July 2010 Client Newsletter
Electronic Medical Records (EMRâ€™s)
Lots of discussion is occurring about EMRâ€™s. One of the key considerations is, aside from working well for you, is that it must meet â€œmeaningful useâ€ criteria. If it does not meet it before or after you buy it â€“ it will result in no Medicare bonus payment to you! One of those criteria is certification which many EMR programs do not have and are being sold based upon a promise that it will be. Be VERY careful buying such a program â€“ if they do not obtain the certification â€“ no bonus money!
Mark R. Anderson, FHIMSS, CPHIMS, CEO and Healthcare IT Futurist, AC Group, Inc. (http://www.acgroup.org) is an EMR expert who has provided the following statistics:
- 42% of Physicians have purchased EHR
- Only 7% are using EHR in full production
- 72% of EHR installs are not fully operational after a year or de-installed
- 19% stopped using within 1 year
Further, another EMR expert estimates there are about 400 different companies selling EMRâ€™s with less than 10% of surviving the eventual market shakeout. Looked at another way â€“ providers have a 90% chance of selecting a vendor that will go out of business! Clearly you need to carefully select which package you purchase and will want to ensure you have flexibility. One of the questions to ask is will the EMR provide an â€œHL7â€ file that can be imported into our software for billing? If so, then your billing data will continue to be safe if the EMR product develops any issues - like going out of business.
AUDITS / MEDICAL RECORD REQUESTS
We are beginning to see medical record requests for a variety of audits â€“ mostly all Medicare. And we are hearing this is occurring nationally. We strongly suggest that you carefully review the requests before responding and be sure that:
- All the requested documentation is returned, and that it is legible.
- All signatures meet Medicare signature requirements.
- Send it timely â€“ generally the sooner, the better.
- Documentation is not altered once it has been sent.
If they receive no response, all charges are denied. If already paid, they will move to recoup the payments. It also raises other concerns which could lead to further action.
CMB is experienced with these issues and will be glad to assist you.
PAYMENTS FOR DRUGS
If we are billing any drugs for you to NJ Medicaid, we must use the National Drug Codes (NDCâ€™s) numbers in order to get you paid. These #â€™s are based on the manufacturer, dosage, etc. If you change any of that â€“ buy from a different manufacturer, change the dosage, route of administration, etc., we will need to know the NDC # from the packaging prior to billing.
RED FLAG RULE
Late in May, after the June 1 Client Bulletin was printed, the FTC delayed implementation until December 31, 2010.
It has the potential to completely disrupt the payment system â€“ for MANY reasons. This is not an exaggeration. While Medicare (along with TriCare, Medicare Advantage, and Railroad MC) says it will go to ICD-10 on 10/1/13, no other payors are required to!
For example, letâ€™s say the patient has Medicare 1â€™ and Blue Shield 2â€™. We bill Medicare with 1 of the 68,000 ICD-10 codes, but when it auto crosses over to the 2â€™, Blue Shield does not accept ICD-10 â€“ only ICD-9 (about 13,000 codes) â€“ so refuses payment. So then we have to decide which ICD-9 code matches to each ICD-10 code. In a best case scenario, we successfully accomplish that and the provider gets paid.
But provider training in documenting what is required to be specific enough to code the additional 55,000 ICD-10 codes alone will be a significant task.
Medicare INPATIENT CONSULTS
Occasionally there are patients whose initial inpatient E/M service is less than CPT 99221 (a detailed or comprehensive history; a detailed or comprehensive examination; and medical decision making that is straightforward or of low complexity). National Government Services (NGS) Medicare has stated: "There may be instances where subsequent hospital care codes best fit the description of the service rendered. NGS recommends the use of subsequent care codes 99231 or 99232 for those encounters that would have previously been coded using consultation codes 99251 or 99252, since these would match the complexity of the visit codes (problem focused history and physical/straightforward medical decision making; expanded problem focused history and physical and straightforward medical decision making) for the 99251 and 99252, even if this is a providerâ€™s first visit with the patient during the hospitalization. National Government Services advises not to code the 99499 in these instances."