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 is change, 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 a look at some of the proposed updates for E/M CPT coding and documentation requirements will verify that!)
• 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 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, it 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.
[ Written by Stephanie Cremeans of EZClaim ]
Compliance Plan Breakout
AMBA 2019 National Conference Session Recap
Compliance Plan Breakout – Written by Stephanie Cremeans of EZClaim
Any provider that is treating Medicare or Medicaid patients is required to have a compliance plan for their practice. This is mandated under the Patient Protection and Affordable Care Act of 2010.
The Office of Inspector General (OIG) has established an outline of seven components to help the small or individual provider offices get started. They also understand that small practices don’t typically have extensive resources creating and establishing a plan, and encourage practices to start with one item, making the compliance plan a working document that is updated and added to as necessary. The seven components are as follows:
- Conduct internal monitoring and auditing
- Implement compliance and practice standards
- Designate a compliance officer or contact
- Conduct appropriate training and education
- Respond appropriately to detected offenses and develop corrective action
- Develop open lines of communication with employees
- Enforce disciplinary standards through well-publicized guidelines
Let’s dig in a bit to the first component, conducting internal monitoring and auditing. Starting with this step will help a practice lay the groundwork of its compliance plan and shed light on areas that need additional work. There is no set number of records that are required to be audited, rather a suggestion of 5 (or more) per provider annually for a small or solo practice. You can start your compliance plan by simply documenting that no less than 5 charts per provider will be audited annually. Keep track of the results and use them to start implementing other components. For instance, you have the audit results, but what is considered passing? What are you going to do if a provider isn’t compliant? Document the answers and you are building your plan. Did the audit show specific areas for improvement? Find applicable training or host training for those that need it, document it in your plan. Did you find overpayments? Document how these are to be handled, resolve it quickly and put policies in place to prevent a bigger problem.
By taking steps to create a compliance plan and show a good-faith effort to improve on risk areas your practice will reap the benefits of clean claims with a reduction in denials, fewer billing errors and the assurance that your records are ready for an audit. This will also reduce your risk exposure to fines.
For help getting started with that first audit, setting benchmarks and improvement plans or for education on problem areas contact RCM Insight. For additional assistance with building your HIPAA compliance plans contact Live Compliance.
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