By Melody S. Irvine, CPC, CPMA, CEMC, CFPC, CPC-I, CCS-P, CMRS
As a physician auditor, I spend much of my time educating clinicians on proper documentation. This involves explaining and interpreting coding and compliance guidelines. When providing such guidance, the most common reply I hear from providers is, “I want it in writing.” An auditing compliance plan helps to satisfy this need.
Formulate a Plan
An auditing compliance plan gives providers written details of what is expected and/or permitted for documentation and billing purposes. For example, a plan may specify what terminology is permissible, which examination guidelines will be used, and the documentation required to support a type or level of service.
An effective plan also provides a map for all auditors (internal or external) to follow, and shows a practice’s “due diligence” in monitoring, education, and documentation. Finally, per the Office of Inspector General (OIG), auditing and monitoring of physician documentation is required.
Get It in Writing
The accompanying sample auditing compliance plan (pages 48-51) can aid in developing an effective plan of your own. Use this as a guide only; your auditing compliance plan should be based on your medical practice, Medicare/payer guidelines, and the recommendations of your compliance officer. I also recommended your practice’s health care attorney to review any compliance plan you put in place.
Put Your Plan into Motion
Formulating your auditing compliance plan is step one. You must also put the compliance plan into effect and ensure that it’s followed.
Auditing Compliance Plan Sample
A. Purpose of Audits
(Name of Medical Practice) promotes adherence to an Auditing Compliance Program as a major element in the performance evaluation of all Providers/Non-physician Practitioners (NPPs) documentation. Providers are bound to comply, in all official acts and duties, with all applicable laws, rules, regulations, standards of conduct, including, but not limited to laws, rules, regulations, and directives of the federal government and the state of ______________, Medicare Contractor, Fiscal Intermediary (FI), or Carrier (Name of MAC Provider) and rules policies and procedures of (Name of Medical Practice).
B. Orientation and Training
All new Physicians/NPPs will receive orientation and training in documentation and auditing policies and procedures. Failure to participate in required training may result in disciplinary actions, up to and including, termination of employment. Every Physician/NPP is asked to sign a statement certifying they have received, read, and understood the contents of the auditing compliance plan.
C. Education
Every Physician/NPP will receive periodic training updates in auditing. Ongoing education will be based on regulatory changes. Attendance is mandatory for all providers.
D. Audits/Monitoring
Auditors will conduct ongoing evaluations of compliance auditing processes involving thorough monitoring. The audits will inquire into compliance with specific rules, policies, documentation and policies of Medicare FIs or Carriers. Audits should identify any patterns and trends, non-compliance, or violations.
Auditors
All audits will be performed by Certified Coders with one or more of the following credentials; (CPC®, CPMA®, etc.). Auditors will be audited by external resources to monitor their accuracy and performance.
Frequency of Audits
Internal audits will consist of a minimum of 10 audits per Provider and will be conducted on a (monthly/quarterly/semi-annual/annual) basis. They will be selected on (random basis, trending reports, frequency).
Audit Error Rate
Error rates will be conducted with Provider audits and required to pass audits at a minimum of (90 percent is recommended).
Auditing Reports
Following each audit, Physicians will receive a written report, including:
- Patient name/date of service
- Provider name
- Level billed/level documentation supports
- Diagnosis codes billed/diagnosis documentation supports
- Any coding/billing discrepancies
- Medical necessity
- Recommendations/concerns
- Auditor name
E. Non-compliant Physicians/NPPs/Auditors
When disciplinary action is warranted, it should be prompt and imposed according to written standards of disciplinary action. Continuous violations will be reported and the Medical Director will determine the appropriate actions.
F. Documentation Requirements
New vs. Established Patients
Documentation should clearly state when the patient is new to the practice. A new patient is one that has not been seen within the same group practice in three years.
Component Requirements
These three components will be used to qualify the level of service performed. If any of the components is missing from the documentation, the services will not be billed.
- History
- Examination
- Medical decision making
Counseling/Coordination of Care/Time
- Documentation requirements:
- Time spent counseling, detailed documentation of counseling
- Coordination of care – documentation of time, detailed documentation of coordination of care provided, and conversations with other health care providers
Chief Complaint
The medical record should clearly reflect the chief complaint. The chief complaint will support the medical necessity of the services/procedures provided.
History
Three chronic illnesses can be used for an extended history of present illness (HPI).
HPI can be recorded by the ancillary staff or by the patient, but must be reviewed and confirmed by the provider.
Review of systems (ROS) and past medical, family, social history does not need to be re-recorded if obtained during an earlier encounter; however, documentation of no change, and that the information was reviewed, must be noted.
Documentation should clearly reflect the patient condition or circumstances that prevented the provider from obtaining any history.
Documentation of unremarkable and non-contributory are not acceptable forms of documentation.
Documentation of normal or negative is permissible, but abnormal findings must be described.
ROS must meet medical necessity of the systems reviewed.
“All others negative” (is or is not) acceptable with (your FI name).
If an element is used in the HPI, it cannot be used in the ROS.
Examination
All audits are based on 1995 or 1997 Documentation Guidelines for Evaluation and Management Services.
The extent of examination performed must meet medical necessity for the patient’s illness, condition, or injury.
Abnormal or any relevant negative findings should be documented and described. Negative, normal, unremarkable, and/or noncontributory are not acceptable forms of documentation.
Certain acronyms are not permissible. Each organ system or body area should be described in detail.
1995 Exam
The level of examination for 1995 guidelines will be determined as:
- 1 body area or 1 body system – Problem Focused
- 2-4 body areas and/or body systems – Expanded Problem Focused
- 5-7 body areas and/or body systems – Detailed
- 8 or more body systems – Comprehensive
Medical Decision Making (MDM)
No credit is given for a diagnosis that is not applicable to that day’s visit, unless it is a secondary issue.
Diagnoses must have relevance to the treatments provided or ordered.
Attending Physician should document when interpretation was done, and the results.
If history is obtained from someone other than the patient, this information must be documented.
When old records are reviewed, document that fact, along with a summary of those records.
Discussions with other health care providers must be documented, with a summary of the conversation.
Diagnosis Codes
Diagnosis codes for billing services, and ordering ancillary services, must be supported in the medical record.
Include information that will be important for ICD-10.
G. Other Evaluation and Management (E/M) Coding Guidelines
Critical Care (99291-99292)
Critical care must be supported by documentation. Time spent with the patient in critical care must be documented in the medical record. If the patient is unable to participate in discussions, time spent with family members or another decision maker must be documented.
Consultation Visits (non-Medicare Patients)
(99241–99255)
Consultations must be documented as a request for an opinion from another provider. It is the Provider’s responsibility to make sure a report is written to the referring Provider. The report must be documented. The documentation must state the reason for the consultation, as well as the Provider’s opinion and recommendation.
Observation Care Codes (8-hour Rules)
(99218–99226, 99234–99236)
Observation services that are less than 8 hours and performed on the same calendar day: Report 99218-99220 without discharge code 99217.
Observation care performed at a minimum of 8 hours, but less than 24 hours, on same calendar day: Report 99234-99236 without 99217.
Patients admitted to inpatient for less than 8 hours: Report 99221-99223 without discharge codes 99238-99239.
Prolonged Services (99354–99357)
Codes 99254-99357 must be used with other E/M codes.
Time spent with the patient must be face-to-face and documented in the medical record.
Each additional 30 minutes (minimum of 15 minutes) must be documented.
Documentation must support billed prolonged services.
Prolonged services without face-to-face services (99358-99359) are not billable.
Care Plan Oversight
Care plan oversight can be billed for patients in office/outpatient, hospital, home, nursing facility, hospice, home health agency, or domiciliary settings for non-face-to-face services.
Only one Physician can report care plan oversight per month.
Documentation must detail:
i. Patient name, date of service
ii. Detail of services performed
iii. Time spent on non-face-to-face services
iv. Physician name
Preventive Medicine (99381-99397)
Office E/M (can or cannot) be charged during a preventive visit for any abnormality that is encountered.
A separate note for the abnormality must be documented to support the visit.
Any insignificant problem or abnormality is included in preventive care.
H. Procedure/Surgery Documentation
Procedures performed without an E/M component must be documented in detail with:
Date of surgery, patient name and date of birth, surgeons, anesthesiologist and type of anesthesia used, facility where services were performed, consents obtained, preoperative diagnosis/postoperative diagnosis, indications for the procedure, IV infusions, description and details of procedure, findings, complications and how they were resolved, diagnostic reports/pathology reports, intra-operative information, postoperative condition of patient, and signatures.
I. Cloning Documentation
Cloning is “cut-and-paste” documentation resulting in the medical record being worded exactly the same or similarly to previous entries or encounters. Cloning is not acceptable.
J. Medical Necessity
Auditors will take reasonable measures to ensure that claims for services for office encounters and all procedures performed are reasonable and necessary, given the patient’s condition. All documentation must meet the medical necessity and MDM of the level charged.
K. Addendums/Late Entries
Any corrections to the medical record, such as addendums or late entries, are acceptable within (days/weeks/months). Dates of addendums/late entries must be documented.
L. Acronyms
Below are the only acceptable acronyms used for (Name of Medical Practice):
(e.g., Acceptable:
1. HTN – Hypertension
2. COPD – Chronic Obstructive Pulmonary Disease
Unacceptable:
1. HEENT in examination)
M. Handwritten Notes
Handwritten notes (i.e., hospital encounters that are handwritten) will be reviewed by two separate auditors, if illegible. If either auditor is unable to decipher handwritten information, the documentation will be considered non-billable.
N. Modifiers
Modifier use will be audited according to frequency and proper use.
O. Advanced Beneficiary Notice
of Noncoverage (ABN)
ABNs must be presented to the patient before a service/procedure is performed to notify the patient that Medicare may not cover the service. The entire form must be completed and signed by patients, but only for those services that may not be paid by Medicare.
P. Unbundling of Services
Some services are bundled into services per National Correct Coding Initiative (NCCI) edits. These services will not be unbundled per the request of a Provider unless documentation or modifiers support the medical necessity. Some items—such as pulse oximetry and electrocardiograms—are routinely bundled into office visits and not billed separately.
Q. Global Days/Surgical Packages
Services included in global days and surgical packages cannot bill be separately.
R. Incident-to
NPP professional services can be billed as incident-to with the following guidelines.
New patients are not billed as incident-to.
Established patients with new problems are not billed as incident-to.
The Supervising Physicians must be present in the office and immediately available when billing incident-to.
S. Scribes
The record must be clear that the Physician has performed all components of the service. Documentation should include that the information was obtained by the scribe acting on behalf of the Physician, the scribe’s name, and the date. Documentation should include a statement that the information obtained by the scribe has been reviewed and verified by the Physician.
T. Signatures
All signatures should be original or electronic and legible. Stamped signatures are not allowed. Attestation statements may be required if signature requirements are not met.
U. Teaching Physician Guidelines
Provided office services will be determined by the combine documentation from the Resident and Teaching Physician. The Resident can document his or her services in the office and the Teaching Physician must also document his or her participation of the service rendered. If documentation is incomplete or invalid, the Teaching Physician must document as if services were performed in a non-teaching setting.
Most practices have a medical director or a physician who is a “cheerleader” and supports coders, auditors, and compliance standards. This is the person you want to have help you develop and implement your plan. If you have a physician’s support, you have won half the battle. Organize an auditing compliance committee to develop the plan, and meet regularly for follow-up, amendments, and disciplinary measures with non-compliant individuals. You cannot expect your physicians to follow all rules and regulations without proper training.
Melody S. Irvine, CPC, CPMA, CEMC, CFPC, CPC-I, CCS-P, CMRS, is owner of Career Coders, LLC, a medical billing and coding school in Colorado. She served as an officer on the AAPC National Advisory Board.
April 1st, 2013
Let under-utilized appeals systems work for your practice.
By Heather M. Shand, CMAA, CBCS, CMB
Sometimes, even if you do everything right, you may end up with denied claims. Rather than throw up your hands and walk away, you should appeal. Yes, it will mean extra work, but the results are worth it: Most of the offices I’ve worked with have increased their revenue by at least 30 percent through strategic appeals. Here are seven steps to get you started.
1. Investigate Every Denial
If the insurer denies a claim, you must find out why and follow up to correct problems or collect payment if the denial is in error. Double-check everything about the claim to be sure you have grounds for appeal. Do not just re-file an unamended claim, hoping for payment the second time around.
For instance, if you are coding a surgery, review the “body” of the operative report to be sure all listed procedures actually were performed. Check modifier use. Maybe you missed a necessary modifier 25 Significant, separately identifiable evaluation and management service by the same physician on the same day of the procedure or other service. or 59 Distinct procedural service? If the insurer denies the claim for medical necessity, check to be sure the service was documented appropriately. Regardless of what the doctor does or how valid the service, you are sure to get a denial if the details are not documented sufficiently to support the claim.
If the insurer’s denial is unwarranted, or you are able to legitimately amend the claim to gain payment, it’s time to roll up your sleeves and ready yourself for an appeal.
2. Know Your Payers’ Appeal Process
Be sure you understand your rights to appeal. Most fully-funded plans have a designated external appeals process. Appeals may be more difficult with self-funded plans; you may wish to seek the advice of an attorney. Determining if plans are self funded or fully funded will help you prepare for appeals before you have to pursue them.
Know the type of problems and issues your state’s external appeal programs address, and whether appeal programs other than the state’s external appeal program and the insurer’s internal appeal programs are available to you.
3. Explain Yourself, Then Mark Your Calendar
Prepare a letter to the payer that explains exactly why you are appealing. If you’re unable to state in straightforward terms why you deserve payment, don’t expect to get it.
Be sure to submit appeals in the allowable time frame. This usually is 180 days. The time may be less if you are contracted. If you are contracted, review your rights; you may have given up your appeal right by being in network.
4. Send Appeals Certified
When submitting an internal appeal, send it via certified mail. You need to track that the insurer received the appeal. If you can’t track it, you have no proof it was ever sent.
If you did your homework, you know exactly how long the insurer has to respond to your appeal. If you do not have a response by the allowed time, file a complaint with your state insurance department. The state may ask for proof you sent the appeal (which is where your certified mail receipt comes in).
5. Be Wary of Internal Appeals
The insurer is likely to first pursue an internal appeals process. Some insurance companies require two internal appeals, while others require only one internal appeal.
Before you pursue an internal appeal, make sure it is mandatory. If it isn’t, and you choose to file internally with the insurer, one of two things could happen that are not to your benefit:
- The insurance company sends your appeal to an outside vendor for review. Such reviews are supposed to be independent, but often are not. Appeal decisions of this type can be binding, or can be used against you in later appeals.
- While you are pursuing an optional appeal, you may be missing out on your time to submit to the state. Most external appeal to the state must be sent within a certain time frame from your final adverse appeal determination letter. If you miss a deadline, you will lose your right to appeal.
Bottom line: Only agree to mandatory internal appeals. Do not accept optional appeals.
6. Direct External Appeals Appropriately
If you exhaust the internal appeals process without results, you must decide where external appeals need to be sent. For example, New Jersey has two appeal systems: one for experimental/medical necessity and another for incorrect payments. You also need to find out what your state requires you to send to them to process an external appeal.
For information regarding your state external appeals, go to your states’ departments of banking and insurance websites (or, call them). Most states require you to complete a form, and some states charge fees of $25-$250. If the appeal is in your favor, they usually return the money.
Note: There are avenues to collect incorrect payments/underpayments. You can use Maximus if your state has that program. Most states also have a complaint department you can use for these types of issues, which are outside of the normal appeal systems.
7. Be Strategic
Before pursuing an appeal, assess the amount of the claim and determine if it is worth the fees. Ask yourself: Does the amount of the claim warrant the fees you might lose? For instance, if the claim is $25, you most likely won’t risk $100 in fees to submit it. Keep in mind the insurance company also has to pay for external appeals, so this can be a bargaining chip.
Appeal systems are underutilized. The appeals systems can work for your practice and can increase your revenue. You will have to put time into this process, but the rewards are great. Keep in mind that all external appeals are paper reviews, not oral reviews. You need to make sure you are articulating your argument in an orderly, rational, and reasoned manner. If you have documented correctly and can articulate your agreement on paper, there is no reason why you cannot capture your lost revenue.
Know the Medicare Appeals Process
After an initial claim determination, providers, participating physicians, and other suppliers have the right to appeal, which may progress through as many as five levels. All appeal requests must be made in writing and must contain specific information (such as beneficiary name, dates of service, and other details), as detailed in the Centers for Medicare & Medicaid Services (CMS) publication “The Medicare Appeals Process: Five Levels to Protect Providers, Physicians, and Other Suppliers.”
First Level: Redetermination
A redetermination is an examination of a claim made by fiscal intermediary (FI), carrier, or Medicare administrative contractor (MAC) personnel; these are not the same people who made the initial determination. The appellant (the person filing the appeal) has 120 days from the date of receipt of the initial claim determination to file an appeal. No monetary threshold is applied to first-level appeals. The FI has 60 days from the date of receipt to issue a redetermination. If a provider disagrees with the FI’s redetermination the provider may seek the second level of appeal.
Second Level: Reconsideration by a Qualified Independent Contractor
Second-level appeals, or reconsiderations, are made to a qualified independent contractor (QIC). No monetary threshold is applied to second-level appeals. The provider must file reconsiderations within 180 days of receipt of the FI’s redetermination.
All supporting documentation, such as the initial demand letter and any evidence supporting the provider’s claim and the FI’s redetermination should be submitted with the reconsideration request. Any documentation not submitted prior to the issuance of the reconsideration decision may be excluded from subsequent levels of appeal. Additional evidence or documentation may be admitted only in subsequent levels of appeal upon a showing of “good cause.” Where the appeal is a matter of medical necessity, a QIC is required to have an independent panel of physicians or other appropriate health care professionals review the claim.
The QIC has 60 days from the date of receipt to issue reconsideration. If a provider disagrees with the results of the QIC’s reconsideration, the provider may seek the third level of appeal. If the QIC does not finish its reconsideration during the 60-day time frame, the provider has the option to accelerate to the next level of appeal by filing directly with the administrative law judge (ALJ).
Third Level: Administrative Law Judge Hearing
ALJ hearings are available if the amount in controversy totals at least $130. A request for an ALJ hearing must be filed within 60 days after receipt of the QIC reconsideration decision. The request also must be forwarded to the individuals who participated in the QIC panel.
Specific reasons why the defense disagrees with the level 1 and 2 findings, cogent arguments, and expert witness testimony at this level can be helpful because the ALJ will often seek clarification from the expert why the provider documented a certain way, or may ask the expert to explain why the defense disagrees with previous appeals.
ALJ hearing decisions must be issued within 90 days after receipt of the hearing request. If the ALJ hearing decision is not issued within the applicable time frame, the provider may request to the ALJ that their approval move forward to the fourth level of appeal. If a provider disagrees with the result of the ALJ hearing, the provider may seek the fourth level of appeal.
Fourth Level: Medicare Appeals Council Review
Fourth level appeals are made to the Medicare Appeals Council. There is no monetary threshold, although all claims must be at least $130.
A request for a Medicare Appeals Council review must be filed within 60 days of receipt of the ALJ hearing decision. A Medicare Appeals Council decision must be issued within 90 days of receipt of the request for review. If a Medicare Appeals Council decision is not issued within the applicable time frame, a provider may request for their appeal to move forward to the fifth level of appeal. If a provider disagrees with the results of the Medicare Appeals Council, the provider may seek the fifth level of appeal.
Fifth Level: Judicial Review in U.S. District Court
Judicial review in U.S. District Court is available only if the amount remaining in controversy totals at least $1,260. The request for judicial review must be filed within 60 days of receipt of the Medicare Appeals Court decision. There is no time frame for the judicial decision.
Heather Shand, CMAA, CBCS, CMB, is CEO of N&D Consulting, LLC, and Smart Healthcare Solutions. N&D is a consulting, billing, and collection management firm for all types of practices, specializing in revenue management. Heather has served on the advisory board for Lincoln Technical Institute. Prior to starting N&D Consulting, Heather worked for a multi-disciplinary practice for several years.
June 1st, 2012
With a trend moving toward hospital care, consider chargemaster basics.
By Dorothy Steed, CPA, CPC-H, CPC-I, CEMC, CFPC, CPMA, CHCC, CPUM, CPUR, CPHM, CCS-P, ACS-OP, RCC, RMC
As more physicians head under the hospital umbrella to furnish cost-effective care, opportunities are opening for coders in the facility environment. Your doctor may be considering a move to a facility setting, or perhaps you’ve been considering taking advantage of new emerging hospital jobs. Whatever your motivation may be, now is a good time to learn as much as you can about the nuances of facility coding. To get you better acquainted with hospital coding and billing, let’s talk about one area of coding that is different from the physician office: the chargemaster.
The chargemaster is a large master file combining all services provided by each hospital. As patients receive services, that department enters the charges through this mechanism.
The structure contains these elements:
- An internal general ledger number
- A revenue code under which the charge will be posted
- A CPT® code
- The facility’s charge for one unit of service
Also included is a flag which indicates a current service, service or code scheduled for deletion, or inactive service.
Chargemaster Maintenance
The chargemaster needs to be updated at least annually, and when beginning new services or discontinuing current services. This task is likely to be a full-time position in a large facility. When a new fiscal year begins, it is common for hospitals to increase their rates across the board. This requires chargemaster updating to reflect the new rates. Chargemasters also must be updated to reflect ongoing code changes.
Posting Charges
Typically, all laboratory, radiology, respiratory/pulmonary, and therapy services are posted from the chargemaster, as well as pharmacy and supply charges. If the facility has a dedicated gastrointestinal (GI) or cardiovascular lab, these charges may also be posted through the chargemaster. When the designated department provides services to a patient, the department is responsible for entering the correct charges to the patient’s financial record. For admitted inpatients, the unit on which the patient is admitted will post the applicable room charges, drugs, and supplies to the patient record. Clinics, the emergency department, and the observation area will post facility charges applicable to their respective areas; and surgery, anesthesia, and recovery will post their charges. For surgery, anesthesia, and recovery, 1 unit typically equals 15 minutes (4 units would equal 1 hour).
It is customary for facilities to set their financial systems to drop claims to the biller’s queue in a specific number of days after patient encounter. For example: If it is set for six days, the claim will drop to the biller on day seven. This step allows time for departments to complete charging for their patients and for the coding department to finalize coding.
Coder’s Role
Facility coders are responsible for diagnosis coding of all inpatient records, ambulatory surgery, emergency department, and ancillary service departments. It isn’t uncommon to report 15 or more diagnosis codes on an inpatient record. Coders apply CPT® codes for ambulatory surgery and some emergency services. Patients who present for diagnostic testing, such as laboratory or radiology, will not require CPT® codes from the coding staff because these codes will be applied by the chargemaster. CPT® codes are not reported on inpatient claims; however, procedure codes from ICD-9, volume 3, must be applied by the coder. Facility coders also are required to report the present on admission (POA) indicator on inpatient claims and abstract the record. The abstractor is a separate software program that finalizes the coding function. These steps must be completed based on productivity and accuracy standards.
Biller’s Role
Billers and coders generally are maintained as separate departments in a facility, and likely do not interact with each other on a daily bases. The coders may be stationed in the health information management department, or they may be working remotely from home. Billers are most commonly based in the business office.
Once a claim drops to the biller’s queue, the responsibility then falls to the biller to review the claim information for posting errors, missing charges, missing modifiers, incorrect number of units, and coding completion. The facility biller must be adequately skilled to make these determinations. Although it is unlikely that each drug or supply will be recognized by the biller, he or she must be able to determine when required charges are missing. Examples are:
(1) Anesthesia and recovery is charged; no surgery charge
(2) Procedure code indicates implant; charge for implant is missing
(3) 230 units charged for anesthesia (This would equate to 15 hours under sedation, an unlikely number of units.)
If the biller determines that a claim has erroneous or missing charges, he or she must place a hold on the claim until the errors have been corrected. One rationale for the facility financial system’s automatic dropping of claims is to maintain some control of unbilled claims. The billing manager can determine the number of claims dropped to each biller and the number of claims released by the biller. The biller is held accountable for claims assigned to his or her queue, and must be ready to report held claims due to charge errors or incomplete coding. If certain departments have a high incident of incorrect or delayed charging, the manager of that department is likely notified and expected to develop an action plan to reduce charge posting errors. If there is a coding backlog, coding management is expected to explain the delay and provide a reasonable plan to bring the work current.
Delays and Late Charges
Another potential problem is charge posting delays over a three-day holiday. If services rendered on Friday are not posted until sometime the following week, the original claim will be incomplete. The delayed posting will drop to the biller queue as late charges (depending on how many days the financial system is set for dropping the claim). Medicare typically pays hospitals based on Medicare Severity Diagnosis-related Group (MS-DRG) for inpatient claims and Ambulatory Payment Classifications (APC) for most outpatient services. This equates to reimbursement for all services based upon the calculation; late charge billing is not accepted from facilities that are reimbursed based on these concepts. This is another reason facility billers must be skilled enough to recognize missing charges. If deemed to be the case, the claim must be held until the late charges have dropped and those charges must be added to the original claim. If released prior to the late charge inclusion, the original claim must be revised and resubmitted as an adjusted claim.
Keeping Errors in Check
The skill set required for facility billers is much different from physician billers. Although the chargemaster is a valuable tool used for charge maintenance and posting, the users must exercise care in correct posting and the biller must keep billing errors to a minimum. These performance stats are often tracked by management to determine areas of billing weakness and to plan for and implement training where deficiencies are identified.
Planning Ahead for Hospital Coding Trends
The Certified Professional Coder-Hospital Outpatient (CPC-H®) credential prepares a coder for the specialized payment knowledge necessary for facility jobs. The CPC‐H® credential recognizes expertise in the area of outpatient hospital, hospital‐based ASC coding, and independent ambulatory surgery centers (ASC). If you are interested in solidifying your expertise in these areas, go to AAPC website to learn more.
Dorothy Steed, CPA, CPC-H, CPC-I, CEMC, CFPC, CPMA, CHCC, CPUM, CPUR, CPHM, CCS-P, ACS-OP, RCC, RMC, is a technical college instructor in Atlanta and an independent consultant, performing physician audits and education for the Quality Improvement Organization in Georgia. Her 34 years of experience in health care includes working as a Medicare specialist for a large hospital system, as well as contributing to various medical publications, presenting at health care conferences, and developing training classes focusing on facility billing, coding, and reimbursement.
May 1st, 2012