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2016 CPT Code Changes

New Year CPT Codes for 2016

The 300 new, deleted, revised, and converted CPT codes for 2016 are here and you will need to make sure they are loaded in your billing and EMR system(s) on or before January 1, 2016. This is also a great time to upload the 2016 Medicare allowables for your locality and for any payer contracts that apply a multiplier to the current Medicare fee schedule for their own allowables (for instance, XYZ payer pays 125% of 2016 Medicare).

Only a few areas do not have any changes this year – there are no deleted or changed modifiers and there are no changes to the anesthesia chapter of CPT. As for everything else, grab your 2016 CPT code book or digital version and follow along. Note that this is not an all-inclusive list; review your CPT book for complete description of all codes.

Don’t forget to scroll down to the bottom of this post to see the new category three (temporary) codes that may apply to your specialty.

 

Evaluation and Management Codes (E/M)

  • Add-on codes for Prolonged Services +99354 and +99355 now apply to prolonged face-to-face outpatient psychotherapy as well as to prolonged face-to-face E/M codes. Use a primary E/M or psychotherapy code, one 99354 (30-74 minutes in addition to the time spent on the initial/primary service) per day and as many units of 99355 as needed to match the time spent. NOTE: check the table in your CPT book to report the correct codes by time. OUTPATIENT ONLY.
  • Two new add-on Prolonged Services codes have been created. +99415 and +99416 are to be used to report prolonged face-to-face clinical staff service with physician, NP OR PA supervision. Same rules as above. Prolonged codes start at >45 minutes. NOTE: Document what you did and how long you did it. If you are reporting additional procedures, document the time and note that they are excluded from the prolonged service so no one thinks you’re double-dipping. OUTPATIENT ONLY.
  • Any code with a “+” prefix must be reported with a primary code. These add-on codes can never appear on a claim by itself.

Integumentary System

  • New: 10035, placement of soft tissue locations devices such as clips, markers, etc., first lesion
  • New add-on: +10036, placement of soft tissue locations devices such as clips, markers, etc., additional lesions (Not be used for breast, use existing breast codes (19081-19086), w/biopsy (19281-19288)

Musculoskeletal System

  • Deleted: 21805 – open treatment w/o fixation for rib fracture (Closed treatment or uncomplicated to use E/M code, Open treatment with fixation, use 21811- 21813)

Respiratory System

  • Revised: 31632 and 31633 bronchoscopy codes now include moderate sedation
  • Deleted: 31620
  • New: Bronchoscopy codes with EBUS 31652 (one or two node stations or structures), 31653, (three or more node stations or structures), +31654 (peripheral lesions – look in the CPT book for primary codes this add-on code can be used with)

Cardiovascular System

  • New: Category III code 0262T has been replaced with 33477, Transcatheter pulmonary valve implantation, includes procedure, angioplasty and imaging guidance, supervision and interpretation when performed
  • Revised: 37184, 37185, and 37186 were revised to include description “non-intracranial vessels”. Fluoroscopy is included.
  • New: 37211 is for intracranial vessels
  • Deleted: +37250 and +37251
  • Newadd-on: +37252 (intravascular ultrasound, initial noncoronary vessel) and +37253 (intravascular ultrasound, each additional noncoronary vessel. Look in the CPT book for primary codes this add-on code can be used with.)
  • Deleted: 39400
  • New: 39401 (Mediastinoscopy with biopsy of mediastinal mass, when performed) and 39402 (Mediastinoscopy with lymph node biopsy, when performed)

Digestive System

  • New: 43210 transoral approach using endoscope, not open, partial or complete

Biliary

  • Deleted: 47560 and 47561 (see 47579, 47531, or 47532 for percutaneous cholangiography)
  • Deleted: 47630 (see 47544)
  • Deleted: 47500, 47505, 47510, 47511, 47525, 47530, 74305, 74320, 74327
  • New: 47531 Injection procedure for cholangiography, includes RSI – radiologic supervision and interpretation, existing access and 47532 Injection procedure for cholangiography, includes RSI – radiologic supervision and interpretation, new access.
  • New: 47533 Placement of biliary drainage catheter, includes cholangiography, includes RSI – radiologic supervision and interpretation, external and 47534 Placement of biliary drainage catheter, includes RSI – radiologic supervision and interpretation, internal-external.
  • New: 47535 Conversion of external biliary drainage catheter to internal-external biliary drainage catheter, includes cholangiography, includes RSI – radiologic supervision and interpretation
  • New: 47536 Exchange of biliary drainage catheter, all types, includes cholangiography, includes RSI – radiologic supervision and interpretation
  • New: 47537 Removal of biliary drainage catheter, includes cholangiography, includes RSI – radiologic supervision and interpretation
  • New: 47538 Placement of stent into bile duct, includes cholangiography, includes balloon dilation and catheter exchange(s) and removal(s), includes RSI – radiologic supervision and interpretation, each stent, existing access
  • New: 47539 Placement of stent into bile duct, includes cholangiography, includes balloon dilation and catheter exchange(s) and removal(s), includes RSI – radiologic supervision and interpretation, each stent, new access, without placement of separate biliary drainage catheter (Handy table for reference in CPT book before this code!)
  • New: 47540 Placement of stent into bile duct, includes cholangiography, includes balloon dilation and catheter exchange(s) and removal(s), includes RSI – radiologic supervision and interpretation, each stent, new access, with placement of separate biliary drainage catheter
  • New: 47541 Rendezvous Procedure, new access, includes RSI – radiologic supervision and interpretation
  • New add-on: +47542 Balloon dilation of biliary duct, each duct (look for primary codes this can be used with and use modifier -59 if a second unit/duct is treated)
  • New add-on:+47543 Endoluminal biopsy of biliary tree, single or multiple, includes RSI – radiologic supervision and interpretation , report this code once per session
  • New add-on:+47544 Removal of calculi or debris from biliary ducts or gallbladder, includes RSI – radiologic supervision and interpretation (look for primary codes this can be used with)

Digestive System: Sclerotherapy

  • New: 49815 – one unit per lesion treated, report subsequent lesion(s) with modifier -59

Urinary System: Kidney

  • Revised: 50387 deleted transnephric ureteral stent and added “nephroureteral catheter”, see 50688 for removal and replacement of externally accessible ureteral stent (removal of stent without a replacement falls under E/M)

Kidney: New Heading Called Injection, Change or Removal

  • Deleted: 50392, 50393, 50394, 50398
  • New: 50430 (new access) and 50431 (existing access) both include RSI – radiologic supervision and interpretation
  • New: 50432 and 50433 (new access) both include RSI – radiologic supervision and interpretation, report one unit of 50432 for each renal collecting system or ureter accessed
  • New: 50434 (pre-existing nephrostomy tract) and 50435 (exchange catheter), both include RSI – radiologic supervision and interpretation, report one unit of 50435 for each renal collecting system or ureter accessed
  • New add-on: +50606 non-endoscopic endoluminal biopsy, once per ureter per day, includes RSI – radiologic supervision and interpretation (look in the CPT book for primary codes this add-on code can be used with)
  • New: 50693 (placement of ureteral stent, existing access) 50694 (new access  separate nephrostomy catheter) and 50695 (new access with separate nephrostomy catheter), all include RSI – radiologic supervision and interpretation
  • New add-on: +50705 (ureteral embolization or occlusion) includes RSI – radiologic supervision and interpretation, once per ureter treated per day (look in the CPT book for primary codes this add-on code can be used with)
  • New add-on: +50706 (balloon dilation) includes RSI – radiologic supervision and interpretation (look in the CPT book for primary codes this add-on code can be used with)

Male Genital

  • New: 54437 Penis Repair (repair of urethra may be reported separately)
  • New: 54438 Penis Replantation, complete amputation (for partially amputated see 54437,  for urethra repair see 54310 and 54315)

Nervous System

  • New: 61645 Mechanical thrombectomy, intracranial
  • New: 61650 Endovascular intracranial prolonged administration of pharmacologic agents not for thrombolysis, arterial, initial vascular territory
  • New add-on: +61651 Endovascular intracranial prolonged administration of pharmacologic agents, arterial, not for thrombolysis, each additional vascular territory
  • Deleted: 64412, use 64999
  • New: 64461 Paravertebral Block (PVB), thoracic, single injection, includes imaging guidance when performed
  • New add-on: +64462 Second and any additional injection sites, can only be reported once per day, includes imaging guidance when performed
  • New: 64463 Continuous infusion by catheter, includes imaging guidance when performed

Eye

  • New: 65785 Implantation of intrastomal corneal ring segments, revised to state “one session” (Category III code 0099T was replaced by this code)
  • Revision: 67101 Trabeculoplasty by laser surgery, revised to state “including drainage when performed” and revised to replace “with or without” with “including when performed”
  • Revision: 67105 Trabeculoplasty, photocoagulation, repair of retinal detachment, revised to state “including drainage when performed” and revised to replace “with or without” with “including when performed”
  • Deleted: 67112 Retinal detachment, use 67107, 67108, 67110 or 67113 as appropriate
  • Revised: 67107 Repair of retinal detachment, scleral buckling, revised to replace “with or without” with “including when performed”
  • Revised: 67108 Repair of retinal detachment with vitrectomy, revised to replace “with or without” with “including when performed”
  • Revised: 67113 Repair of complex retinal detachment, revised to replace “with or without” with “including when performed”
  • Revision: 67227 Destruction of extensive or progressive retinopathy, revised to remove “one or more sessions”
  • Revision: 67228 Treatment of extensive or progressive retinopathy, photocoagulation, revised to remove “one or more sessions”

Auditory System

  • New: 69209 Removal of impacted cerumen using irrigation/lavage, unilateral
  • New: 69210 Removal of impacted cerumen requiring instrumentation, unilateral, NOTE: For removal of non-impacted cerumen, use E/M code, append modifier -50 for bilateral (both ears), do not report 69209 and 69210 for the same ear!

Diagnostic Radiology

  • Deleted: 70373 (see unlisted code 76499 for contrast laryngography)
  • Revised: 72080 Spine, thoracolumbar junction, minimum of two views
  • Deleted: 72069 and 72090
  • New: Scoliosis Evaluation Codes 72081 (one view), 72082 (two or three views), 72083 (four or five views) and 72084 (minimum six views)
  • Deleted: 73500, 73510, 73520, 73530 and 73540
  • New: Hip With Pelvis (when performed) Unilateral 73501 (one view), 73502 (two or three views), 73503 (minimum four views)
  • New: Hip With Pelvis (when performed) Bilateral 73521 (two views), 73522 (three or four views), 73523 (minimum five views)
  • Deleted: 73550
  • New: 73551 Femur (one view) and 73552 (two or more views)
  • The word “film” has been replaced by “image” in 74240, 74241, 74245, 74246, 74247, 74250 and 74340
  • New: MRI of Fetus 74712 (single gestation) and +74713 (each additional gestation) only if fetus is imaged

Radiology: Brachytherapy

  • New: 77767 and 77768 (multiple lesions or channels)
  • Deleted: 77785 and 77786
  • New: 77770 (one channel), 77771 (two to twelve channels), 77772 (more than twelve channels)
  • Deleted: 77776 and 77777 (see 77799 for intermediate service)
  • Revised: 77778  to include “supervision, loading and handling of the radiation source”

Radiology: Nuclear Medicine

  • Revised: 78624 to include “imaging study” and “(solid food, liquid food or both)”
  • New: 78265 (small bowel transit) and 78266 (small bowel and colon transit)

Pathology and Laboratory

  • New: 80081 addition of HIV testing the standard OB panel (must have all elements of the panel performed to use 80085 or 80081, otherwise must code each test separately
  • NOTE: Refer to the CPT book for many additional changes

Medicine: Vaccines

  • Deleted: 13 outdated codes deleted
  • Revised: 40+ codes reworded to improve clarity
  • New: 90625 Cholera Vaccine
  • New: 90697 DTap-IPV-Hib-HepB
  • New: 90620 Meningococcal, 2 dose schedule
  • New: 90621 Meningococcal, 3 dose schedule

Otolaryngology

  • Deleted: 92543
  • New: 92537 (bilateral, bithermal, 4 irrigations) and 92538 (bilateral, monothermal, two irrigations)

Cardiovascular and Pulmonary

  • New: 93050 Arterial pressure waveform analysis (Category III code 0311T deleted)
  • Revised: 94640 “for therapeutic purposes” and includes “sputum induction”

Neurology and Neuromuscular

  • Deleted: 95973
  • Revised: 95972 revised to remove the time element

Dermatology

  • New primary and add-on codes: RCM Codes 96931 (image acquisition, interpretation and report, first lesion), 96932 (image acquisition only, first lesion), and 96933 (interpretation and report only, first lesion), +96934 (image acquisition, interpretation and report, each additional lesion), +96935 (image acquisition only, each additional lesion), and +96936 (interpretation and report only, each additional lesion) NOTE: Technical is image acquisition, Professional is interpretation and report. Both components are included in 96931 and 96934.

Medicine: Other

  • Revised: Ocular Screening 99174 to include “remote analysis and report”
  • New: Ocular Screening 99177 onsite analysis

Category III Codes

  • Sunset Codes: 0103T, 1223T, 0123T, 0223T, 0224T, 0225T, 0233T, 0240T, 0241T, 0243T, 0244T (codes not replaced by a Category I code)
  • Replaced Codes: 0099T see 65785, 0182T see 0394T and 0395T, 0262T see 33477, 0311T see 93050
  • New: 0381T (Epilepsy seizure recording up to 14 days with review and report), 0382T (14-day with review and report only), 0383T (Epilepsy seizure recording for 15 to 30 days with review and report), 0384T (15 to 30 days with review and report only), 0385T (Epilepsy seizure recording for more than 30 days with review and report), and 0386T (>30 days with review and report only)
  • New: Permanent Leadless Pacemaker 0387T (insertion/replacement), 0388T (removal), 0389T (programming), 0390T (evaluation) and 0391T (interrogation)
  • New: Esophageal Sphincter Augmentation Device 0392T (placement), and 0393T (removal)
  • New: Electronic Brachytherapy 0394T (skin surface) and 0395T (interstitial or intracavitary)
  • New add-on: +0396T Implant stability testing during knee replacement
  • New add-on: +0397T Optical endomicroscopy during ERCP
  • New: 0398T MRI-guided ultrasound for intracranial lesion ablation
  • New: +0399T Myocardial strain imaging
  • New: 0400T (Digital skin lesion analysis, one to five lesions) and 0401T (digital skin lesion analysis, six or more lesions)
  • New: 0402T Collagen cross-linking of cornea
  • New: 0403T Behavior change in high-risk patients for diabetes prevention, group setting, 60 minutes per day
  • New: 0404T Uterine fibroid ablation with ultrasound guidance, radiofrequency,reported once regardless of number of fibroids treated
  • New: 0405T Thirty minutes or more per month non-face-to-face liver assist care oversight
  • New: 0406T Nasal endoscopy, placement of drug-eluding implant and 0407T endoscopy with biopsy, polypectomy or debridement

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Posted in: Collections, Billing & Coding, Compliance

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2016 Medicare Deductibles and Premiums

Medicare Part B Deductible Increases

Yesterday the Centers for Medicare & Medicaid Services (CMS) announced the 2016 premiums and deductibles for the Medicare inpatient hospital (Part A) and physician and outpatient hospital services (Part B) programs.

Part B Premiums/Deductibles

As the Social Security Administration previously announced, there will be no Social Security cost of living increase for 2016. As a result, by law, most people with Medicare Part B will be “held harmless” from any increase in premiums in 2016 and will pay the same monthly premium as last year, which is $104.90.

Beneficiaries not subject to the “hold harmless” provision will pay $121.80, as calculated reflecting the provisions of the Bipartisan Budget Act signed into law by President Obama last week. Medicare Part B beneficiaries not subject to the “hold-harmless” provision are those not collecting Social Security benefits, those who will enroll in Part B for the first time in 2016, dual eligible beneficiaries who have their premiums paid by Medicaid, and beneficiaries who pay an additional income-related premium. These groups account for about 30 percent of the 52 million Americans expected to be enrolled in Medicare Part B in 2016.

“Our goal is to keep Medicare Part B premiums affordable. Thanks to the leadership of Congress and President Obama, the premiums for 52 million Americans enrolled in Medicare Part B will be either flat or substantially less than they otherwise would have been,” said CMS Acting Administrator Andy Slavitt. “Affordability for Medicare enrollees is a key goal of our work building a health care system that delivers better care and spends health care dollars more wisely.”

Because of slow growth in medical costs and inflation, Medicare Part B premiums were unchanged for the 2013, 2014, and 2015 calendar years. The “hold harmless” provision would have required the approximately 30 percent of beneficiaries not held harmless in 2016 to pay an estimated base monthly Part B premium of $159.30 in part to make up for lost contingency reserves, according to the 2015 Trustees Report. However, the Bipartisan Budget Act of 2015 mitigated the Part B premium increase for these beneficiaries and states, which have programs that pay some or all of the premiums and cost-sharing for certain people who have Medicare and limited incomes. The CMS Office of the Actuary estimates that states will save $1.8 billion as a result of this premium mitigation.

CMS also announced that the annual deductible for all Part B beneficiaries will be $166.00 in 2016.

Premiums for Medicare Advantage and Medicare Prescription Drug plans already finalized are unaffected by this announcement.

To get more information about state-by-state savings, visit the CMS website here.

Since 2007, beneficiaries with higher incomes have paid higher Part B monthly premiums. These income-related monthly adjustment amount (IRMAA) affect fewer than 5 percent of people with Medicare. Under the Part B section of the Bipartisan Budget Act of 2015, high income beneficiaries will pay an additional amount. The IRMAA, additional amounts, and total Part B premiums for high income beneficiaries for 2016 are shown in the following table:

Medicare Premiums Vary Based on Income and Type of Tax Return

Premiums for beneficiaries who are married and lived with their spouse at any time during the taxable year, but file a separate return, are as follows:
2016 Medicare Monthly Premiums

Part A Premiums/Deductibles 

Medicare Part A covers inpatient hospital, skilled nursing facility, and some home health care services. About 99 percent of Medicare beneficiaries do not pay a Part A premium since they have at least 40 quarters of Medicare-covered employment.

The Medicare Part A annual deductible that beneficiaries pay when admitted to the hospital will be $1,288.00 in 2016, a small increase from $1,260.00 in 2015. The Part A deductible covers beneficiaries’ share of costs for the first 60 days of Medicare-covered inpatient hospital care in a benefit period. The daily coinsurance amounts will be $322 for the 61stthrough 90th day of hospitalization in a benefit period and $644 for lifetime reserve days. For beneficiaries in skilled nursing facilities, the daily coinsurance for days 21 through 100 in a benefit period will be $161.00 in 2016 ($157.50 in 2015).

Enrollees age 65 and over who have fewer than 40 quarters of coverage and certain persons with disabilities pay a monthly premium in order to receive coverage under Part A. Individuals with 30-39 quarters of coverage may buy into Part A at a reduced monthly premium rate, which will be $226.00 in 2016, a $2.00 increase from 2015. Those with less than 30 quarters of coverage pay the full premium, which will be $411.00 a month, a $4.00 increase from 2015.

Part A Deductibles and Coinsurance for 2016

Slight Increases for Medicare 2016 Part A

For more information on the 2016 Medicare Parts A and B premiums and deductibles (CMS-8059-N, CMS-8060-N, and CMS-8061-N), click here.

Posted in: Collections, Billing & Coding, Finance, Medicare & Reimbursement, Medicare This Week

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Is This Physician Crazy? She Walked Away From a “Big Five” Payer Contract!

Feel All Alone Contracting With Payers?I recently helped a physician start a new practice and we began applying for enrollment with the Big Five insurance companies. The physician was stunned to find:

  • Insurance companies regularly “lost” her applications and we had to submit the same information numerous times. Some companies require an online application which provides no ability to track. They will not accept paper applications which can be tracked by the delivery service.
  • She was offered contracts with no fee schedule attached. When we asked for the fee schedule, we were told it was available in the physician portal. When we went to the physician portal, we were told that only enrolled physicians have access to the portal.
  • Contracts she received made reference to the physician adhering to the rules of the Provider Manual. When we asked for a copy of the Provider Manual, we were told it was available in the physician portal. You guessed it – only enrolled physicians have access to the portal.
  • Some insurance companies routinely took 90-120 days or more to complete the application process, then another 60-90 days to enter the contract into the system so physician claims would be paid. This means that a physician may not be able to get paid by one or more payers for 6-7 months after opening a practice.

The physician ultimately decided to walk away from the most egregious of the payers.

After having numerous potential new patients call the practice to find out if she was contracted with this payer, she had to tell them that she would not be contracting with this payer.

Here’s the letter she wrote to the Insurance Company Representative:

Good Afternoon:

Thank you for your follow-up note.  I am uncertain why, but the information you provided, once again, is in direct conflict with the data provided by our local physician’s organization as well as the objective data of looking at pricing vs reimbursement for the ___ vaccination.

I have included for your review comments made by an 18-year veteran of contract negotiations, Ron Howrigon.  It appears being evasive and obtuse in how you negotiate with physicians is an intentional cultural value.

The tenets of our practice require honesty, good-faith and integrity from all of our partners in healthcare.  This article and our experience with you suggests a different and unacceptable organizational value displayed by your company.

At this time, given the disorganized credentialing process, the poor interactions with your company and the vexatious conversation with you, we will not be partnering with you.  We have notified all of our patients insured by your company that we will not be accepting your plans in our practice.  This is a values and ethics-based decision.  We regret you and your company have chosen to conduct yourselves with such hostility and disregard for physicians and the important work we do on behalf of our patients.

Sincerely,

Physician in a New Practice

Posted in: Collections, Billing & Coding, Starting a New Practice

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Why You Should Not Reward Your Billing Staff for Collections

I Don't Recommend You Incentivize Billing Staff for Collections!

Do not incentivize and reward your billing staff for reduced days in accounts receivable, increased collections or decreased non-contractual (bad debt) write-offs!

I bet you thought I was going to say that billers are paid to do a job and they should not be incentivized for doing the job you hired them to do.

Not true – I am not against incentivizing employees to do a job at all; most people enjoy a challenge and feel great when they reach a goal.

However, when a subset of employees in your practice is incentivized for increasing revenue, you can be sure it will create resentment and low morale for the rest of your employees. Do you think word won’t get around that you’re rewarding the billers? If so, you’re completely wrong. There are no secrets in a medical office. People know what others make, and regardless of what your Employee Handbook might say, it is not grounds for termination for employees to share what they make with others.

What I do encourage you to do is to incentivize your ENTIRE staff to reduce days in accounts receivable, increased collections and decrease non-contractual (bad debt) write-offs. Ultimately, your entire staff is responsible in one way or another for collections.

Consider how each person in your practice must contribute to the overall effort to make sure collections are at goal:

Front Desk: entering/verifying demographics and picking the right insurance plan for each patient; collecting the correct amount at time of service, whether it is an exact amount or an estimate of the patient’s responsibility.

Phones/Scheduling: making new patients aware of financial policies and what will be expected at time of service (“Please remember to bring the credit card you’d like us to keep on file for you”); making sure that Medicare patients know the difference between an Annual Wellness Visit and a Complete Physical.*

All clinical staff including Physicians/PAs/NPs: making sure that the patient signs an Advance Beneficiary Notice (ABN) for any services that insurance will not pay for, regardless of whether the patient is Medicare or non-Medicare**, before the service is rendered.

Manager: addressing patient complaints that escalate to you quickly and efficiently, not giving a patient any reason not to pay; making sure you have an easy-to-read-and-understand Financial Policy*** explaining your collection at time of service policy.

Everyone: embracing a culture of Customer Service, making sure that patients are satisfied with their experience; sending a consistent message to patients that you are interested in bringing them value for their dollars and reinforcing your desire to have an ongoing relationship with them.

Complete the Contact Form here to request any of the free resources discussed in this post and listed below.

  • *Cheat Sheet for Medicare visits
  • **Non-Medicare Advance Beneficiary Notice (ABN)
  • ***Financial Policy

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Posted in: Amazing Customer Service, Collections, Billing & Coding, Day-to-Day Operations, Finance, Human Resources

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Who’s Listening to Our EHR Issues?

Who You Gonna Call When Your EHR Sucks...the Life Out of You?

 

 

 

 

 

We hear more and more every day about EHR problems and physician dissatisfaction with performance and usability, and the way the federal government makes them use it. So, who should physicians complain to?

Of course you should complain to the vendor about usability, and complain in groups when possible. I’ve started several user groups in the past and have had success in communicating with vendors to improve their products. The key is keeping the User Group independent from the vendor, which takes committed volunteers.

In addition, you may want to complain to the Office of the National Coordinator (ONC) and hope that other physicians will do the same and there will be traction gained by many voices. The ONC has just launched an online complaint form for this purpose, but note, Coordinator Karen B. DeSalvo, MD only wants to hear about problems with certified EHRs.

Don’t know if your EHR is certified? Check here.

The American Medical Association (AMA) is also working on behalf of physicians with a campaign called “Break The Red Tape” which calls upon physicians to write about (or video) their EHR story. Even if you don’t plan to share your EHR story, be sure to click on the link and hear from real people.

Physicians (and their staffs) are overwhelmed with all the mandates. As a consultant, I no longer work with Meaningful Use, PQRS/VBM or PCMH. I refer practices to other consultants for these needs because I would rather work on what I think is meaningful in medical practice today – practice business models and strategies that bring more satisfaction to the physician and the patient.

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Posted in: Electronic Medical Records, Headlines, Learn This: Technology Answers

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CMS and AMA Make ICD-10 “Family” Clarification

Medicare will reimburse claims with ICD-10 codes as long as they are in the correct code "family" for 12 months.

Clarifying Questions and Answers Related to the July 6, 2015 CMS/AMA Joint Announcement and Guidance Regarding ICD-10 Flexibilities

Question 1:

When will the ICD-10 Ombudsman be in place?

Answer 1:

The Ombudsman will be in place by October 1, 2015.

Question 2:

Does the Guidance mean there is a delay in ICD-10 implementation?

Answer 2:

No. The CMS/AMA Guidance does not mean there is a delay in the implementation of the ICD-10 code set requirement for Medicare or any other organization. Medicare claims with a date of service on or after October 1, 2015, will be rejected if they do not contain a valid ICD-10 code. The Medicare claims processing systems do not have the capability to accept ICD-9 codes for dates of service after September 30, 2015 or accept claims that contain both ICD-9 and ICD-10 codes for any dates of service. Submitters should follow existing procedures for correcting and resubmitting rejected claims.

Question 3:

What is a valid ICD-10 code?

Answer 3:

ICD-10-CM is composed of codes with 3, 4, 5, 6 or 7 characters. Codes with three characters are included in ICD-10-CM as the heading of a category of codes that may be further subdivided by the use of fourth, fifth, sixth or seventh characters to provide greater specificity. A three-character code is to be used only if it is not further subdivided. To be valid, a code must be coded to the full number of characters required for that code, including the 7th character, if applicable. Many people use the term billable codes to mean valid codes. For example, E10 (Type 1 diabetes mellitus), is a category title that includes a number of specific ICD-10-CM codes for type 1 diabetes. Examples of valid codes within category E10 include E10.21 (Type 1 diabetes mellitus with diabetic nephropathy) which contains five characters and code E10.9 (Type 1 diabetes mellitus without complications) which contains four characters.

A complete list of the 2016 ICD-10-CM valid codes and code titles is posted on the CMS website at http://www.cms.gov/Medicare/Coding/ICD10/2016-ICD-10-CM-and-GEMs.html. The codes are listed in tabular order (the order found in the ICD-10-CM code book). This list should assist providers who are unsure as to whether additional characters are needed, such as the addition of a 7th character in order to arrive at a valid code.

Question 4: What should I do if my claim is rejected? Will I know whether it was rejected because it is not a valid code versus denied due to a lack of specificity required for a NCD or LCD or other claim edit?

Answer 4:

Yes, submitters will know that it was rejected because it was not a valid code versus a denial for lack of specificity required for a NCD or LCD or other claim edit. Submitters should follow existing procedures for correcting and resubmitting rejected claims and issues related to denied claims.

Question 5:

What is meant by a family of codes?

Answer 5:

“Family of codes” is the same as the ICD-10 three-character category. Codes within a category are clinically related and provide differences in capturing specific information on the type of condition. For instance, category H25 (Age-related cataract) contains a number of specific codes that capture information on the type of cataract as well as information on the eye involved. Examples include: H25.031 (Anterior subcapsular polar age-related cataract, right eye), which has six characters; H25.22 (Age-related cataract, morgagnian type, left eye), which has five characters; and H25.9 (Unspecified age-related cataract), which has four characters. One must report a valid code and not a category number. In many instances, the code will require more than 3 characters in order to be valid.

Question 6:

Does the recent Guidance mean that no claims will be denied if they are submitted with an ICD-10 code that is not at the maximum level of specificity?

Answer 6:

In certain circumstances, a claim may be denied because the ICD-10 code is not consistent with an applicable policy, such as Local Coverage Determinations or National Coverage Determinations. (See Question 7 for more information about this). This reflects the fact that current automated claims processing edits are not being modified as a result of the guidance.

In addition, the ICD-10 code on a claim must be a valid ICD-10 code. If the submitted code is not recognized as a valid code, the claim will be rejected. The physician can resubmit the claims with a valid code.

Question 7:

National Coverage Determinations (NCD) and Local Coverage Determinations (LCD) often indicate specific diagnosis codes are required. Does the recent Guidance mean the published NCDs and LCDs will be changed to include families of codes rather than specific codes?

Answer 7:

No. As stated in the CMS’ Guidance, for 12 months after ICD-10 implementation, Medicare review contractors will not deny physician or other practitioner claims billed under the Part B physician fee schedule through either automated medical review or complex medical record review based solely on the specificity of the ICD-10 diagnosis code as long as the physician/practitioner used a valid code from the right family of codes. The Medicare review contractors include the Medicare Administrative Contractors, the Recovery Auditors, the Zone Program Integrity Contractors, and the Supplemental Medical Review Contractor.

As such, the recent Guidance does not change the coding specificity required by the NCDs and LCDs. Coverage policies that currently require a specific diagnosis under ICD-9 will continue to require a specific diagnosis under ICD-10. It is important to note that these policies will require no greater specificity in ICD-10 than was required in ICD-9, with the exception of laterality, which does not exist in ICD-9. LCDs and NCDs that contain ICD-10 codes for right side, left side, or bilateral do not allow for unspecified side. The NCDs and LCDs are publicly available and can be found at http://www.cms.gov/medicare-coverage-database/.

Question 8:

Are technical component (TC) only and global claims included in this same CMS/AMA guidance because they are paid under the Part B physician fee schedule?

Answer 8:

Yes, all services paid under the Medicare Fee-for-Service Part B physician fee schedule are covered by the guidance.

Question 9:

Do the ICD-10 audit and quality program flexibilities extend to Medicare fee-for-service prior authorization requests?

Answer 9:

No, the audit and quality program flexibilities only pertain to post payment reviews. ICD-10 codes with the correct level of specificity will be required for prepayment reviews and prior authorization requests.

MEDICAID

Question 10:

If a Medicare paid claim is crossed over to Medicaid for a dual-eligible beneficiary, is Medicaid required to pay the claim?

Answer 10:

State Medicaid programs are required to process submitted claims that include ICD-10 codes for services furnished on or after October 1 in a timely manner. Claims processing verifies that the individual is eligible, the claimed service is covered, and that all administrative requirements for a Medicaid claim have been met. If these tests are met, payment can be made, taking into account the amount paid or payable by Medicare. Consistent with those processes, Medicaid can deny claims based on system edits that indicate that a diagnosis code is not valid.

Question 11:

Does this added ICD-10 flexibility regarding audits only apply to Medicare?

Answer 11:

The official Guidance only applies to Medicare fee-for-service claims from physician or other practitioner claims billed under the Medicare Fee-for-Service Part B physician fee schedule. This Guidance does not apply to claims submitted for beneficiaries with Medicaid coverage, either primary or secondary.

Question 12:

Will CMS permit state Medicaid agencies to issue interim payments to providers unable to submit a claim using valid, billable ICD-10 codes?

Answer 12:

Federal matching funding will not be available for provider payments that are not processed through a compliant MMIS and supported by valid, billable ICD-10 codes.

OTHER PAYERS

Question 13:

Will the commercial payers observe the one-year period of claims payment review leniency for ICD-10 codes that are from the appropriate family of codes?

Answer 13:

The official Guidance only applies to Medicare fee-for-service claims from physician or other practitioner claims billed under the Medicare Fee-for-Service Part B physician fee schedule. Each commercial payer will have to determine whether it will offer similar audit flexibilities.

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Posted in: Headlines, ICD-10, Medical Coding Education, Medicare & Reimbursement, Medicare This Week

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A Manage My Practice Classic: Five Simple but Powerful Performance Evaluation Questions

Performance Review

This continues to be one of our top ranking posts of all time.

This tells me that people continue to struggle with the process of evaluating employee performance.

The point of the “Five Questions” evaluation is not to focus on the fact that the employee is often tardy or doesn’t complete assignments on time – those things should be initially dealt with outside of this process (remember the old adage “No new news at the performance evaluation.”) They can be added to #3 as goals, but the idea is to to dig under those things and see if the employee is dissatisfied, overwhelmed or under-challenged.

I typically use this form at 90 days after hire, then at the one year mark, then every 6 months thereafter.

Yes, evaluating this much is very time-consuming – but it pays BIG dividends.

Invest in your employees by using this form and meeting for at least an hour – you might be surprised that it’s one of the most in-depth evaluations you’ll ever do!

This is a VERY succinct performance evaluation that I’ve used for years. Called “Five Questions”, the employee completes it, submits it to the manager, then together they discuss, evaluate and add to it during the evaluation interview. Here are the questions:

  1. What goals did you accomplish since your last evaluation (or hire)?
  2. What goals were you unable to accomplish and what hindered you from achieving them?
  3. What goals will you set for the next period?
  4. What resources do you need from the organization to achieve these goals?
  5. Based on YOUR personal satisfaction with your job (workload, environment, pay, challenge, etc.) how would you rate your satisfaction from 1 (poor) to 10 (excellent.) 1 2 3 4 5 6 7 8 9 10

You do have to stress that question #5 is not how well they think they’re doing their job, but how satisfied they are with the job.

The great thing about this evaluation is that it is one piece of paper and not too intimidating. Staff can use phrases or sentences and write as little or as much as they like. If it’s hard to get a conversation going with the employee, ask them “What was your thought process when you assigned your job satisfaction a number __.” Usually that opens the floodgates!

If you use a goal-oriented evaluation like this one, you will find that employees will grasp that you are asking for their performance to be beyond the day-to-day tasks, and to focus on learning new skills, teaching others, creative thinking and problem-solving and new solutions for efficiency and productivity.

Posted in: Human Resources, Leadership, Manage My Practice Classics

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July 15-16 CMS Webinars: New Payment Model for Joint Replacements

Surgeons Should Weigh In On Proposed CMS Joint Replacement Payment Model

UPDATED INFO: These recorded webinars are now available here.

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On July 9, 2015 the Centers for Medicare & Medicaid Services (CMS) announced the Comprehensive Care for Joint Replacement (CCJR) model, a proposed payment, quality, and care improvement initiative for hip and knee replacements.

The Center for Medicare & Medicaid Innovation (CMS Innovation Center) will host two offerings of a webinar to describe the proposed rule and respond to questions. The dates and registration links for these webinars are as follows:

Additional information on this Model can be accessed through the CCJR Model web page.

The proposed rule will undergo a 60-day comment period during which time CMS welcomes the input of stakeholders and the public. You can read the proposed rule in the Federal Register.

We encourage all interested parties to submit comments to the rule electronically through the CMS e-Regulation website at http://www.cms.gov/Regulations-and-Guidance/Regulations-and-Policies/eRulemaking/index.html?redirect=/eRulemaking or on paper by following the instructions included in the proposed rule. Submissions must be received by September 8, 2015.

*Large audiences are anticipated. Plan on joining a few minutes early.

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Posted in: Medicare & Reimbursement, Medicare This Week

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Before Starting a New Medical Practice Ask Yourself These 10 Questions

Starting a New Medical Practice: Who's the Boss?

 

 

 

 

 

 

 

 

  1. Can I go without any income from a new practice for 3-6 months?
  2. Do I have another income stream or can I continue to work part-time at the hospital or at an urgent care while I’m building my practice?
  3. Can I envision starting my practice by myself (no receptionist or medical assistant)?
  4. Do I have an existing patient base which will be interested in joining my practice?
  5. Is the community in which I want to work underserved or overserved in my specialty?
  6. Do I have a cash component to my practice that can help defray expenses while I’m building my practice?
  7. Will I be able to count on unpaid help from my spouse, family or friends to get things started?
  8. Will I be satisfied to start my practice by leasing space from another practice, or at a less-prestigious location that might not be my forever-location?
  9. Am I willing to shop for gently used and refurbished furniture and equipment for my medical practice?
  10. Will I be satisfied to use one of the free EHRs, even if it doesn’t have all the bells and whistles?
  11. Bonus Question: Do I have saved or can I borrow $20K to cover my expenses for the first 3-6 months?

Starting a new medical practice is not easy. No one should tell you that it is.

But, if you want to put in the work, make the decisions, and ultimately, practice the way you want to, then a solo practice may be a fit for you.

You may have to call your friends and family together to help you, you may have to work someplace else while you’re building your practice, but the good news is, you are the boss of you.

Posted in: Innovation, Quality, Starting a New Practice

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The CMS ICD-10 Announcement: What It Means to Your Practice

The Lion and the Lamb - CMS and the AMA Collaborate on ICD-10 Concessions

First, the game-changing announcement below means that a sigh of relief is in order. Some of the anxiety surrounding potential financial disaster should be abated. CMS announced:

“Medicare review contractors [MACs and RACs] will not deny physician or other practitioner claims billed under the Part B physician fee schedule through either automated medical review or complex medical record review based solely on the specificity of the ICD-10 diagnosis code as long as the physician/practitioner used a valid code from the right family.” (see FAQ2 below)

Second, we think it means that the sword rattling coming from the AMA and other individuals should subside. The fact that the CMS changes are based on recommendations from the AMA, which has been adamantly opposed to the ICD-10 mandate for years, is no less unexpected than the lion laying down with the lamb.

Regardless of the changes, the AMA’s previous assertion that ICD-10 “will create significant burdens on the practice of medicine with no direct benefit to individual patients’ care” still stands. The transition is inevitable, in my mind, but the changes will lessen the burden on physicians.

In the announcement from CMS, the clarification was made that

“In accordance with the coming transition, the Medicare claims processing systems will not have the capability to accept ICD-9 codes for dates of services after September 30, 2015, nor will they be able to accept claims for both ICD-9 and ICD-10 codes.”

Third, CMS will name a CMS ICD-10 Ombudsman to triage and answer questions about the submission of claims. The ICD-10 Ombudsman will be located at CMS’s ICD-10 Coordination Center.

Also, mark your calendars! CMS will have a provider call on August 27th to discuss these changes.

See the answers below provided by CMS in their new FAQs published this week.

Q1. What if I run into a problem with the transition to ICD-10 on or after October 1st 2015?

A1. CMS understands that moving to ICD-10 is bringing significant changes to the provider community. CMS will set up a communication and collaboration center for monitoring the implementation of ICD-10. This center will quickly identify and initiate resolution of issues that arise as a result of the transition to ICD-10. As part of the center, CMS will have an ICD-10 Ombudsman to help receive and triage physician and provider issues. The Ombudsman will work closely with representatives in CMS’s regional offices to address physicians’ concerns. As we get closer to the October 1, 2015, compliance date, CMS will issue guidance about how to submit issues to the Ombudsman.

Q2. What happens if I use the wrong ICD-10 code, will my claim be denied?

A1. While diagnosis coding to the correct level of specificity is the goal for all claims, for 12 months after ICD-10 implementation, Medicare review contractors will not deny physician or other practitioner claims billed under the Part B physician fee schedule through either automated medical review or complex medical record review based solely on the specificity of the ICD-10 diagnosis code as long as the physician/practitioner used a valid code from the right family. However, a valid ICD-10 code will be required on all claims starting on October 1, 2015. It is possible a claim could be chosen for review for reasons other than the specificity of the ICD-10 code and the claim would continue to be reviewed for these reasons. This policy will be adopted by the Medicare Administrative Contractors, the Recovery Audit Contractors, the Zone Program Integrity Contractors, and the Supplemental Medical Review Contractor.

Q3. What happens if I use the wrong ICD-10 code for quality reporting? Will Medicare deny an informal review request?

A3. For all quality reporting completed for program year 2015 Medicare clinical quality data review contractors will not subject physicians or other Eligible Professionals (EP) to the Physician Quality Reporting System (PQRS), Value Based Modifier (VBM), or Meaningful Use 2 (MU) penalty during primary source verification or auditing related to the additional specificity of the ICD-10 diagnosis code, as long as the physician/EP used a code from the correct family of codes. Furthermore, an EP will not be subjected to a penalty if CMS experiences difficulty calculating the quality scores for PQRS, VBM, or MU due to the transition to ICD-10 codes. CMS will not deny any informal review request based on 2015 quality measures if it is found that the EP submitted the requisite number/type of measures and appropriate domains on the specified number/percentage of patients, and the EP’s only error(s) is/are related to the specificity of the ICD-10 diagnosis code (as long as the physician/EP used a code from the correct family of codes). CMS will continue to monitor the implementation and adjust the timeframe if needed.

Q4. What is advanced payment and how can I access this if needed?

A4. When the Part B Medicare Contractors are unable to process claims within established time limits because of administrative problems, such as contractor system malfunction or implementation problems, an advance payment may be available. An advance payment is a conditional partial payment, which requires repayment, and may be issued when the conditions described in CMS regulations at 42 CFR Section 421.214 are met. To apply for an advance payment, the Medicare physician/supplier is required to submit the request to their appropriate Medicare Administrative Contractor (MAC). Should there be Medicare systems issues that interfere with claims processing, CMS and the MACs will post information on how to access advance payments. CMS does not have the authority to make advance payments in the case where a physician is unable to submit a valid claim for services rendered.

NOTE: Watch for upcoming posts on ICD-10 websites and apps that I am rating for their usefulness. We will also be producing free webinars on translating the diagnoses on your superbills, picklists and cheat sheets for ICD-10 – stay tuned!

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Posted in: Headlines, ICD-10

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