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2014 Compliance Training Billing Compliance Office Dermatology Staff Meeting 7/10/2014 BWH/BWPO Billing Compliance Office 801 Massachusetts Avenue, 5th Floor Boston Mass 02118 Phone 617-582-0090 & 617-582-0095 (fax) Efficiency, Growth, Financial Performance Efficiency, Growth, Financial Performance Physician Billing Compliance • Modifier 25 when to use and when not to • Suture Removal Documentation • Copy and Paste 2 Efficiency, Growth, Financial Performance Modifier 25 • Informs the payers that the E&M service provided is a significant, separately identifiable service. • Payment for both the E&M and procedure is made only if an exception applies: – An unrelated problem is addressed – Patient’s condition requires above and beyond the usual care associated with procedure – Decision for procedure was made during exam 3 Efficiency, Growth, Financial Performance Procedures In every procedure there is some element of an E&M. • A brief history • Vital signs may be needed • Limited exam of the procedure site These are included in the reimbursement of the procedure if they are pertaining only to the procedure that was scheduled and being performed. Examples: injection, excision, biopsy, destruction Efficiency, Growth, Financial Performance 4 Injection with E&M History of Present Illness: Mr. Castro presents today in followup. He was last seen in this clinic in 7/12. He presents for evaluation and treatment of his keloidal scars. He has done well with these, but over the last 1.5 years, the scars on the chest have slowly enlarged and become increasingly tender, very sensitive to touch. They were flat for a long time, however. He does well after the injections but then they start to grow again. Medications Acetaminophen Extra Strength 500 MG (500 MG TABLET Take 1) PO Q8H PRN Knee ache, Last Updated: 10/04/2013; No Change Ecasa (ASPIRIN Enteric Coated) 81 MG PO QD, Last Updated: 10/04/2013; No Change Ibuprofen 800 MG (800MG TABLET Take 1) PO BID PRN pain - dolor, after eating - despues de comer, Last Updated: 10/04/2013; No Change Lipitor (ATORVASTATIN) 80 MG TABLET PO QHS, Dose increased from 40 mg to 80 mg today. Thanks, Last Updated: 10/04/2013; No Change Lisinopril 10 MG (10 MG TABLET Take 1) PO QD, Dose increased from 5 mg to 10 mg today, Last Updated: 10/04/2013; No Change Miralax (POLYETHYLENE Glycol ) 17 GM (17G/DOSE POWDER DOSE) PO QD, Each 17 GM dose to be dissolved in 8 oz of water, Last Updated: 10/04/2013; No Change Nifedipine (EXTENDED Release) 60 MG (60MG TABLET Take 1) PO QD, Last Updated: 10/04/2013; No Change Viagra (SILDENAFIL) 100 MG (100 MG TABLET Take 1) PO as directed PRN , Take 1 hour prior to relation. Maximum one per day., Last Updated: 10/04/2013; No Change Problems Hepatitis B : History of Hepatitis B Hypercholesterolemia hypertension : EKG: LVH Alcohol abuse Keloid scar Helicobacter-associated disease Adenomatous polyp of colon : Repeat Colonoscopy 2018 Hyperplasia of prostate : CT scan Steatosis of liver : CT scan 10/2011 Allergies NKA Physical Examination: Focused to the chest, back, arms. Well appearing, in no apparent distress. Mood and affect were normal. Notable Findings/Assessment/Plan: 1. Several keloidal scars today on the chest, right upper back, left upper arm. These have grown larger since our last visit, although still much smaller than when he initially presented. Lesion on left upper arm is minimal. Upper chest scar, left, is most severe. The 4 keloidal scars on the chest were wiped with alcohol and then a total of 0.6 mL of 40 mg/mL Kenalog was injected into the lesions. He tolerated this well. I will see him back in clinic on an as needed basis. Efficiency, Growth, Financial Performance 5 Injection Only HISTORY OF PRESENT ILLNESS: Followup visit, a delightful 25-year-old female here today for followup of keloid ear lobe. Status post excision keloid, left anterior ear lobe. The area is doing quite well. The patient pleased with results. Continue intralesional Kenalog 40 mg/mL, 0.3 mL instilled into the keloid and surrounding tissue. Tolerated well. Follow up 10 weeks/p.r.n. 6 Efficiency, Growth, Financial Performance Medicare’s Global Surgical Package Services considered part of the global surgical fee include: • Preoperative visits after the decision is made to operate beginning with the day before major surgical service and the day of minor surgeries. • Visits during post op period that are related to the recovery from the surgery . These services include: – – – – – post op pain management dressing changes removal of sutures, staples or drains local incision care removal of operative packs – typical postoperative follow-up care • All medical or surgical services due to complications that do not require additional trip to the operating room. 7 Efficiency, Growth, Financial Performance Suture Removal w/E&M CC: Suture removal; f/u eczematous dermatitis HPI: 55 yo AA male with h/o itchy rash on the abdomen, arms, and hands s/p biopsy revealing pityriasiform and spongiotic dermatitis with eos and excoriations consistent with eczematous dermatitis. DIF was negative. Was prescribed a taper of prednisone and has been on 40mg PO q day x 4 days now with marked improvement of the rash on his hands and arms. Using clobetasol 0.05% oint BID PRN to affected areas. ROS: negative, no other skin complaints. Feels well, no systemic complaints FHx: No family h/o melanoma Physical exam/Assessment/Plan: Well appearing pt in NAD mood and affect wnl A skin examination was performed including scalp, head, eyes, ears, nose, lips, neck, chest, axillae, abdomen, back, bilateral upper extremities, hands, fingers, fingernails Skin type: VI 1. Eczematous dermatitis -- favoring allergic contact dermatitis - Resolving patches with residual hyperpigmentation on the arms, hands and abdomen - Erythematous plaques on the abdomen - Involvement of the hands favors the radial palmar aspect B, suggestive of exposure to contact allergen - Pt works in a copy shop -- concern for possible sensitivity to thiuram or PPD in toner - Referral to patch testing at BIDMC 8 - f/u 1 month after course of prednisone is complete Efficiency, Growth, Financial Performance Suture Removal Only Patient presents for suture removal. Date of Procedure 5/22/14 Location/Pathology A. SKIN, LEFT ANTERIOR SHOULDER, EXCISION: BASAL CELL CARCINOMA, nodular type; margins appear negative. Cicatrix. There are no signs or symptoms of infection or dehiscence. There is no evidence of bleeding or hematoma formation. Sutures were removed. Pathology was reviewed with patient and patient was given wound care instructions. Patient informed to schedule follow-up appointment for skin check with Dr. Rubenstein 9 Efficiency, Growth, Financial Performance Copy and Paste • Always document the HPI based on the patient’s description that day-never copy it from a previous encounter • Only use the Review of Systems components that are relevant to that day’s encounter • Only use past medical, family and social history from a previous note if it is reviewed with the patient • Modify or delete template language when it does not apply to the visit that day • The individual performing the copy/paste function is responsible for the documentation regardless of who authored the original information 10 Efficiency, Growth, Financial Performance Risks • Inaccurate or outdated information may adversely affect patient treatment • With each copy/paste replication, notes are lengthened and errors accumulate • Inability to accurately support medical necessity or defend services for professional or technical billing • Inability to identify authors…..who thought what 11 Efficiency, Growth, Financial Performance Payors and Regulatory Agencies National Government Services (Medicare) Cloned documentation will be considered a misrepresentation of the medical necessity requirement for coverage of services due to lack of specific individual information for each unique patient. Identification of this type of documentation will lead to denial of services for lack of medical necessity and the recoupment of all overpayments made. OIG Medicare contractors have noted an increased frequency of medical records with identical documentation across services. We will review multiple E/M services for the same providers and beneficiaries to identify HER documentation practices 12 associated with potential improper payments Efficiency, Growth, Financial Performance Partners Health Care Health Information Services EHR Policy PH-140 Copy and pasting information that originated within the Partners electronic record is not recommended, as it could create redundant information. It should only be copy and pasted if it is critical that information be repeated in the current note and had a direct impact on patient care rendered during that encounter 13 Efficiency, Growth, Financial Performance Questions? Thank You ! 14 Efficiency, Growth, Financial Performance