In the world of healthcare revenue cycle management, there are numerous scenarios that can put a stranglehold on your revenue if you’re not prepared. With the COVID-19 pandemic causing varying degrees of change in inpatient volumes and visits, and telemedicine coming further into play, physicians and their practices are having to quickly navigate the nuances of their financial well-being. A practice may be buttoned up from the time the patient walks in the door, but what happens after the visit will determine when the practice will get paid. This element of the revenue cycle starts with coding. Here are five medical coding challenges that will ruin your bottom line.
1. Coding to the Highest Specificity
Missing data on a claim relative to the patient’s diagnosis and procedure can easily cause a rise in denials once received by the payers, resulting in potentially thousands of dollars in write-offs. Medical coders are responsible for coding patients’ claims to the highest level of specificity, ensuring the appropriate CPT, ICD-10-CM, and HCPCS codes are applied based on the patient’s chart from the day’s services.
COVID-19 and telemedicine are frequently bringing on new codes and code sets, all with different variations and modifiers to make the matter even more complex. Medical coders spend a lot of time researching and learning new codes, but every year – and throughout the year – changes and updates are made. Payers don’t only want to know the diagnosis and the treatment; they want to know the cause as well. The Coronavirus Aid, Relief, and Economic Security Act passed in March of 2020 allows for an additional payment from Medicare of 20 percent for claim billed for inpatient COVID-19 patients, however, it was later indicated that a positive COVID-19 test must be stored in the patient’s medical records in order to be eligible for this payment. Being able to stay on top of codes specific to the patient’s diagnosis at treatment is more difficult than ever before.
While code specificity is important, so too is ensuring the claims do not contain codes for exaggerated procedures, or even procedures that were never performed, resulting in reimbursement for these false procedures. This seems logical enough, but upcoding can easily occur as a result of human error, misinterpretation of a physician’s notes, or lack of understanding of how to appropriately assign the thousands of ICD-10-CM codes in existence. To add to the pressure, the Office of the Inspector General issued a plan with objectives to prevent fraud and scams, and remedy misspending of COVID-19 response and recovery funds.
Much like under-coding or not providing enough data on the patient’s visit can create issues, upcoding can be a major contributor to financial loss for a practice. Questionable claims can be denied and sent back for corrections and appeals, but upcoding can have more serious ramifications outside of paper-pushing between coders and payers.
Whether it’s making sure the codes are in accordance with the care provided, understanding the code sets that apply for each procedure, or comprehension of the medical record, refraining from upcoding will help ensure a sturdy and compliant revenue stream.
3. Missing or Incorrect Information
There’s a common theme to coding challenges, and that’s having the sufficient information necessary. This information typically is pulled from a patient’s chart or record of a visit, which is often completed by the attending physician. However, even when a claim is submitted, providing required information relative to the procedure to the payer is critical as well. Situations such as failure to report time-based treatments (such as anesthesia, pain management, or hydration treatments) or reporting a code without proper documentation can result in denials.
Furthermore, information in a patient’s electronic health record may also contain inaccurate information. Keystrokes and other human errors can cause these situations to flare up, and it takes a diligent, thoughtful coder to read between the lines and ensure claims have the appropriate information.
4. Timeliness of Coding
The Medical Group Management Association (MGMA) suggested in their 2018 Setting Practice Standards report that a Primary Care Physician should maintain a claim submission rate of 3.11 days after the date of service, but it is becoming increasingly difficult for practices to sustain anything close to this rate. Constant changes to code sets, an increased focus on submitting claims with sufficient and compliant information, and the requirement to code claims to the highest level of specificity, can easily delay the submission by days or weeks.
Nevertheless, delays in coding and submitting claims can cause major lags in payment and substantial loss in revenue. Insurance payers have statutes of limitations that require claims to be submitted anywhere from 120 to just 60 days after the date of service. Simply put – the more time spent coding the claim, the later it will be submitted, thus increasing the odds that the claim will be denied. Expert coders are aware of this and do everything in their power to get coded claims out the door.
5. Staffing Shortages
However, finding experts well versed in coding claims quickly, accurately and in compliance with the False Claims Act is not always an easy task. As you can imagine, the increasing need for care within the senior population is causing a rise in claim volumes, and trying to find a team of coders who know the ins and outs of complex ICD-10-CM coding can easily cause a bottleneck in the revenue cycle. Health executives expressed their struggles to find talent back in 2015, and some forecasts expect a decline in commercial payments by 2024 to further hamper a C-suite’s ability to manage labor costs. The ramifications of incorrect coding are still a key topic of discussion to this day.
The time has come for practices to begin looking outside of their organization for coding support. How is your practice planning to tackle the coding conundrum? When choosing a partner for your medical coding needs, you need to pick an expert to help your practice stay on target. TriZetto Provider Solutions, a Cognizant Company, has available highly-trained, AAPC & AHIMA certified coders with the experience of getting the details right the first time and understand the importance of coding to the medical practice.
For more information about TriZetto Provider Solutions, a partner of EZClaim, visit their website, contact them, or give them a call at 800.969.3666.
ABOUT EZCLAIM: EZClaim is a medical billing and scheduling software company that provides a best-in-class product, with correspondingly exceptional service and support. Combined, they help improve medical billing revenues. To learn more, visit EZClaim’s website, e-mail them, or call them today at 877.650.0904.
[ Contribution of the TriZetto Provider Solutions Editorial Team ]
EZClaim is always looking for ways to help our medical billing clients improve. In an effort to further that mission, this month we are kicking off the first in a series called, “What’s Current in Coding.” In this series, we will highlight coding topics, events, webinars, and more, all with the aim of keeping you current in medical billing and coding.
This month our focus came from two articles on coding sourced from the AMBA Newsletter that we feel are hot topics of the industry: “Coding for Group Visits” and the “Telehealth Coding Guide.”
Below you will find full articles and source links.
ARTICLE 1: “Coding for Group Visits”
Many physicians are interested in providing group medical visits. Whether the drop-in group medical appointment (DIGMA), chronic care health clinic (CCHC) or other model is delivered, the coding and billing of these services raise questions about codes and payment policies.
While past instruction on coding for group visits often indicated that physicians should report code 99499 for unlisted evaluation and management services, using this code requires that documentation is sent with the claim to identify the service(s) provided and leaves valuing of the service in the hands of the payer.
No official payment or coding rules have been published by Medicare. However, the question of “the most appropriate CPT code to submit when billing for a documented face-to-face evaluation and management (E/M) service performed in the course of a shared medical appointment, the context of which is educational”, was sent to the Centers for Medicare and Medicaid Services (CMS) with a request for an official response. The request further clarified, “In other words, is Medicare payment for CPT code 99213, or other similar evaluation and management codes, dependent upon the service being provided in a private exam room or can these codes be billed if the identical service is provided in front of other patients in the course of a shared medical appointment?”
The response from CMS was, “…under existing CPT codes and Medicare rules, a physician could furnish a medically necessary face-to-face E/M visit (CPT code 99213 or similar code depending on level of complexity) to a patient that is observed by other patients. From a payment perspective, there is no prohibition on group members observing while a physician provides a service to another beneficiary.” The letter went on to state that any activities of the group (including group counseling activities) should not impact the level of code reported for the individual patient.
Some private payers have instructed physicians to bill an office visit (99201-99215) based on the entire group visit. For compliance purposes, we recommend that you ask for these instructions in writing and keep them on file as you would any other advice from a payer.
Where each individual patient is provided a medically necessary, one-on-one encounter, in addition to the time in the group discussions, there should be no problem in billing for the visit based solely on the documented services provided in a direct one-on-one encounter.
If your group visits include the services of nutritionists or a behavioral health specialist, contact payers to determine if that portion of the group visit can be directly billed by the non-physician provider. This typically would include codes for medical nutrition therapy (97804) or health and behavior intervention (96153).
Other codes that may be applicable are the codes for education and training for patient self-management involving a standardized curriculum (98961-98962). Neither these codes nor medical nutrition or behavioral health therapy are billed by physicians. Physicians must use evaluation and management codes to report these services.
Code 99078 describes physician educational services in a group. Again, it is necessary to contact the payer to verify that coverage of this service is a payable benefit.
As with many services, coding for group visits requires that billing and coding staff do preliminary work with payers to identify desired coding applications.
ARTICLE 2: “Telehealth Coding Guide”
There’s nothing more frustrating than rendering a service and not being paid. Nuanced coding rules are difficult to understand, and physicians aren’t taught this information in medical school.
Still, health care is a business. As business owners, physicians need to know how they’re paid, including what codes to use, what modifiers to append, and what details to document. Brushing up on common coding mistakes helps avoid costly recoupments and denials. We’ve asked several coding experts to provide their best advice on how physicians can maintain compliance and collect all of the revenue to which they’re entitled.
In part 1 of our two-part coding guide, we focused on coding for Telehealth and other forms of remote patient care — important codes for physician practices’ short-term survival as the U.S. continues to grapple with the COVID-19 pandemic.
In times of social distancing, telephone services have become a practical way to improve patient access and prevent the spread of COVID-19. Telephone services are ideal for straightforward problems (e.g., simple rash, asymptomatic cough, medication refills) that require a minimum of five minutes of medical discussion, says Toni Elhoms, CCS, CPC, chief executive officer of Alpha Coding Experts, LLC, in Orlando, Florida. Consider the following codes that Medicare accepts during the current public health emergency (PHE). Commercial payers may accept these codes, as well. Note that once the PHE has concluded, Medicare may only accept G2012 (virtual check-in) for telephone services.
Elhoms provides these tips to ensure compliance:
Document verbal consent, including patient acknowledgment and acceptance of any copayments or coinsurance amounts due.
Only count time spent on the phone engaging in medical discussion with the patient or caregiver. Do not report these codes for conversations lasting less than five minutes.
Clearly document what was discussed, as well as the outcome of the conversation (e.g., medications prescribed, referrals to specialists, additional steps for the patient to take).
Don’t report these codes when the telephone service ends with a decision to see the patient in 24 hours or the next available appointment.
Don’t report these codes when the telephone service relates to a related E/M service performed within the previous seven days or within the postoperative period of a previously completed procedure.
Only provide 99441-99443 and 98966-98968 for established patients. During the PHE, Medicare permits providers to bill G2012 for new and established patients.
‘The best way to operationalize these codes is to set up an edit in the practice management system that pends claims for a manual review to determine whether and which services are ultimately billable, Elhoms says.
Telehealth services In the last few months, providers have adopted Telehealth to improve patient access and generate revenue during COVID-19. Among the services physicians can render via Telehealth to patients with Medicare during the current PHE are Medicare annual wellness visits, new and established patient office visits, prolonged services, smoking, and tobacco cessation counseling, annual depression and alcohol screenings, advanced care planning, and more. Medicare covers more than 200 services via Telehealth, many of which were added for temporary coverage during the current PHE. Commercial payer coverage of these services may vary, and it’s best to check with individual payers, Elhoms says.
Elhoms provides these tips for billing Telehealth services:
Pay attention to audio-only vs. audio-visual requirements. Medicare requires the use of audio-visual technology for certain Telehealth services and permits audio-only for others. Commercial payers also may have specific requirements. For example, physicians can render a Telehealth visit for advanced care planning using audio-only, but they must use audio-visual technology for a new patient telehealth office visit.
Don’t render Medicare’s Initial Preventive Physical Exam via Telehealth. Medicare does not permit it.
Document verbal consent for Telehealth, including patient acceptance of any copayments or coinsurance amounts due.
Use place of service (POS) code 11 and modifier -95 when billing Medicare. Note that commercial payers may require a different POS code (e.g., POS 2 or POS “other”) and modifier.
Document, document, document. Physicians need to prove they met all of the code requirements even when rendering the service via Telehealth, Elhoms says. “Don’t pull in a problem list if you didn’t treat or manage all of those problems,” she adds. “Physicians need to link the diagnosis with the assessment and treatment plan. That’s imperative.” One caveat is that during the current PHE, physicians can bill 99201-99215 rendered via Telehealth based on time or medical decision-making. “The total time in direct medical discussion with the patient is going to be critical,” Elhoms says.
“The best advice I can give anyone doing Telehealth right now is to watch the CMS [Centers for Medicare & Medicaid Services] and commercial payer websites pretty much on a daily basis,” says Rhonda Buckholtz, CPC, CPMA, owner of Coding and Reimbursement Experts in Pittsburgh, Pennsylvania. “The coding of services changes constantly, and practices really need to be careful.”
Online digital E/M services
Though online digital E/M services are relatively new, they also can help practices increase patient access during COVID-19. Here’s how it works: An established patient initiates a conversation through a HIPAA-compliant secure platform (e.g., electronic health record portals, secure email, secure texting). A physician or other qualified health care professional reviews the query, as well as any pertinent data and records. Then they develop a management plan and subsequently communicate that plan to the patient or their caregiver through online, telephone, email or other digitally supported communication.
Elhoms provides these tips to maintain compliance:
Use these codes when physicians or other qualified health care professionals make a clinical decision that would otherwise occur during an office visit. Do not use them for scheduling appointments or nonevaluative communication of test results.
Use these codes only for established patients.
Do not use these codes for fewer than five minutes of E/M services.
Document verbal consent, including patient acknowledgment and acceptance of any copayments or coinsurance amounts due.
Do not report these codes when the online digital E/M service ends with a decision to see the patient in 24 hours or the next available urgent visit appointment.
Do not report these codes when the online digital E/M service relates to a related E/M service performed within the previous seven days or within the postoperative period of a previously completed procedure.
Promoting these services is often the biggest barrier, says Elhoms, who suggests putting up signs letting patients know they can access their provider electronically for non-urgent medical issues.
Remote patient monitoring Remote patient monitoring (RPM) is a relatively easy way for physicians to keep tabs on patients without requiring them to come into the office. Medicare covers RPM for patients with one or more acute or chronic conditions, and commercial payer coverage may vary. During the PHE, physicians can initiate RPM on new and established patients. Normally, Medicare permits it only for established patients.
RPM consists of two forms: monitoring data through either a non-manual or manual data transfer, says Jim Collins, CPC, CCC, a consultant at CardiologyCoder.com, Inc. in Saratoga Springs, New York.
For example, physicians can remotely monitor a patient’s pulse oximetry, weight, blood pressure or respiratory flow rate using a device that transmits daily recordings or programmed alerts. Physicians can purchase them directly from manufacturers or patients can purchase the devices themselves. Collins says patients should look for Bluetooth-enabled devices or ones that include a built-in Global System for Mobile Communications (GSM) transmitter. The former requires an Internet connection, and the latter automatically transmits data to an internet cloud service through an encrypted bandwidth. Physicians can bill for the initial setup, cost of the device itself (when applicable), and data monitoring.
Another example is the self-measured blood pressure monitoring. When patients supply their own blood pressure device that a physician calibrates, physicians may be able to bill for patient education, device calibration, reviewing the data that the patient provides and communicating a treatment plan to the patient or caregiver.
“Monitoring physiologic data on a regular basis substantially reduces hospitalizations, trips to the emergency room and exacerbations of chronic conditions,” says Collins. “It can also be a huge chunk of revenue.”
Collins provides these tips for compliant RPM billing:
Document patient consent. Patients must opt-in for these services.
Document total time spent rendering these services to support time-based requirements.
Know when these codes are appropriate. It’s unclear whether Medicare will pay physicians for monitoring physiologic data derived from internal devices (devices placed within the patient’s body) or data derived from wearable fitness devices.
Only bill 99457 when the provider renders at least 20 minutes of live, interactive communication with the patient or caregiver. “It’s not going to be medically necessary to spend 20 minutes every month on every patient,” Collins says. “Patients could go for several months without physicians needing to do anything for them.”
So, it looks that there will be a lot new for E/M coding (Evaluation and Management) in 2021, and practices should start to get ready for it.
Well, it seems the only constant in the world of medical billing changes, and 2020 would only compliment that cliché. While the chaos of COVID-19 forced many unexpected changes—how you see your patients and bill for services—a bigger change is in the works for 2021. This change will complement the “Patients Over Paperwork” initiative from CMS and the AMA, which has been developed to eliminate “Note Bloat.” So, since the new year will roll out changes to E/M visits, now is the time to make sure that all parties are prepared for this long overdue and welcome change to medical billing.
Evaluation and management services have been long overdue for an overhaul. The 1995/1997 guidelines were in place well before electronic medical records, and with the growth of EMR’s, the process to document for a specific level required a lot of tedious, unnecessary documentation. (A cursory look at some of the proposed updates for E/M CPT coding and documentation requirements will verify that!)
PROPOSED CHANGES: • History and Examination: While the elements of history and examination that are pertinent to a specific visit shall be recorded, they will no longer be used to ‘score’ the level billed • Code Selection: It will be based on MDM or time • Medical Decision Making: It will still utilize the CMS Table of Risk. However, the wording and explanations are being updated to provide more concise language. For instance, definitions will now be included to clearly identify subjective wording like “self-limited and stable chronic illness.” The clinical example will likely be removed, and the terms are more clearly defined. We will see this same type of clarification in the MDM table. For example, the 2021 guidelines will specify that the amount and/or complexity of data to be reviewed must also include analysis. • Time-based Code Selection: It will also be easier. The guidelines will give specific amounts of time rather than the generic estimate that we currently see attached to E/M codes. Another major advantage to the codes selected based on time, they will now include non-face-to-face services. There will also be additional add on codes—in 15-minute increments—if the time has been exceeded for the 99205 or 99215.
While changes are daunting, this change will be rewarding from a documentation standpoint. So, if you need help with training your team on these new updates, there are FREE videos available on the AMA website, or you can enlist the help of an independent consultant like RCM Insight.
One way of keeping up with these changes is to use EZClaim’s medical billing software, which is continually updated. For more details, visit their website, ezclaim.com, contact them, or just give them a call at 877.650.0904.
One of our partners, Alpha II, is presenting a special webinar on COVID-19 billing changes on April 16, 2020, “COVID-19: Critical Coding and Regulatory Updates,” to provide the most up-to-date information on the coming changes to new procedures, diagnosis codes, telehealth updates, and changes to regulatory policies.
As guidelines for coding and billing of COVID-19 services are revised almost daily, rest assured Alpha II is working to implement these critical changes to regulations and coding guidance as quickly as possible by conducting near-daily promotions.
Here is a very brief summary of some of the updates we’ve implemented:
Clarification of correct telehealth rendering POS and use of modifier -95
Modification of diagnosis code edits for billing of COVID-19 symptoms from February 20 – March 31, 2020, and use of new diagnosis U07.1 for dates of service on or after April 1, 2020
Addition of the new AMA CPT code 87635 effective March 13, 2020
Addition of the new CMS CPT codes U0001 and U0002 retroactively effective February 4, 2020
Modification for waiver of DME replacement requirements prior to March 1, 2020
Modification for waiver of occurrence code 70 on SNF three-consecutive day stay validation prior to March 1, 2020
Modification to LCD/NCD edits to relax rules related to respiratory-related devices and services
Modification to Medicaid for the temporary suspension to prior authorization rules in PHE areas effective March 1, 2020
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