hunlock Creek PA Michelle Kreiser, CPC Jonestown PA Christopher Valentino Reveron, CPC Kings of Prussia PA Bambi Lynne Cioffi, CPC Lancaster PA Kristen Donovan, CPC Lansdale PA Jasmine Leguillow, CPC Levittown PA Betsy Miller, CPC Mertztown PA Betsy I Dominick, CPC New Castle PA Ann Marie Patsy, CPC New Castle PA Robert Albert Phillips, CPC New Castle PA Lucy Marie Sallmen, CPC New Castle PA Rebecca Ann Sallmen, CPC New Castle PA Pamela Jo Stoops, CPC New Castle PA April Lea Miller, CPC Nicktown PA Stephanie George, CPC Palmyra PA Carol Furness, CPC Parkside PA Adriene Bey-Brown, CPC-H Philadelphia PA Shalina Brown, CPC Philadelphia PA Carrie Beth Fisher, CPC, CIRCC Philadelphia PA Rochelle Redding, CPC Philadelphia PA Jacqueline Mehalich, RN, CPC, CPC-H Pittsburgh PA Raynuld Reyna, CPC Secane PA Pradnya Sathaye, CPC-H Whitehall PA Jennifer Berlew, CPC Womelsdorf PA Andrea Lynn Webster, CPC Adams Run SC Tammy Strickland Bickerstaff, CPC Charleston SC Tiffany Lee Cribb, CPC Charleston SC Michelle Lee Hurt, CPC Charleston SC Diane Meadows, CPC Charleston SC DeeDee Murray, CPC Charleston SC Patricia M Palmer, CPC Charleston SC Roslyn S Peterson-Hale, CPC Charleston SC Patricia Windham, CPC, CPMA Charleston SC Sandra Annette Williams, CPC Darlington SC Catherine Dudley, CPC Florence SC Melisa C Hewitt, CPC Florence SC Dena Robinson, CPC Florence SC Timmi Caskey, CPC Fort Mill SC Kimber A Bullington, CPC Goose Creek SC Evelyn DeCastro, CPC Goose Creek SC Angel Bice Cline, CPC Greenwood SC Janice Carr, CPC Hilton Head Island SC Tonya Plair, CPC Johnston SC Nathan Edward Bartlett, CPC Mount Pleasant SC Sharon Denise Davis, CPC North Charleston SC Laura W Mayes, CPC North Charleston SC Tamra Marie Stebbins, CPC North Charleston SC Suzanne Brown, CPC Pawleys Island SC Vonda Pickelsimer, CPC Piedmont SC Katherine Maureen Melton, CPC Ravenel SC newly credentialed members Julie Lyn Davis, CPC Summerville SC Sandra Marie Effler, CPC Summerville SC Lindsy Gutierrez, CPC, CPMA Summerville SC Lisa M Hair, CPC, CPMA Summerville SC Cindy Lou Riscart, CPC Summerville SC Angela Boyd, CPC West Columbia SC Donna Marie Schenkel, CPC Brandon SD Kathi Lynne Sorter, CPC Sioux Falls SD Kanisha Williams, CPC Brentwood TN Cynthia Herron, CPC Chattanooga TN Lindsey D Vaughn, CPC, CPMA Hixson TN Wendy Annette Rhodes, CPC, CPC-H, CPMA Jefferson City TN Theresa L Byrd, CPC Kingsport TN Terri Fey McDonough, CPC Lebanon TN Trina Ewing, CPC Memphis TN Diana Hollis, CPC Murfreesboro TN Jaime Sarten, CPC Murfreesboro TN Peggy J Coleman, CPC-H Nashville TN Amy Hixon, CPC Rutledge TN Maureen E Foster, CPC, CPMA Signal Mountain TN Priscilla Alfaro, MD, CPC Austin TX Judy Devore, CPC Austin TX Vicky C Foss, CPC Austin TX Constance Stagman, CPC Austin TX Sandra Lynn Keahey, CPC Benbrook TX Christy A Miller, CPC Charlotte TX Douglas Arrington, CPC, CPC-H, CPMA Dallas TX Deirdra L Gaines, CPC Duncanville TX Wathen Strong, CPC Frisco TX Angelica Maria Martinez, CPC Ft Worth TX Diann Kelley, CPC Garland TX Guinnevere Stevens, CPC Garland TX Dallia Jones, CPC Georgetown TX Courtney Cofer, CPC, CPMA Kyle TX Elaine Farias, CPC La Vernia TX Theresa Vallery-McCoy, CPC Leander TX Amy Pippin, CPC Lone Oak TX Jessica Faircloth, CPC-H Longview TX Leslie O'Neal, CPC McKinney TX Senia Rascon, CPC McKinney TX Nancy Barron, CPC Mesquite TX Dale H Hill, CPC Nacogdoches TX Roxanne Bazan, CPC Pleasanton TX Stacy Williams, CPC Princeton TX Cynthia Marie Funari, CPC Round Rock TX Gloria Alaniz, CPC San Antonio TX Nikki Lamberty, CPC San Antonio TX Sarah Bueno, CPC Tyler TX Froncel Burns, CPC Tyler TX Kristal Rodriquez, CPC Tyler TX Regina Karen Whitley, CPC Tyler TX Pamela J Biffle, CPC, CPC-P, CPC-I Watauga TX Vickie Quinn, CPC Windcrest TX Becky J Wilson, CPC, CPMA Winona TX Angela Miller, CPC Herriman UT Stacie Tippetts, CPC Layton UT Chelsey Marie Larson, CPC Roy UT Valeria Jane Knotts, CPC Bentonville VA Kathleen W Foster, CPC, CPMA Catlett VA Amanda N Worlds, CPC Chesapeake VA Mary Colleen Mescall, CPC, CPMA, CPC-I Chesterfield VA Robin Osler Hayes, CPC, CPMA Forest VA Tamara A Phillips, CPC Richmond VA Maire A Young, CPC, CPMA Stafford VA Angela Frank Gagnon, CPC, CPC-H Virginia Beach VA Nora Hodge, CPC Virginia Beach VA Carol Suzan Tomala, CPC Virginia Beach VA M LaNeice Watson, CPC-H Virginia Beach VA Dawnelle R Sager, CPC, CPMA Weyers Cave VA Debbie Robertson Tabb, CPC Newport VT Tammy Cox, CPC Bremerton WA Cecilia Maskell, CPC Fircrest WA Jennifer Busselle, CPC Lacey WA Arcell Dungca, CPC McChord AFB WA Gustavo Adolfo Aviles-Espinosa, CPC Olympia WA Molly Miller, CPC Seattle WA Yuliya Petrov, CPC, CPMA Seattle WA Jessica R Pisca, CPMA Seattle WA Frances Mauritson, CPC Shelton WA Leanne Dukes, CPC Tacoma WA Julie Schrag, CPC, CPC-H, CPMA Tukwila WA Christine J Badora, CPC Green Bay WI Jennifer L Fye, CPC Green Bay WI Ellen Neibrand, CPC Waterford WI Laura Kudronowicz, CPC Wausau WI Kathy Williams deHaan, CPC Cody WY Patricia Nicole Lawson, CPC Ft Washakie WY Cindy Linton, CPC Powell WY Vickie Prante, CPC Powell WY Apprentices Rosemary Bell, CPC-A APO AE Clifton Edwards, CPC-A APO AE Tracey-Ann Jackson, CPC-A APO AE Shanna Vose, CPC-A APO AE Nicole Zenke, CPC-A APO AE Katherine Hill, CPC-A Bel Air AE Michele Boucher, CPC-A Hooksett AE Annette Fleming, CPC-A Mooresville AE Donald R Page, CPC-A North Bend AE Jennifer Lesley, CPC-A Rosedale AE Charlene Kilinski, CPC-A Wall AE Judith Marsh, CPC-A Wells AE Nancy Lynn Brown, CPC-A Andalusia AL Amy Thomas, CPC-H-A Dothan AL Barbara Veneziano, CPC-A Enterprise AL Ronda McLeod, CPC-A Fairhope AL Teresa Haynes, CPC-A Hartselle AL Venetia Langland, CPC-A Homewood AL Jeannie Teague, CPC-A Starrett AL Amanda Whitley, CPC-A Jonesboro AR Tiffany Basha Williams, CPC-A Little Rock AR Cheryl Moore, CPC-H-A Pine Bluff AR Lynn Saenz, CPC-A Mesa AZ Anne K Hoge, CPC-A Phoenix AZ Dora Beltran, CPC-A San Luis AZ Melissa Gonzalez, CPC-A Scottsdale AZ Jaime Camacho, CPC-A Somerton AZ Danielle Ernestine Beeaff, CPC-A Tucson AZ Emmie S Gouvisis, CPC-A Tucson AZ Elizabeth J Guerra, CPC-A Tucson AZ Sucheta M Vyas, CPC-A Tucson AZ Lauren G Marscher, CPC-A Apple Valley CA Carey Cameron, CPC-A Ben Lomond CA Eufrocinita Manalansan, CPC-A Buena Park CA Ani Stepanian, CPC-A Burbank CA David Howe, CPC-A Cerritos CA Nallammai Vijayakumar, CPC-A Cerritos CA Sonja Gil, CPC-A Clovis CA Virginia Hillhouse, CPC-A Concord CA Jeffrey Roth, CPC-A Cypress CA Sarah Corpuz, CPC-A Daly City CA Karen Jones, CPC-A El Cerrito CA Jerry Hammond, CPC-A Fresno CA Diane Tarifa, CPC-A Galt CA Jody Mullen, CPC-A Garden Grove CA Ronald Murphy, CPC-A Glendale CA Ronald Murphy, CPC-A Glendale CA Sara Jane Traylor, CPC-A Hesperia CA Karen S Gilbert, CPC-A Irvine CA Charles E Jones, CPC-A La Puente CA Monica L Quesada, CPC-A Lake Forest CA Theresa Beam, CPC-H-A Lincoln CA Anthony E Mckee, CPC-A Long Beach CA Colette A Dryden, CPC-A Los Angeles CA Leticia Suniga, CPC-A Mission Hills CA Givvenchy Viridiana Velazquez, CPC-A Murrieta CA Timothy Walker, CPC-A Ontario CA Bianca Gallegos, CPC-A Pittsburg CA Cyndie Myers, CPC-A Pittsburg CA Brenda Sinjem, CPC-A Placentia CA Shirley L McGowen, CPC-A Redondo Beach CA Michelle Mutuc, CPC-A Rosemead CA Mercy Flora Ravi, CPC-A Sacramento CA Jonathan Haile, CPC-A San Luis Obispo CA Hao Phan, CPC-A San Mateo CA Gay Sue Hemming, CPC-A San Pablo CA Sherrie Chesnut, CPC-A Santa Clarita CA Sepehr Samadani, CPC-A Tarzana CA Lillian J. Galindo-Bryson, CPC-A Walnut Creek CA Sandra Kim Bale, CPC-A Whittier CA Farah Safaei, CPC-A Woodland Hills CA Raquel Villalpando, CPC-A Yuba City CA Teilene Bliss, CPC-A Aurora CO Andrea Laca, CPC-A Castle Rock CO Julie Joy Yashur, CPC-A Castle Rock CO Dawn Barberot, CPC-A Colorado Springs CO Shaun Cox, CPC-A Colorado Springs CO Sonja V Hurtado, CPC-A Colorado Springs CO Debbie Kindt, CPC-A Colorado Springs CO Rhiannon Lee, CPC-A Colorado Springs CO Edith Marie Nelson, CPC-A Colorado Springs CO Christina Oran Nottoli, CPC-A Colorado Springs CO Amanda Christine Toney, CPC-A Fountain CO Stephanie DeRosa, CPC-A Branford CT Joan Lang, CPC-A Branford CT David Miller, CPC-A Branford CT Meegan Sweeney, CPC-A Branford CT Janet Frizell, CPC-A East Haven CT Linda J Mastrangelo, CPC-A Lebanon CT Catherine Perry, CPC-A Manchester CT Tracy Kardas, CPC-A Middletown CT Mary Roraback, CPC-A New Britain CT Lori Ann Sheldon, CPC-A North Grosvenordale CT Betty Allen, CPC-A Salem CT John Stanley Budarz, CPC-A South Windsor CT Paul J Grassel, CPC-A Stonington CT Kathryn Haserick, CPC-A Tolland CT Patricia Dobos, CPC-A Wethersfield CT Carolyn Winton McNamara, CPC-A Windsor Locks CT Viola Coleman, CPC-A New Castle DE Donna F Bolte, CPC-A Neward DE Jennifer Rowbottom, CPC-A Smyrna DE Sarah Elizabeth Forbes, CPC-A Wilmington DE Himabindu Kaza, CPC-A Wilmington DE Hemi Patel, CPC-A Wilmington DE Beyen Garcia, CPC-A Apopka FL Kenneth Asch, CPC-A Boca Raton FL Jillian Nichole McLaughlin, CPC-A Cantonment FL Karen Norris, CPC-A Crestview FL Karen Williams, CPC-A Dade City FL Stacey Piccuito, CPC-A Ft Walton Beach FL Rhoda Rhodes, CPC-A Gibsonton FL Peter Frazier, CPC-A Green Cove Springs FL Izabella Kurdian, CPC-A Green Cove Springs FL Christine Sigmon, CPC-A Holiday FL Ashley Miller, CPC-A Hollywood FL Shaun Kunnmann, CPC-A Jacksonville FL Nicavian Wilson, CPC-A Jacksonville FL Jo-Ann Cassidy, CPC-A Lake City FL Carol L Hart, CPC-A Lakeland FL Lisa Diane Jacklin, CPC-A Lakeland FL Cassandra Miller, CPC-A Lakeland FL Teresa Nesmachnov, CPC-A Lakeland FL Lynn Demos, CPC-A Lehigh Acres FL Debora Lalor, CPC-A Mary Esther FL Carrie Young, CPC-A Milton FL Yudelkis Gil, CPC-A Miramar FL Loreto Kaplan, CPC-A Naples FL Aydee Molina, CPC-A North Miami Beach FL Gail Michele Anscombe, CPC-A Orange Park FL Suzanne Newman, CPC-A Orange Park FL Payal J Bhatt, CPC-A Riverview FL Annabel Caceres, CPC-A Royal Palm Beach FL Kathleen C Gartland, CPC-A Spring Hill FL Dawn May, CPC-A Spring Hill FL Chad William Parrish, CPC-A St Petersburg FL Nancy Talamonti, CPC-A St Petersburg FL Nicole Cain, CPC-A Tampa FL Adriana Crespo-Tanner, CPC-A Tampa FL Sheryl Downs, CPC-A Tampa FL Robin Gerdes, CPC-A Tampa FL Elena Houle, CPC-A Tampa FL Pashen Jackson, CPC-A Tampa FL Robin Stephenson, CPC-A Tampa FL Stacey Suggs, CPC-A Wesley Chapel FL Jessica Brown, CPC-A Zephyrhills FL Rose Kesanghe Udoumana, CPC-A Austell GA Talia Kline, CPC-A Braselton GA Julianne Tooher, CPC-A Buford GA J Dillon, CPC-A Canton GA Erin Gravitt, CPC-A Canton GA Sangita Hazari, CPC-A Douglasville GA Monica Kocjan, CPC-A Flowery Branch GA Pamela Ramey, CPC-A Flowery Branch GA Debra Whitley, CPC-A Flowery Branch GA Iris Morales, CPC-A Gainesville GA MaChanda Rush, CPC-A Jonesboro GA Wendy Hayden, CPC-A Kennesaw GA Colby McCulley, CPC-A Snellville GA Nicole Roland, CPC-A Altoona IA Sandra Lee McGrath, CPC-A Amana IA Angela S Baker, CPC-A Belle Plaine IA Linda A Campbell, CPC-A Cedar Rapids IA Steven K Franks, CPC-A Cedar Rapids IA Sheryl J Hansen, CPC-A Cedar Rapids IA Debra R Linehan, CPC-A Cedar Rapids IA Renee Mary Martin, CPC-A Cedar Rapids IA Donna Lee Mullenix, CPC-A Cedar Rapids IA Jeanne M Myers, CPC-A Cedar Rapids IA Jeannine Kay Robinson, CPC-A Cedar Rapids IA Laura J Ameling, CPC-A Clermont IA Beth Moore, CPC-A Des Moines IA Stephanie Jo Ranberger, CPC-A Fredericksburg IA Julia Hanson, CPC-A Ft Dodge IA Eileen Marie Wander, CPC-A Hawkeye IA Holly K Auman, CPC-A Hiawatha IA Jamie Blevins, CPC-A Lewiston IA Roxanne Delany, CPC-H-A Marion IA Brandy Marie Pingree, CPC-A Oelwein IA Becky Sue Winkler, CPC-A Ossian IA Justi R Steenhoek, CPC-A Prairie City IA Kristi Jones, CPC-A Sioux City IA Angela Mary Abernathey, CPC-A Swisher IA Nancy M Steffen, CPC-A Waterloo IA Kathy Sue Senner, CPC-A West Union IA Teresa Kay Yauslin, CPC-A West Union IA Deborah Atkeson, CPC-A Boise ID Cindi Baker, CPC-A Boise ID Linda Eastwood, CPC-H-A Boise ID Julie Williams, CPC-A Boise ID Yadira Bergstrom, CPC-A Caldwell ID Michelle Villarreal, CPC-A Caldwell ID Danielle Porritt, CPC-A Eagle ID Patricia Larsen, CPC-A Lewiston ID Melony Cade, CPC-A Meridian ID D'rese Werry, CPC-A Meridian ID Dorothy B Smith, CPC-A Nampa ID Kathy Hardy, CPC-A Payette ID Melanie Fahrner, CPC-A Belleville IL Lorey Morton, CPC-A Bloomington IL Alex Castle, CPC-A Chicago IL Tyeisha Goree, CPC-A Chicago IL Maritza Navedo, CPC-A Cicero IL Emily Atkins, CPC-A Collinsville IL Hal Blake, CPC-A Columbia IL Christina Deutschendorf, CPC-H-A Geneva IL Donna Dines-Huff, CPC-A Manteno IL William Edward Huff, CPC-A Manteno IL Karen Dauck, CPC-A Peru IL Megan Reynolds, CPC-A Rockford IL Angela Shaw, CPC-A Staunton IL Christina Newnum, CPC-A Bloomingdale IN Jennifer Sampson, CPC-A Carmel IN Mary Upton, CPC-A Carmel IN Jennifer Hollander, CPC-A Evansville IN Amber Martin, CPC-A Evansville IN Julie Basham, CPC-A Georgetown IN Heather Robinson, CPC-A Greenville IN Cynthia Parsley, CPC-A Greenwood IN Jennifer Lynn Bolden, CPC-A Indianapolis IN Joy Frakes, CPC-A New Albany IN Pamela Riggs, CPC-A New Albany IN Kelsey Stiles, CPC-A New Albany IN Laura Mitchell, CPC-A Noblesville IN Gregory S Ehlers, CPC-A Richmond IN Danita Heiter, CPC-A South Bend IN Cheryl Jean Bindel, CPC-A Baxter Springs KS Danielle Wiggin, CPC-A Ft Scott KS Jamie Renee Sterling, CPC-A Hays KS Liana Alona Ayala, CPC-A Mayetta KS Terra A Swor, CPC-A Pittsburg KS Amanda Marie Whisenant, CPC-A Pittsburg KS Erin McIntosh, CPC-A Roeland Park KS Kamala D Smith, CPC-A Scranton KS Traci Dawn Imes, CPC-A Topeka KS Nancy Kloetzli, CPC-A Topeka KS Jacqueline Kay Lytle, CPC-A Topeka KS Megan McCarthy, CPC-A Topeka KS Kimberley Nelle McCoy, CPC-A Topeka KS Katie M Waters, CPC-A Wakarusa KS Cindy Ann Painter, CPC-A Adolphus KY Dustin Fugate, CPC-A Bowling Green KY Paula Plummer, CPC-A Bowling Green KY Sondra Schilke, CPC-A Bowling Green KY Kassie Nicole Gibson, CPC-A Cave City KY Michelle Kinsolving, CPC-A Cave City KY Kathy June Luttrell, CPC-A Cub Run KY Robin Lee Dotson, CPC-A Etoile KY Lisa Donahoe, CPC-A Lexington KY Kevin Wells, CPC-A Lexington KY Ashley Hourigan, CPC-A Louisville KY Stephanie Lynn Kinney, CPC-A Louisville KY Christa Mercke, CPC-A Louisville KY Kimberly Palmer, CPC-A Louisville KY Chelsea Rougeux, CPC-A Louisville KY Debra White, CPC-A Louisville KY Kimberly Bramel, CPC-A Maysville KY Kathy Tufano, CPC-A Mt Sterling KY Jenny Jackson, CPC-A Owensboro KY Melissa Johnson, CPC-A Richmond KY Karen Denise Tucker, CPC-A Rockfield KY Etta M Monhollen, CPC-A Scottsville KY Rita Faye Parrish, CPC-A Scottsville KY Betty Jo Short, CPC-A Scottsville KY Lesa Spahr, CPC-A Scottsville KY Shawn Curtis, CPC-A Winchester KY Cheryl Reichel, CPC-A Winchester KY Betsy Boudreaux, CPC-A Houma LA Candace Riley Rockett, CPC-A LaFayette LA Mary Ann Baldyga, CPC-A Belchertown MA Debra Bassett, CPC-A Brewster MA Kathleen Whittle, CPC-A Brewster MA Jaclyn McNeil, CPC-A Burlington MA Debra J Warren, CPC-A Chicopee MA Thomas Heath, CPC-A Framingham MA Martha Farnsworth, CPC-A Hampden MA Manisha Kumar, CPC-A Hudson MA Sandra Lee Nadeau, CPC-A Marlboro MA Carole J Amore, CPC-A Mashpee MA Lakeisha Clayton, CPC-A Milton MA Sarah Moe, CPC-A North Andover MA Shannon Decker, CPC-A North Chelmsford MA Thomas Stoll, CPC-A Pocasset MA Donna Degraide, CPC-A Sturbridge MA Susan Hope Hines, CPC-A Taunton MA Karen Correa, CPC-A Upton MA Sharon L Nappi, CPC-A Westford MA Benise Donahue, CPC-P-A Worcester MA Lauren Techla Hill, CPC-A Worcester MA Larraine Formica, CPC-A Abingdon MD Kelly Naumann, CPC-A Baltimore MD Randy Stapleton, CPC-A Belcamp MD Kimann McHose, CPC-H-A Bowie MD Jeanie Aydelotte, CPC-A Easton MD Pamela Roth, CPC-A Ellicott City MD Karen Campbell, CPC-A Forest Hill MD Marlene Brown, CPC-A Laurel MD Ranie Gopaul, CPC-A Laurel MD Kamrul Hasan, CPC-A Laurel MD Daniela Kantor, CPC-A, CPC-H-A Lutherville MD Doralyn Osei, CPC-A Silver Spring MD Lori Stauffer, CPC-A Taneytown MD Laura McCann, CPC-A White Marsh MD Amanda Worster, CPC-A Biddeford ME Norma J Fritz, CPC-A Bowdoin ME Doris J Marquis, CPC-A Bowdoin ME Romney Davis, CPC-A Eliot ME Merena R Daniel, CPC-A Freeport ME Christy Griffin, CPC-A North Waterboro ME Nicole Bechard, CPC-A Presque Isle ME Linda A Dowd, CPC-A Richmond ME Suzanne Holliday, CPC-A Sanford ME Donna Kimball, CPC-A Shapleigh ME Norman Roy, CPC-A Waterboro ME Shannon Petty, CPC-A Belleville MI Patricia Dale Rodgers, CPC-A Caledonia MI www.aapc.com January 2011 39 newly credentialed members Kimberly Desjarlais, CPC-A Dearborn Heights MI Lakisha Lampley, CPC-A Detroit MI Tammie Marie Klump, CPC-A Dexter MI Karen Berriman, CPC-A Flint MI Rachel Adams, CPC-A Grand Rapids MI Dana Sutton Garver, CPC-A Grand Rapids MI Sherri Lewis, CPC-A Kimball Township MI Shirley Owsiany, CPC-A Lawton MI Suzanne Rodriguez, CPC-A Midland MI Marcia Ramer, CPC-A Portage MI Suzanne Duda, CPC-A Warren MI Brenda Jenkins, CPC-A Warren MI Toua Lee, CPC-A Brooklyn Park MN Mary Frances Bjorn, CPC-A Minneapolis MN Julie Zabel, CPC-A Minneapolis MN Tannaz Ameli, CPC-A Roseville MN Sherry Sue Powers, CPC-A Cape Girardeau MO Sarah Jean Hester, CPC-A Chaffee MO Teresa W Becker, CPC-A Columbia MO Jennifer Renee Campbell, CPC-A Eldon MO Margaret Jane Wilde, CPC-A Florissant MO Ashley N Holt, CPC-A Fulton MO Barbara Michele Sciacca, CPC-A Jasper MO Lori M Curry, CPC-A Joplin MO Annette Marie Murphy, CPC-A Joplin MO Anita Salinas, CPC-A Joplin MO Michele Leigh Lee, CPC-A Kansas City MO Mary Lagergren, CPC-A Lake Waukomis MO Teresa E. Hindrichs, CPC-A O'Fallon MO Rebecca Ann Cox, CPC-A Oronogo MO Kimberly Van de Riet, CPC-A St Charles MO Mary Cooke-Dorhauer, CPC-A St Louis MO Tatiana D Montgomery, CPC-A St Louis MO Amanda McLaughlin, CPC-A Biloxi MS Sandra W Berry, CPC-A Byhalia MS Sherll Lynn Fry, CPC-A Jackson MS LaTonya Surnette Hubbard, CPC-A Jackson MS Nicole Diane Crouch, CPC-A Missoula MT Teresa Gong, CPC-A Angier NC Mary Byerly, CPC-A Archdale NC Kathleen Hansen, CPC-A Asheville NC Lucia Batchelder, CPC-A Chapel Hill NC Renee Militante, CPC-A Chapel Hill NC Aaron Elizabeth Bradley, CPC-A Charlotte NC Lisa Ince, CPC-A Charlotte NC Rhonda Granja, CPC-A Concord NC Gail Stoycon, CPC-A Cornelius NC Kathryn Abbott, CPC-A Durham NC Shadonna Pierce, CPC-A Durham NC Nanci-Ann Whitworth, CPC-A Durham NC Marcia Cunningham, CPC-A Elizabeth City NC Kenneth Earl Jordan, CPC-A Fayetteville NC Frances Alexander, CPC-A Greensboro NC Kathy Clark, CPC-A Greensboro NC Pat Driver, CPC-A High Point NC Alicia Cain, CPC-A Hubert NC Hsiu Hsiang Elsa Gant, CPC-H-A Julian NC Rhonda Goodman Travis, CPC-A Kannapolis NC Kay L Hedrick, CPC-A Lexington NC Berea Thomas, CPC-A Lexington NC Lindsay M Willis, CPC-A Marshville NC Donna M Craig, CPC-A Mooresville NC Jan K Harris, CPC-A Mooresville NC Sheri Lively, CPC-A Mooresville NC Janice Williams, CPC-A Morrisville NC Linda Planchon, CPC-A Olin NC Jackie Watkins, CPC-A Olin NC Mary Arnold, CPC-H-A Pittsboro NC Angela Kelly, CPC-A Raleigh NC Cindy Hodge, CPC-A Rolesville NC Joseph Mullen, MD, CPC-A Shelby NC Catherine Ann Baker, CPC-A Statesville NC Christie Lee, CPC-A Statesville NC Angela Harris, CPC-A Union Grove NC Chantal Proulx, CPC-A Vale NC Christine Crosby Taylor, CPC-A Wake Forest NC Judith Cecilia Wicker, CPC-A Weddington NC Laura Jean Barker, CPC-A Yanceyville NC Tiffany M Larson, CPC-A Burlington ND Regina Reynolds, CPC-A Bow NH Debra Peck, CPC-A Center Ossipee NH Cheryl A Aiken, CPC-A Claremont NH Emilee Jane Minckler, CPC-A Claremont NH Sheryl Scott, CPC-A Conway NH Lynda Wright, CPC-A Derry NH Michele Lise Becker, CPC-A Goffstown NH Cheryl Morrissette, CPC-A Goffstown NH Joseph Reopel, CPC-A Hillsboro NH Marc Aldrich VonGeldern, CPC-A Lebanon NH Teri Michael, CPC-A Litchfield NH John Kelly, CPC-A Littleton NH Nikki Bicchieri, CPC-A Londonderry NH 40 AAPC Coding Edge Meaghan Donohue, CPC-A Londonderry NH Doral Garon, CPC-A Manchester NH Shawna Harper, CPC-A Manchester NH Karen Hendershot, CPC-A Manchester NH Lisa Reid, CPC-A Manchester NH Milena Simon, CPC-A Manchester NH Jessica Young, CPC-A Manchester NH Ildiko Balogh, CPC-A Merrimack NH Lisa Anne Oakes, CPC-A N Haverhill NH Cheryl Wilson, CPC-A Ossipee NH Elizabeth Ann Trussell, CPC-A Piermont NH Lynn Zeltman, CPC-A Plainfield NH Kelly Abbott, CPC-A Raymond NH Diane Cardwell-Beland, CPC-A Weare NH Tracey Lachance, CPC-A Weare NH Laura Beth Boncek, CPC-A West Lebanon NH Cynthia Schafer, CPC-A Belle Mead NJ Lauren Earnest, CPC-A Bridgeton NJ Annette Vanderhoff, CPC-A Butler NJ Agnes Linder, CPC-A Cliffwood NJ Jennifer J Sterner, CPC-A Colts Neck NJ Kristeen Craig, CPC-A Eatontown NJ Jill Mensch, CPC-A Egg Harbor Township NJ Sherry Ann Driver, CPC-A Freehold NJ Karen Giovetsis, CPC-A Gloucester City NJ Evelyn Kaveski, CPC-A Hamilton NJ Sherry McGuire, CPC-A Hamilton NJ Susan Helmstetter, CPC-A Hazlet NJ Marina Benoit, CPC-A Irvington NJ William Lloyd, CPC-A Jackson NJ Natalie Schaeffer, CPC-A Leonardo NJ Jill Sandorse, CPC-A Little Silver NJ Stephanie Dibble, CPC-A Marlboro NJ Lois Weaver, CPC-A Middletown NJ Jason Sobel, CPC-A Monroe Township NJ Liqun Wang, CPC-A Morganville NJ Paula Zumbana, CPC-A Piscataway NJ Carol Linda Vermeulen, CPC-A Pompton Plains NJ Nitya Iyer, CPC-A Princeton NJ Ilene Janofsky, CPC-A Princeton Junction NJ Randa Shetter, CPC-A Somers Point NJ Janet Cleveland, CPC-A Vineland NJ Ellen Giamboy, CPC-A Vineland NJ Caroline Katz, CPC-A Westfield NJ Bev Mayor, CPC-A Whippany NJ Leslie Cruz, CPC-A Willingboro NJ Sandra Evelyn Johnson, CPC-A Aztec NM Megan Gabrielle Martinez, CPC-A Aztec NM Darla S Monarco, CPC-A Kirtland NM Wanda L Smith, CPC-A Kirtland NM Audrey Dunn Leonard, CPC-A Sparks NV Peter J Damico, CPC-A Apalachin NY Kimberly Carey, CPC-A Bainbridge NY Pamela R Snyder, CPC-A East Amherst NY John Yesuratnam, CPC-A Jamaica NY Natoshia Fraser, CPC-A Maryland NY Denise Debra Wynter, CPC-A Middletown NY Sharon Goodman, CPC-A Owego NY Haimanti Mukherjee, CPC-A Rye NY Laura Drozynski, CPC-A Sherrill NY Karol Henderson, CPC-A Tonawanda NY Jaime Decker, CPC-A Utica NY Elizabeth Anne Schmeltz, CPC-A Wallkill NY Charise N Owens, CPC-A Wappinger Falls NY Lela Baker, CPC-A Akron OH Mira Stojadinovic, CPC-A Akron OH Crystal Jones, CPC-A Barberton OH Matthew O'Malley, CPC-A Canton OH Jillian Hendrickson, CPC-A Chardon OH Debbie Matthews, CPC-A Cincinnati OH Sheila Gooch, CPC-A Columbus OH Therese A Nicholas, CPC-A Dayton OH Marsi Williams, CPC-A Delaware OH Elizabeth Quinn, CPC-H-A Dover OH Tracy Ann Martin, CPC-A Eaton OH Heather Michelle Mortellite, CPC-A Liberty Township OH Michelle Layette Scott-Dickens, CPC-A Mayfield Heights OH Deidre Hann, CPC-A McConnelsville OH Kirstie Sword, CPC-H-A Navarre OH Karrie Abruzzino, CPC-A Newbury OH Colleen Baxter, CPC-A North Canton OH Michelle Dechiara, CPC-A North Canton OH Randi Hendrickson, CPC-A North Olmsted OH Lori H Lauver, CPC-A North Olmsted OH Diane Salsburey, CPC-A Orrville OH Angela Ziccardi, CPC-A Ravenna OH Janet Ward, CPC-A Seville OH Mandie Jo McCort, CPC-A Sherrodsville OH Susan Neumaier, CPC-A Vandalia OH Joyce A Cook, CPC-A West Chester OH Laura Krupka, CPC-A Wickliffe OH Gwendolyn Sexton, CPC-A Youngstown OH Jan Toomey, CPC-A Broken Arrow OK Carolyn Purcell, CPC-A Cameron OK Deanna Blalock-Polley, CPC-A Jones OK Darcy Jones, CPC-A Moore OK Corie Bottoms, CPC-A Tulsa OK Jennifer Boysel, CPC-A Tulsa OK Debbi Lee Fussell, CPC-A Beaverton OR Jessica Gustafson, CPC-A Beaverton OR Thomas James Nguyen, CPC-A Beaverton OR Mary Pham Tran, CPC-A Beaverton OR Julie Watkins, CPC-A Boring OR Edith A Adair, CPC-A Eugene OR Marie Hoots, CPC-A Hillsboro OR Linnell York, CPC-A Hillsboro OR Linda Anderson, CPC-A Keizer OR Roberta Holman, CPC-A Portland OR Martin Vodka, CPC-A Portland OR Susan Huhn, CPC-A Alburtis PA Monica Suchdeo, CPC-A Allentown PA Ahmi Kim, CPC-A Ambler PA Jessica Viguers, CPC-A Aston PA Joy Noecker, CPC-A Auburn PA Mary Sieffert, CPC-A Barto PA Melissa Ashburner, CPC-A Bethlehem PA Doreen Baranowski, CPC-A Bethlehem PA Linda Lou Peck, CPC-A Carlisle PA Renee Warren, CPC-A Carlisle PA Cherie Kraynick, CPC-A Catasauqua PA Traci Hood, CPC-A Chadds Ford PA Sara Elizabeth Curry, CPC-A Danville PA Colette Robbins, CPC-A Danville PA Karen L Curto, CPC-A Easton PA Barbara Mulik, CPC-A Emmaus PA Trisha Christine Mattis, CPC-A Erie PA Jessica Marie Sanchez, CPC-A Erie PA Christine Anne Satur, CPC-A Erie PA Christa Keren DeVelde, CPC-A Franklin PA Michael Alan Marquardt, Sr, CPC-A Gettysburg PA Pamela Jeanne Heilman, CPC-A Grantville PA Beverly Andrews, CPC-A Greensburg PA Martha J Lawrence, CPC-A Hanover PA Suzanne Hedrick, CPC-A Havertown PA Brenda Cooper, CPC-A Jenkintown PA Rebecca Wolfe, CPC-A Kempton PA Christine M Shannon, CPC-A King of Prussia PA Laurel Elizabeth Heinley, CPC-A Lancaster PA Carol Stank, CPC-A Lancaster PA Catherine Ward, CPC-A Lancaster PA Jessica Kalinski, CPC-A Langhorne PA Wanda Ambrose, CPC-A Lebanon PA Debra Hoover, CPC-A Lebanon PA Morgan Mellott, CPC-A Lebanon PA Robert Bartlett, CPC-A Lehighton PA Elizabeth Stewart, CPC-A Mechanicsburg PA Deborah Cohen, CPC-A Melrose Park PA Megan Szychowski, CPC-A Nanticoke PA Sherry Lee Chaklos, CPC-A Nazareth PA Nupur Pant, CPC-A Orefield PA Marylee E Zart, CPC-A Orefield PA Marie P Schoch, CPC-A Palmerton PA Jodi R Freed, CPC-A Philadelphia PA Kathy Kramer, CPC-A Ronks PA Crystal A Nutall, CPC-A Smithton PA Andrea Di Paulo, CPC-A Springfield PA Marcella M Reynolds, CPC-A Terre Hill PA Rosemary LoCastro-Talbert, CPC-A Washington Crossing PA Debbie J Brunner, CPC-A Wellsville PA Sharon Lanzos, CPC-A Whitehall PA Kelci Howard, CPC-A York PA Denise Pazdan, CPC-A York PA Lisa Curless, CPC-A York Haven PA Diana Lynne Krehling, CPC-A York Haven PA Rebecca Quinones, CPC-A Cayey PR Pam Ziegenhorn, CPC-A Andrews SC Ashley B Metcalfe, CPC-A Charleston SC Ann E Williams, CPC-A Charleston SC Marsha A Davis, CPC-A Clinton SC Sarida N Davis, CPC-A Columbia SC Mary Johnson, CPC-A Columbia SC Tamara McKeithan, CPC-A Columbia SC Linda Sanford, CPC-A Florence SC Ariel LaGoldia Rice, CPC-A Fountain Inn SC Elizabeth Lauren McRainey, CPC-A Greenville SC Jessica Moore Reynolds, CPC-A Greenville SC Donna Marie Brown, CPC-A Laurens SC Sharniece Martrice Robinson, CPC-A North Charleston SC Aletha L Ellis, CPC-A Roebuck SC Latoya V Glenn, CPC-A Summerville SC Elizabeth R LeBlanc, CPC-A Summerville SC Andrea DeRuntz-Walker, CPC-A Williamston SC Lorraine Higgins, CPC-A Williamston SC Jade Ariel Reeves, CPC-A Williamston SC Sally Hines, CPC-A Salem SD Teneka Clemese Taylor, CPC-A Chattanooga TN Sangeetha Hemaraj, CPC-A Chennai TN Debbie Kester, CPC-A Clarksville TN Jennifer Lynn Baxter, CPC-A Hillsboro TN Kara Ferguson, CPC-A Hixson TN Kelly Raymond, CPC-A Kimball TN Jane Andreaco, CPC-A Knoxville TN Scarlet M Haynes, CPC-A Knoxville TN Kelli A Jones, CPC-A LaVergne TN Lorie Watson, CPC-A Lebanon TN Loraine Sizemore, CPC-A Manchester TN Rebecca Questell, CPC-A McMinnville TN Ashley Lynn Carr, CPC-A Murfreesboro TN Josie Collier, CPC-A Murfreesboro TN Tetanishia Gooch, CPC-A Murfreesboro TN David C Bowlin, CPC-A Nashville TN Sharon Marcia Gardner, CPC-A Nashville TN Iris Kontente Hearn, CPC-H-A Nashville TN Anne Moorman, CPC-A Nashville TN Jessica Williams, CPC-A Nashville TN Kay G Allgood, CPC-A Pegram TN Heather Rey Zaffis, CPC-A Portland TN Holley R Reffue, CPC-A Smithville TN Brandie King, CPC-A Addison TX Marily Salinas, CPC-A Arlington TX Roxanna Menger, CPC-A Austin TX Laura Salazar, CPC-A Austin TX Lorena Rivas, CPC-A Canutillo TX Trenna Lynn Gillett, CPC-A Edgewood TX Daniel Parra, CPC-A El Paso TX Marlenna R Crowe, CPC-A Ft Worth TX Tricia Williams, CPC-A Haslet TX Laura Hanson, CPC-A Lancaster TX Nadia Pullin, CPC-A Leander TX Sheryl Therriault, CPC-A McKinney TX Tonya Brogdon, CPC-A Mineral Wells TX Cheabon Altwein, CPC-H-A New Braunfels TX Lauren Shapard, CPC-A North Richland Hills TX Florine Sanchez, CPC-A Plano TX Rachel Arcos, CPC-A San Antonio TX Rosario Barrientes, CPC-A San Antonio TX William Liles, CPC-A San Antonio TX Arpita Maloo, CPC-A San Antonio TX Lanaea Galindez, CPC-A Draper UT Heidi Daines, CPC-A Harrisville UT Kristine Dalton, CPC-A Harrisville UT Lori Strong, CPC-A Herriman UT Michelle Sawley, CPC-A Ogden UT Katie Spangenberg, CPC-A Ogden UT Terree Brough, CPC-A Plain City UT Michelle Herbert, CPC-A Springville UT Nancy Pontzer, CPC-A Alexandria VA Helen Martin, CPC-A Chesapeake VA Rochelle A Owens, CPC-A Chesapeake VA Angela Chamberlain, CPC-A Chester VA Sharon L Moncrief, CPC-A Colonial Heights VA LaPhandra Hoyes, CPC-H-A Hampton VA Stacy M Quarles, CPC-A King William VA Mary H Kellner, CPC-A Midlothian VA Dorothy McFadden, CPC-A Midlothian VA Virginia Marston, CPC-A Red House VA MarQuetta Blakey, CPC-A Richmond VA Kathryn M Deal, CPC-A Suffolk VA Charles Aloisa, CPC-A Virginia Beach VA Metina Baucom, CPC-A Virginia Beach VA Janelle Elizabeth Grandison, CPC-A Virginia Beach VA Mary Ellen McCann, CPC-A Virginia Beach VA Victoria Anne Paur, CPC-A Virginia Beach VA Lisa Michelle Lawrence, CPC-A Warrenton VA Lisa Marie Hoskins, CPC-A Winchester VA Dominique Veitch, CPC-A Chester VT Annie Malloy, CPC-H-A Grand Isle VT Angelia Marie Russell, CPC-A White River Junction VT Lyn K Kolb, CPC-A Woodstock VT James VanLiew, CPC-A Bellingham WA Nicolette Doyle, CPC-A Bothell WA Nicolette Wolfe, CPC-A Burlington WA Holland Wood, CPC-A Camano Island WA Kamalpreet Dhillon, CPC-A Everett WA Peggy Jean Hagglund, CPC-A Everett WA Kelly Lyn McCoy, CPC-A Federal Way WA Ronald Weightman, CPC-A Federal Way WA Sidney Faas, CPC-A Kent WA Damika Rodrigue, CPC-A Kent WA Tracey Lynne Jones, CPC-A Kirkland WA Janet Eulene Ramynke, CPC-A Moxee WA Daniela Wever, CPC-A Orting WA Candace Drollinger, CPC-A Port Townsend WA Patricia Langhans, CPC-A Redmond WA Dena Bailey, CPC-A Renton WA Denise Annette Brennan, CPC-A Renton WA Roman R Gatalyak, CPC-A Renton WA Jamie Robin Hallmark, CPC-A Renton WA Alicyn Westerfield, CPC-A Selah WA Rosandra Fedorko, CPC-A Silverdale WA Anna-Louise Amiscua, CPC-A Stanwood WA Maureen Strickland, CPC-A Tacoma WA Vernon Eugene Brand, CPC-A Yakima WA Patricia Kingsborough, CPC-A Yakima WA Charlotte Werthmann, CPC-A Appleton WI Keli M Westphal, CPC-A Appleton WI Robyn Theresa Plompen, CPC-A Depere WI Sara A Levendusky, CPC-A Manitowoc WI Susan Milliron, CPC-A New Richmond WI Specialties Mary F Greenleaf, CPC, CEMC APO AE Selina Maria Thomson, CEMC APO AE Julia Ann Holt, CPC, CPCD Fresno CA Cheryl Tubig, CPC, CPC-H, CEMC Oakland CA Ashley Nicole Pickerill, CPC, CANPC, CEMC Santa Cruz CA Pallas Buckley, CPC, COSC South Lake Tahoe CA Kimberly Seegan, COBGC Westlake Village CA Alexis M Pyatt, CPC, CEMC Fountain CO Nancy D Weed, CPC, CPC-H, CEDC, CEMC, CUC Wilmington DE Kim Jones, CPC-A, CHONC Jacksonville FL Jamie Smith, CPC, CEDC Jacksonville FL Theresa Borsch, CASCC Lake Worth FL Paula Buckingham, CPC, CEMC Orange Park FL Jennifer Leigh Hestle, CPC, CHONC Pensacola FL Karen D Renner, CPC, CEMC Buford GA Adrien Leigh Peterson, CPC, CEMC Clayton GA Christy D Payne, CPC, CEMC Clermont GA Jennifer Michelle Kastner, CPC, CEMC Cleveland GA Sandra D Hicks, CPC, CEMC Gainesville GA Angela Odom, CPC, COBGC Gainesville GA Cathy M Stover, CPC, CPC-H, CEDC Richmond Hill GA Patricia Peaslee, CPC-A, CUC Valdosta GA Valerie Gene Westbrook, CPC, CEDC Bethalto IL Barbara Myers, CGIC Charleston IL Valerie N. 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Plus, ICD-9-CM CrossReference Tool: The new “ICD-9-CM CrossReference” tool will provide you list of supporting ICD codes indicating the medical necessity for any CPT® procedure code. To order, call 1-(866)-228-9252 and mention the promo code LN0IS011. Or click online at www.SuperCoder.com Call us: 1-(866)-228-9252 www.SuperCoder.com The Coding Institute LLC, PO Box 933729, Atlanta, GA 31193-3729 www.aapc.com January 2011 41 road map to ICD-10-CM Get on Board for the Next 1000 Days Road Map to ICD-10-CM Get on Board for the Next 1000 Days 42 AAPC Coding Edge Time is ticking and ICD-10 won't stop to let you on the bus. By Angela “Annie” Boynton, BS, RHIT, CPC, CPC-P, CPC-H, CPC-I, CCS, CCS-P As I write this, there are just over 1,000 days until ICD-10 becomes the new standard for disease classification in the United States. The Centers for Medicare & Medicaid Services (CMS) will reject any claim using ICD-9-CM codes with a date of service on or after Oct. 1, 2013. Lack of preparation could be devastating. Ignoring ICD-10 Will Not Make It Go Away Although there are many competing priorities right now (ARRA, HITECH, and Meaningful Use—to name a few), the longer you put off ICD-10 implementation, the harder it will be to comply with this deadline. Those who wait until the last minute to prepare for ICD-10 are risking their revenue in 2013 and beyond. The only way to mitigate these risks is to be fully compliant with ICD-10 by Oct. 1, 2013. Let’s discuss a few things you can do to get the ball rolling toward ICD-10 compliance. Ask Not What ICD-10 Can Do for You … By now, organizations should be finalizing impact assessments. This means that steering committees have been formed; executive buy-in has been obtained; basic education has been delivered to project teams, stakeholders, and executives; and 5010 implementation is on track. If reading this paragraph has made you reach for the antacid (or worse), you are not alone. Recent industry surveys have suggested that as many as 52 percent of health care organizations have not begun their ICD-10 implementation planning efforts. If your organization is one of them, you need to get going—now. Steering Committee— Who’s Driving Implementation? Although physicians will play a crucial role in ICD-10 implementation, steering committees should include members across the breadth and depth of an organization. The steering committee should be an interdisciplinary team representing many areas of the organization. Some examples include: • Project managers •Information technology (IT)/Information systems (IS) • Health information management (HIM) • Physicians • Revenue cycle staff • Training • Communication • Vendors • Management • Coding professionals (of course) ICD-10 Awareness: If You Build It, They Will Come Awareness develops over time and is critical to ICD-10 implementation success. Rather than spending precious dollars creating an ICD-10 campaign, organizations would do better to build ICD-10 awareness by leveraging available resources. Within larger organizations, these resources may include existing newsletters, internal websites, and even memos. Smaller organizations can place ICD-10 information by the water cooler, or in the lunchroom. Any size organization may conduct lunchtime learning sessions. Many vendors, payers, facility specialty societies, and industry organizations are providing free materials and webinars regarding ICD-10. All entry-level communications should give basic information regarding the ICD-10 code set changes, why we must transition, a general timeframe, and potential impacts to the organization. Medical staff, coding professionals, and revenue cycle staff may require additional communication and increased training—but everyone should be aware of the basics. Impact Assessment: An Organizational Crystal Ball An impact assessment helps to provide an accurate picture of costs, scope, timelines, and other resources required for ICD-10 implementation. It involves careful analysis and budgetary consideration for the project’s life. In its simplest form, an impact assessment can be started by addressing a few questions: analyzing where, when, by whom, and how ICD-9 codes currently are used across the organization. More time spent conducting impact assessment equates to greater budgetary accuracy over the life of the implementation project. ICD-10 Revolution: Change is Good! ICD-10 is a revolutionary change to our disease classification system in the United States. Revolutions in general tend to be painful, and projects that carry the size and scope of the ICD-10 transition can cause anxiety. Open and maintain clear communication channels to help mitigate fear. Clearly define changes and expectations associated with ICD-10 implementation as early as possible. Provide constant updates when milestones are formulated and overall project plans become clear. With less than 1,000 days left, there is no time left to lose. Annie Boynton is the director of 5010/ICD-10 communication/ adoption and training at UnitedHealth Group. She also teaches at Massachusetts Bay Community College and is a developer and member of AAPC’s ICD-10 Curriculum Development Team. 2011 Webinar SubScription Top Ten Reasons To Subscribe: 10. Up to 80 CEUs — earn up to 2 CEUs per presentation (per attendee) 9. Entire office can attend 8. Free on-demand recordings of the live presentations 7. Includes all 2011 webinars (live and on-demand) 6. Access to 2010 on-demand library of webinars 5. More than 21 specialties covered in this year’s line-up 4. Increase your value as you learn new concepts and stay current with industry changes 3. Access to an expert presenter via a live chat room More Than Presentatio40 For the Enti ns Office Onlyre 2. New this year… three special webinars on anatomy and physiology in preparation for ICD-10 $745 (THROUG And the #1 reason to get your 2011 AAPC Webinar Subscription: H JAN. 31 ) 1. A great value at just $745 (extended through January 31, 2011) Visit aapc.com/2011webinar and buy your 2011 Webinar Subscription today! or call 800-626-coDe (2633). www.aapc.com January 2011 43 feature COPD: Frequently Used, Frequently Misreported Giving essential details about the patient’s condition can eliminate coding quandaries. By Jill M. Young, CPC, CEDC, CIMC PROFESSIONAL C hronic obstructive pulmonary disease (COPD) is a progressive disease that causes coughing, wheezing, shortness of breath, chest tightness, and other symptoms. The leading cause of COPD is smoking; most people who smoke, or have smoked, have some form of COPD. In 2007, an estimated 12.1 million Americans had the disease, which is not only a major cause of disability but also the fourth leading cause of death in America. Coders will encounter COPD frequently in medical documentation, but often without the specificity required to code the condition appropriately. A little physician education will go a long way to solve this problem. Be Cautious of Shortcuts As coders, we become so familiar with certain anagrams that we memorize the corresponding diagnosis code—HTN for hypertension (401.9 Essential hypertension; Unspecified), DM for diabetes mellitus (250.00 Diabetes mellitus without mention of complication; type II or unspecified type, not state as uncontrolled), and OA for osteoarthritis (715.98 Osteoarthritis, unspecified whether generalized or localized; Other specified sites), to name just a few. Although you may know what ICD9-CM codes to assign in such cases, you do a disservice to providers if you allow them to document with such nonspecific code assignments. Ensure accurate representation of the patient’s illness by looking at the specificity available to diseases such as COPD. “COPD” may be written in the record, but that does not give essential details about the patient’s condition, and this leads to coding quandaries. Was the patient ill at this encounter with another respiratory process? Was this illness and its severity included in the record documentation? This information is necessary if you 44 AAPC Coding Edge are to select codes that accurately identify the patient’s condition. COPD 496 Is a Non-Specific Code Code 496 Chronic airway obstruction not elsewhere classified is one of the few valid three-digit codes in the ICD-9-CM manual. The code includes a subcategory listing of “chronic obstructive pulmonary disease (COPD) NOS,” and is both a not otherwise specified (NOS) and not elsewhere classified (NEC) diagnosis. In other words, 496 is a legitimate diagnosis, but it lacks specificity. Providers like to write the short anagram “COPD” when there may be (and perhaps should be) a more specific code for a patient encounter. Fold COPD into 491-493, When Present You should not report 496 with chronic bronchitis (491. xx), emphysema (492.x), or asthma (493.xx), according to ICD-9-CM instructions. Just as shortness of breath normally should be integrated in the coding for pneumonia, COPD should be incorporated into categories 491-493 for the other lung diseases listed. For example, when COPD is documented with other specified conditions, such as an acute exacerbation (491.21 Obstructive chronic bronchitis) or asthma (493.2x), per coding guidelines, code 496 is not used. In such a case, COPD should not be documented separately because it is redundant to the more-inclusive diagnosis. Nor should you report 496 with 491.0 Simple chronic bronchitis, 492.8 Other emphysemia, or asthma of any kind (493.xx). A tip in ICD-9-CM 2011 reminds, “COPD is a nonspecific term that encompasses many different respiratory conditions. Review medical record and query physician for more specific documentation of emphysema, bronchitis, asthma, etc.” feature Figure A: Venn Diagram Just as shortness of breath normally should be integrated in the coding for pneumonia, COPD should be incorporated into categories 491-493 for the other lung diseases listed. One useful tool is the Venn diagram, as shown in Figure A. Similar to what appears in the ICD-9-CM manual, this diagram shows the interrelationship between chronic bronchitis (491.xx), asthma (493. xx), and emphysema (492). The overlapping areas are indicative of diagnoses with shared qualities of two or all three of the major disease processes. As you can see, COPD has attributes of both chronic bronchitis and emphysema; how much of each changes with every patient, and potentially with each encounter. Tip: As a note of caution, not all physicians agree with the classifications this diagram offers, so you may want to have a discussion with your provider to avoid any confusion. The Venn diagram helps us to understand that these are three different and distinct diagnoses, but there are related disease processes that must be considered. Your code book may have definitions listed in several of the subsections that are very helpful in differentiating codes with common characteristics. Coding tips from the 2011 ICD-9-CM book specifically state, “Due to the overlapping nature of conditions that make up COPD, it is essential that the coder review all instructional notes carefully.” For example, documentation of a patient visit may end with the physician listing COPD and chronic bronchitis. This should be coded to 491.0; the chronic bronchitis is the more specific code to the COPD, according to ICD-9-CM guidelines. The same guidelines are applied if the documentation was COPD and asthma. In this example, it is particularly difficult to omit the 496 COPD code because an unspecified code for the asthma is indicated with an unspecified subclassification, which codes to 493.90 Asthma, unspecified; unspecified. ICD-10 Raises the Stakes COPD documentation and specificity will become even more important with ICD-10-CM. COPD is classified with acute lower respiratory infections (also identify- ing the infection), and with exacerbation. You also are instructed, where applicable, to use additional codes to identify exposure to tobacco. This exposure is identified in codes representative of environmental tobacco smoke, history of tobacco use, occupational exposure to environmental tobacco smoke, tobacco dependence, and tobacco use. Help Providers, Help You How can coders educate providers to document all the necessary information to code COPD accurately? I recommend you take your code book to providers (or, copy and send them the relevant pages) to show them firsthand the ICD-9-CM guidelines. If a physician sees, for example, there are separate codes for a patient with or without COPD and acute bronchitis, chronic bronchitis, or acute and chronic bronchitis together, they will better understand why you are asking for more specificity. Remind the provider that you cannot code what is not documented. Any dialog between coders and providers is invaluable to producing detailed documentation that leads to code selection with the bestpossible specificity. The next time you see COPD (or 496) listed as a diagnosis, think of the prevalence of patients with this disease process, and remember that this code lacks specificity. Don’t forget there are 24 distinct ICD9-CM code listings for which COPD should not be listed separately as a diagnosis, according to guidelines. Look to the documentation and your provider for the data needed to represent the patient encounter accurately, with the greatest specificity that the ICD-9-CM system offers. Jill M. Young, CPC, CEDC, CIMC, has more than 30 years of medical experience working in all areas of the medical practice including clinical, billing, and rounding with physicians. She is the principal of Young Medical Consulting, LLC, and is the current chair of the AAPC Chapter Association (AAPCCA). www.aapc.com January 2011 45 featured coder Evaluate Your Performance When ED Leveling Hospitals must develop internal guidelines, based on general Medicare principles. By Jim Strafford, CEDC, MCS-P H ow well does your emergency department (ED) assign evaluation and management (E/M) levels based on the resources used? How does your facility compare to other, similar facilities? If you don’t know the answers, it’s time to take a closer look at your facility E/M leveling. Review Guidelines The Centers for Medicare & Medicaid Services (CMS) requires hospitals to report ED facility resources using CPT® E/M services codes. But, whereas the 1995 and 1997 Documentation Guidelines for Evaluation and Management Services direct E/M leveling for physician services, there are no standard leveling guidelines when reporting facility resources (see Medicare Claims Processing Manual, chapter 4, section 160: www.cms. gov/manuals/downloads/clm104c04.pdf). Instead, each hospital must develop its own, internal guidelines, based on 11 general principles that CMS outlined in the 2008 Outpatient Prospective Payment System (OPPS) Final Rule (see Federal Register, Nov. 27, 2007, page 66805: http://edocket.access.gpo.gov/2007/pdf/075507.pdf). Among other requirements, CMS expects each hospital’s internal guidelines to: Follow the intent of the CPT® code descriptor (the guidelines should relate reasonably to the hospital resources used) Be based on hospital facility resources, not physician resources Be clear to facilitate accurate payments Not facilitate upcoding Be written or recorded, be well documented, and provide the basis for selection of a specific code As long as these general guidelines (and seven others) are met, CMS allows the hospital (or, more precisely, its coders) to decide how ED services should be documented to support a given service level. The result has been a hodgepodge of methodologies, including point systems, matrixes, and hybrids of both (look to future articles for a discussion of these differing methodologies). Table A: 2009 Medicare Leveling Data for Four EDs in East Coast Suburban Areas Close to Large Urban Areas 46 AAPC Coding Edge Level 99281 99282 99283 99284 99285 ED 1 2.54% 56.21% 28.27% 9.05% 3.92% ED 2 1.39% 27.97% 37.17% 22.70% 10.77% ED 3 1.81% 24.73% 69.01% 3.80% 0.66% ED 4 12.08% 16.65% 15.04% 16.08% 40.16% Medicare Average 5% 16% 33% 31% 16% featured coder How Do You Compare? CMS states in the 2010 OPPS Final Rule, “CMS continues their belief that based on the use of their own internal guidelines, hospitals are generally billing in an appropriate and consistent manner that distinguishes among different levels of visits based on their required hospital resources.” (See Federal Register, Nov. 20, 2009, page 60552: http://edocket.access.gpo.gov/2009/ pdf/E9-26499.pdf.) At Strafford Consulting, review of Medicare data indicates (in a very general way) CMS’s statement may be true; however, many hospitals are well below or well above national averages. Table A gives Medicare acuity levels for four EDs in a densely-populated Northeast state. The EDs are similar in payer mix, volume, and patient mix. So why is there such a variance in leveling among these hospitals? Table A illustrates: • EDs 1 and 2, which have visits in the 30-40K per annum range, are moderate size EDs. • EDs 3 and 4, which have visits in the 70-80K per annum, are moderately large EDs. • EDs 1-3 are well above national averages for 99282 Emergency department visit for the evaluation and management of a patient, which requires these 3 key components: An expanded problem focused history; An expanded problem focused examination; and Medical decision making of low complexity. ED 1 shows over three times the national average for 99282. This could indicate a leveling issue that is affecting revenue. Only ED 4 is in line with national averages for 99282. • A ll of the EDs are well below the national averages for 99284 Emergency department visit for the evaluation and management of a patient, which requires these 3 key components: A detailed history; A detailed examination; and medical decision making of moderate complexity. This could represent a very significant revenue loss. • ED 4 is well above the national average for 99285 Emergency department visit for the evaluation and management of a patient, which requires these 3 key components within the constraints imposed by the urgency of the patient’s clinical condition and/ or mental status: A comprehensive history; A comprehensive examination; and medical decision making of high complexity. If the coding is not supported by documentation and medical necessity, this ED could be vulnerable to negative audit findings and major paybacks. Different practice patterns and resource use may affect acuity levels. For example, a given hospital might have a very robust walk-in clinic in the ED. But this report tracks Medicare patients who typically are sicker than the general population when visiting the ED. Because CMS and CPT® do not provide guidelines for leveling, the major reason for the leveling differences likely is the leveling method each hospital uses, and the quality of documentation at these EDs. This example shows why you should examine E/M leveling in your facility. Be Sure Used Guidelines Are Complete and Capture All Supported Services As a first step, review your reports and work-up percentages based on ED acuity levels. If your ED is coding 99281 Emergency department visit for the evaluation and management of a patient, which requires these 3 key components: A problem focused history; A problem focused examination; and Straightforward medical decision making and 99282 over 50 percent of the time, you could be undercoding ED levels. If the majority (60-70 percent) of your levels are 99283 Emergency department visit for the evaluation and management of a patient, which requires these 3 key components: An expanded problem focused history; An expanded problem focused examination; and Medical decision making of moderate complexity, you might be suffering from “Level-3-itis.” This is still a common issue with physicians who do their own coding (such as hospitalists). On the other hand, if your ED is coding 99285 more than 40-45 percent of the time, there could be a compliance issue. If your ED leveling percentages are way out of line, it is likely that the guidelines you use for leveling are not complete in capturing all elements that can support the services. Or, the personnel who do the leveling are not identifying all of the elements that would support an ED level. In the later case, the problem may relate to who does the leveling at your hospital. ED nurses are responsible for leveling at some hospitals; and they are most familiar with resources utilized in the ED to support levels. Like physicians, though, nurses often do not have the time or inclination to focus on leveling. Recognize also that atypical leveling patterns may attract CMS’ attention. The 2010 OPPS Final Rule (referenced above) states, “In the absence of national guidelines, we [CMS] will continue to regularly reevaluate patterns of hospital outpatient visit reporting at varying levels of disaggregation below the national level to ensure that hospitals continue to bill appropriately and differentially for these services.” www.aapc.com January 2011 47 featured coder To discuss this article or topic, go to www.aapc.com If your ED leveling percentages are way out of line, it is likely that the guidelines you use for leveling are not complete in capturing all elements that can support the services. Who Is Responsible for Leveling? Many hospitals use medical records, or a coder/leveler who is based in the ED (a very good choice for ongoing interaction with ED personnel), to do some combination of the leveling, procedure coding, and ICD-9 coding. This is a great approach if the coder/leveler is trained properly, with complete guidelines and ongoing review and feedback. Some hospitals outsource the ED facility coding to firms that specialize in ED coding. This also can be a good choice. Hospitals often seek hospital-side certification for ED leveling positions. Presently, there is no specific certification for facility-side ED coding. AAPC, however, offers a Certified Emergency Department Coder (CDEC™) certification for reporting physician services. CEDCs must pass a demanding exam that consists entirely of ED chart reviews. CEDC certification assures the hospital that the coder has familiarity with ED procedure and ICD-9 coding, and should learn a given hospital’s leveling methodology quickly. Just remember: Expertise in ED physician coding does not equate automatically to expertise in facility leveling. Jim Strafford, CEDC, MCS-P, principal of Strafford Consulting Inc., has over 30 years experience as a consultant, manager, and educator in all phases of medical coding, billing, compliance, and reimbursement. He is a published, nationally recognized expert on emergency department revenue cycle and coding issues. He can be reached at [email protected] and www.StraffordConsulting.com. 48 AAPC Coding Edge Take Steps to Track Your ED Leveling Based on an analysis conducted by Strafford Consulting, many EDs fall close to national E/M leveling averages. But, in over 200 EDs, codes 99281 and 99282 represent the majority of services for sicker and older Medicare patients. Conversely, there are close to 100 EDs with 99284 levels well below national averages. If your ED is falling well below or above national averages, Strafford Consulting recommends: • Thoroughly reviewing your leveling tool and procedures. Are all elements that can be counted toward levels included in the tool? Are services given proper weight toward determining ED Levels? • Using available research tools from American College of Emergency Physicians (ACEP) to various point systems. Identify the tool that works best for your ED. • Auditing a significant sample of your ED charts. Review documentation and levels that were coded. Analyze data to determine whether the issue is chart documentation, your leveling tool, or coder error. • Determining if personnel doing leveling are best suited for the job. • Educating your staff on audit findings. • Scheduling reviews at least twice a year. • Seeking advice from an outside consultant, when in doubt. feature Acquire Coding Instructor Skills that Motivate Students By Geanetta Johnson Agbona, CPC A s I sit and observe my students intently reading their evaluation and management (E/M) packages, a smile comes across my face. I can see them processing the information: Some stretch their eyes, others rub their hands against their foreheads while breathing deeply, some guide their eyes by putting a pen, pencil, or finger under each word, and still others highlight in multiple colors. I grade each package carefully and feel a sense of pride when I discover each student has learned the material. After the test when the students are leaving, some tell me, “Thanks Mrs. G.—I got it! I am so glad that I passed my test. I will see you tomorrow.” Why are students motivated to return? A student’s desire to learn is a powerful motivator—but to keep students involved teachers should master three skills: audience contact, the use of illustrations, and enthusiasm. Eyes communicate feelings and thoughts. A droopy eye communicates fatigue, while stretched eyes could communicate anger, surprise, or even fear. When addressing students, face them and pause before you speak. This will encourage your students to focus their attention on you. Look at every student in your classroom. Do not stare at each student and force them to feel uncomfortable. Address a student via eye contact, and then move on to another. Take a tip from the book “Benefit from the Theocratic Ministry School,” which advises, “When you throw a ball to someone, you look to see if it is caught. Each thought in your lecture is a separate throw to the student. A catch may be indicated by their response, a nod, a smile, an attentive look. If you maintain good visual contact, this can help you to make sure that your ideas are being caught.” Notes can prevent a teacher from having good audience contact. Use an outline, instead of reading directly from notes. Glance at the outline instead of stopping to read a document verbatim. This requires thorough preparation. One of the best ways to teach is by using illustrations, including examples, comparisons, and dramatizations. You can use words such as “like” or “as” when giving an illustration. Similes and metaphors provide excellent illustrations. How would you teach your students the importance of coding correctly and avoiding fraud? You could be dramatic and wear black and white stripes with your ankles and hands bound together using a set of chains. For the less adventurous, you could tell a story about a practice that committed fraud and the consequences the practice faced. In the case of the latter, verify the information. Whatever form of illustration you decide to use, be sure it is understood by your audience and your idea is “caught” and not offensive. This is very easy to do if you are enthusiastic about your material. Hone in on three teaching techniques that speak volumes to students. PROFESSIONAL Make Audience Contact Use Illustrations Be Enthusiastic Even if you make eye contact and use illustrations, students won’t learn if their teacher sounds depressed, unhappy, and bored. If you are excited, your students will be excited. Always think about why your students need the material. Prepare the material in a way that it is exciting to present. Learn to read with feeling. Put life into your material. Sound as if you are convinced about what you teach. Do not SHOUT EVERY WORD, but spread excitement throughout the classroom. Enthusiasm is contagious. Teaching is an art. If you have been entrusted with the responsibility to mentor or guide someone, you can be effective. Audience contact makes it personal, illustrations make students understand, and enthusiasm motivates them to keep learning. Cultivating these skills will have your students saying, “I’ll see you tomorrow!” Geanetta Johnson Agbona, CPC, is a medical billing and coding instructor at Southeastern Institute, Charlotte, NC. She was recognized as “Instructor of Distinction” in 2010. She co-owns CGS Billing Service with her spouse, Charles Agbona. She can be contacted at [email protected] www.aapc.com January 2011 49 minute with a member Kristy Johnston, CPC Biller for Advanced Medical Consulting and Billing, Southwick, Mass. and are planning to take our next exams together. Without my mother, I wouldn’t be a coder and where I am today. We code together as a team. We use our coding knowledge to educate our doctors on proper billing and documentation. We take great pride in ensuring our billing methods reflect proper coding. I know not to just add a modifier or change a code. I take the time to request notes, and then educate the doctor if there is anything wrong. I would rather have my doctors prepared because, in today’s world of insurance audits, no one is safe. Coding Edge (CE): Tell us a little bit about your career—how you got into coding, what you’ve done during your coding career, what you’re doing now, etc. Kristy: I am a coder because of my mother, Patti Wood, CPC. She owns a small medical billing company that provides services for a variety of providers. Through the years, I have helped my mom when I could and four years ago, after the birth of my first daughter, I finally joined her company full time. I was intrigued by all the diagnostic and CPT® codes. The more accounts I worked with, the more diagnostic and CPT® codes I was exposed to on a regular basis. My mother has been an AAPC member for many years. She told me about the Certified Professional Coding (CPC®) exam and how she always wanted to take it. I asked her to take it with me, and after a lot of convincing, she agreed. Since then, our journey these past two years has been amazing. To begin with, we attended a coding boot camp. For three full days we ate, breathed, and slept coding. We were together and loved every minute of it. After completing the course, we studied every weekend and tested each other during lunch. Finally, we both sat for the exam and passed in June 2009. Mom and I often discuss hot topics, new codes, ICD-10, and other health care issues. We push and inspire each other 50 AAPC Coding Edge CE: What is your involvement level with your local AAPC chapter? Kristy: Mom and I attend local chapter meetings together and we recently attended the AAPC Regional Conference in Springfield, Mass. I try to attend local chapter meetings regularly; however, for a mother of two young children who works full time, that can sometimes be a challenge. I enjoy attending meetings when I can, and I look forward to volunteering for an officer position in the future. CE: What AAPC benefits do you like the most? Kristy: I utilize the AAPC webinars often. I really enjoy them. I usually take information from them to incorporate into everyday billing and coding practices. I find AAPC’s website informative, specifically the ICD-10 section. I enjoy the AAPC e-mails on ICD-10 and the new one on billing. CE: What has been your biggest challenge as a coder? Kristy: Confidence! Even though I have learned so much about coding, I still sometimes lack the self-confidence in determining a code. I am studying for the Certified Evaluation and Management Coder (CEMC™) credential. My goal is to properly determine the level of service based on the documentation provided. Fortunately, I can turn to my mom for a second opinion. I also am challenged by anatomy and physiology. Sometimes I am overwhelmed by the big words I can’t even pronounce. CE: How are you preparing for ICD-10? Kristy: Mom and I read articles and attend webinars or local meetings about ICD-10 whenever possible. We plan to take the ICD-10 proficiency test as soon as it is available. I took a general poll of our doctors and asked them about ICD-10. Almost all of our doctors replied, “You’re my billing service. It is going to affect you (the biller) more than me (the doctor)”. Huh?! So, our office is gearing up for ICD-10 to make sure all our practices have an implementation plan started by the beginning of next year. It seriously could impact productivity and claims payments if our providers aren’t ready, so I feel obligated to make sure they are. CE: If you could have any other job, what would it be? Kristy: That is difficult. I have done many jobs before settling on this career and I really enjoy being a biller and coder. The physician’s job is to provide the patient with quality care and services. Mine is to make sure they are getting paid correctly for their services. Honestly, I’d like to be a consultant for providers. In a dream world, perhaps I’d be a nurse or doctor.. CE: How do you spend your spare time? Tell us about your hobbies, family, etc. Kristy: Most of my time is spent with my supportive husband, Christopher, and my two beautiful and active daughters, Ezri, 4, and Rylee, 1. I hope someday one of my daughters pursues a coding career and we have the same opportunity to work together as my mom and I do. I also am an educational consultant with Discovery Toys, where I do home shows and sell children’s toys, books, and games. Need CEUs CodingWebU.com is the leading provider of books and online education geared towards Medical Coding and Billing. 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