Disclaimer

1. Disclaimer This presentation is intended only for use by Tulane University faculty, staff, and students. No copy or use of this presentation should occur without the permission of Tulane University. Tulane University retains all intellectual property interests associated with the presentation. Tulane University makes no claim, promise, or guarantee of any kind about the accuracy, completeness, or adequacy of the content of the presentation and expressly disclaims liability for errors and omissions in such content.

2. TUMG Documentation Top 10 A countdown of important issues that affect documentation, coding, and reimbursement for physician services. It isn’t the mountains ahead, it’s the grain of sand in your shoe. Before Viewing: print the handout/quiz for TUMG Documentation Top Ten

3. Read Before Proceeding Physicians and Staff may earn one compliance credit by viewing this presentation, completing the assessment, and faxing the assessment to the University Privacy and Contracting Office: 504-988-7777 This presentation may be viewed for compliance credit only once in a fiscal year (July 1 - June 30). To check how many compliance credits you have and to see which training sessions you have completed, contact the University Privacy and Contracting Office at 504-988-7739

4. It is the policy of TUMG to provide healthcare services that are in compliance with all state and federal laws governing its operations and consistent with the highest standards of business and professional ethics. Education for all TUMG physicians is an essential step in ensuring the ongoing success of compliance efforts.

5. This education is a General Compliance Education Presentations available on the Tulane University Privacy and Contracting website:http://tulane.edu/counsel/upco/billing-ed/

6. TUMG Physicians are responsible for documenting their outpatient visits and selecting the level of service to be billed to the carrier. TUMG Compliance

7. “No change in history or exam since…” “No change since last visit…” “Findings same as last visit…” Illegible notes Undocumented work #10 Know what doesn’t count when it comes to documenting a service

8. Outpatient visit documentation must “stand alone.” Physicians cannot link to other visits for chief complaint, HPI or exam. Only information documented in the visit note will count as support for a level of service. Reimbursement guideline: payors base reimbursement on what is documented for a particular date of service, not on information contained in other visit notes. #10 Know what doesn’t count when it comes to documenting a service

9. #9 Link to Ancillary staff notes and patient questionnaires • Patient questionnaires and staff notes can provide documentation to support a level of service, but physicians must link to them in the visit note. • “Positive for cough and fever. Per 6/15/05 patient questionnaire, all other systems negative” • “Per 8/1/05 questionnaire, family history non-contributory” • Note: Physicians may link to ancillary staff notes and patient questionnaires for two elements of History: Review of Systems and Past/Family/Social History. A link to a measurement of Vital Signs can be used as an Exam element.

10. If using a patient questionnaire to support a service, physicians should review, sign, and date the form. If using a patient questionnaire from a previous visit, physicians should include the date the questionnaire was completed. Be sure the questionnaire is put in the medical chart. Auditors/Reviewers won’t look for something they don’t know exists, and they won’t count anything they can’t find in the record. #9 Link to Ancillary staff notes and patient questionnaires

11. #8 Link to Resident Notes • Linking to resident notes means that the level of service and reimbursement can be determined and supported by the combination of both notes. • Not linking to a resident note will result in the level of service and reimbursement being determined by the teaching physician’s note alone. • Example: If the resident documents the patient’s history for a new patient, unless the physician links to the resident note OR re-documents the history, a new patient or consult code cannot be billed.

12. Physician sees patient with the resident: New Patient, Consult/or Follow-up visit: “I was present with the resident during the history and exam. I discussed the case with the resident and agree with the findings and plan as documented in the resident’s note.” Physician sees patient after the resident New Patient, Consult/or Follow-up visit: “I saw and evaluated the patient. Discussed with resident and agree with resident’s findings and plan as documented in the resident’s note.” Examples of Linking to Resident Notes Medicare Transmittal 1780 – Teaching Physician Rule provides other examples of linking statements: http://www.med.ufl.edu/complian/Q&a/CMS_Transmittal_R1780B3.pdf

13. #7 Read Resident Notes Before Linking! • When physicians link to resident notes, they attest that they have “reviewed” the documentation. The combined notes will determine the level of service.

14. #6 Code Signs and Symptoms if a Definitive Diagnosis cannot be made • ICD-9 Coding Guidelines note • Diagnoses are often not established at the time of the initial encounter/visit. It may take two or more visits before the diagnosis is confirmed. • Codes that describe symptoms and signs, as opposed to diagnoses, are accepted for reporting purposes when a related definitive diagnosis has not been established (confirmed) by the physician.

15. #6 Code Signs and Symptoms if a Definitive Diagnosis cannot be made Rule out and possible conditions should not be coded. They may, however, be mentioned in the documentation as support for the complexity of the medical decision making. • Source: ICD-9 CM, Volumes 1 & 2, INGENIX, 2005

16. #5 Always Code Diagnosis to the Highest Specificity • A diagnosis code is INVALID if it has not been coded to the full number of digits required for that code. • ICD-9 CM, INGENIX, 2005

17. #5 Coding to the Highest Specificity Helps to Avoid Workfile Edits and Denials • When a code requires a 4th or 5th digit, IDX is set up to stop charges and drop them into workfiles for follow-up with the physician. Until the additional digit(s) are added, the bill remains suspended in the IDX system.

18. #5 Coding to the Highest Specificity • To avoid coding specificity errors: • Be sure your billing encounter form contains up-to-date codes and that the codes indicate whether a 4th or 5th digit is required. Source: ICD-9 CM, INGENIX, 2005

19. Cloned notes or notes that have little or no change from visit to visit and patient to patient raise both documentation and reimbursement issues: These type of notes do not support Medical Necessity. In some cases, they may not support that a visit actually occurred. Cloned notes may be construed as an attempt to defraud the Medicare program. #4 Avoid “Cloned” Notes • Source: E/M Undercoding: Don’t Lose Earned Reimbursement, Jo Ann Steigerwald, RHIT, ACS GI, ACS-OH, Teleconference July 25, 2005. (Citing Cigna Medicare)

20. #4 Avoid “Cloned” Notes • Visit notes must be patient-specific • If using templates or EMRs (Electronic Medical Records), they should be detailed and specific enough to accurately reflect the patient service.

21. Time-Based codes require two elements of documentation: Time Element – two ‘times’ must be documented: Total time of the visit Amount of time face-to-face counseling with the patient and/or family, which must represent of more than 50% of the total time Content of counseling: Record must reflect what topic(s) were discussed during the counseling portion of the visit Documentation of counseling must be patient-specific; use of generic “canned” notes is discouraged #3 Know How to Document a Time-Based Code

22. To learn more about time-based codes, visit the Tulane School of Medicine Compliance Training Website: http://www.som.tulane.edu/fpp/billing_new/ View the PowerPoint Presentation and Download the file on “Time-Based Codes” #3 Know How to Document a Time-Based Code

23. #2 Understand and appropriately apply E/M Documentation Guidelines • TUMG physicians are responsible for selecting the level of outpatient service billed to the patient or the patient’s insurance. • To bill for a service, medical necessity must be clearly established and • The documentation must support the level of service billed.

24. #2 Understand and appropriately apply E/M Documentation Guidelines • For more information on E/M Documentation Guidelines, visit the Tulane School of Medicine Compliance Training Website: • http://tulane.edu/counsel/upco/billing-ed/ • The website has a 9-part “Documenting an Outpatient Visit” module. Physicians and Staff may view and/or print any or all of the presentations.

25. Corollary: If it isn’t written, It didn’t happen, And it can’t be billed #1 WYSI-WYG Principle What You See Is What You Get

26. #1 WYSI-WYG Principle • If medical record documentation does not support medical necessity, or does not support the level of service billed, reimbursement may be denied. • In the case of an audit, payors may request a refund of reimbursement or impose penalties.

27. Contact Information • TUMG Business • ServicesCompliance Reporting Hotline: 504-988-5142

28. End of Presentation To earn one compliance credit, download the file: “TUMG TOP 10” from the website. Complete the quiz and fax to 504-988-7777