A Belt and Suspenders Approach to Chart Audit and Coding by Carol Olson
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Transcript of A Belt and Suspenders Approach to Chart Audit and Coding by Carol Olson
A Belt & Suspenders Approach to Chart Audit & Coding
March 19, 2014
BUCKLE UP… ARE YOU READY FOR THE RIDE?
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One foot on the brake and one on the gas, hey Well, there's too much traffic, I can't pass, no
So I tried my best illegal move A big black and white come and crushed my groove again
Go on and write me up for 125 …Post my face, wanted dead or alive Take my license, all that jive ...I can't drive 55, oh no, uh
ACCURATE RISK SCORES BEGIN WITH DOCUMENTATION
Accurate DocumentaNon
& Coding
Complete & Timely Data Submission
Accurate Risk Score & Resources
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! Management Challenge 6: • PrevenNng Improper Payments and Fraud in Medicare Advantage
• CMS's reported error rate for MA decreased from 11.4 percent for • FY 2012 to 9.5 percent for FY 2013 • In 2008 the announced error rate was 30% in large part due to signature issues
• CMS implemented RADV to reduce the errors in risk-‐adjustment data and resulNng improper payments . RADV verifies the accuracy of plan-‐reported diagnoses through medical record review and recouping improper payments idenNfied by these audits.
• CMS plans to audit about 30 MA contracts per year • hZp://oig.hhs.gov/reports-‐and-‐publicaNons/top-‐challenges/2013/
FY 2013 OIG REPORT
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DOCUMENTATION IMPROVEMENT STEPS
! Explain • Communicate the changes within the industry and provide adequate educaNon to the providers and staff
! Evaluate • Look at opNons to improve the clinical documentaNon • Analyze or review to idenNfy potenNal problems
! Select • Methods for documentaNon improvement that work for your unique office and staff
• Be sensiNve to the provider’s Nme. Make it worthwhile for providers to take Nme out of their busy day to discuss a case or go over a review
! Analyze • Analyze methodologies and the effecNveness of your programs to ensure the program structure is effecNve
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CHANGES TO THE RULES OF THE ROAD
! Analyze the 2014 PY (25%/75%) blended model. Train coders and providers accordingly • What codes are new? • What codes dropped off? • Changes in Hierarchies
! Audit to ensure documenta^on is complete and accurate for code capture in the revised model • Are there different documentaNon requirements? • Look for areas of improvement • Specificity
! U^lize analy^cs to assist with loca^ng poten^al coding and documenta^on errors • Incorrect documentaNon/coding paZerns • InpaNent condiNons coded in the outpaNent seeng
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! The rules of the road change, we must shib gears and communicate the changes. Let’s offer the providers the opportunity to be successful • Provider and Coder Training-‐Who will be your audience? • Primary Care/Specialty Care • Coders/ Billers • Office Managers/Cooperate Staff • Large Group versus Small Group
! Be crea^ve in the planning stages • Don’t rush the process. Plan, Plan, Plan you want to drive the message to as many vehicles as possible
• Involve Provider RelaNons, possible making it a contest • Quarterly Provider meeNngs are a good venue • Breakfast, Lunch or Dinner meeNngs most aZended.
Ø Feed them and they will come • Offer CME’s for the Providers and CEU’s for the Coders • Requirement to aZend in order to parNcipate in incenNve programs
! The right planning and training will drive higher performance
HOW DO WE DRIVE THE MESSAGE
CHALLENGES FOR VALIDATION FOR 2013/2014
ICD-‐9-‐CM 2013 HCC Model PY 2014
2014 HCC Model PY 2015
Status
Diabetes Unspecified 250.00
19 19 No change
DiabeNc Renal 250.40
16 18 Category Change 2014
Morbid Obesity 278.01
0 22 Added Code 2014
CKD-‐Stage 1 585.1
131 0 Deleted Code 2014
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Some codes that exist in both models had category changes
BUCKLE UP AND LET’S WORK TOGETHER
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CMS requests organizations’ best efforts to assist in correcting and improving payment error
ECONOMICS OF HEALTHCARE
! The Big Picture • Resources are being spent each and every day regardless if the condiNons were documented appropriately
• What steps are you taking to ensure medical record documentaNon support chronic condiNons?
• We must teach our providers the basic requirements, acceptable verbiage, the differences between provider documentaNon and the official coding guidelines
• Direct Feedback to the coder and provider should be provided • Physicians are overwhelmed and just want to treat their paNents, however Nme constraints someNmes lead to minimal documentaNon, poor specificity, unsigned records and missed status codes…
• Let’s demonstrate this doesn’t need to be an added burden • Provide soluNons and tools
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THE COMPLETE PICTURE OF HEALTH
! Documen^ng and coding the pa^ent’s diagnosis to the highest specificity in the medical record • Affects the accuracy of your paNent’s health status and is reflected in measures of paNent outcomes and potenNally reimbursement
• Drives the development of care management strategies and idenNfies paNents most in need of resources
• Shapes the coordinaNon of care in both the inpaNent and outpaNent seengs
• Reflects CMS’s assessment of quality of care delivered • Drives government and state distribuNon of funding to support enriched paNent services
• Under coding skews the cost data and possibly the outcomes as well
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IMPORTANCE OF MEDICAL RECORD DOCUMENTATION
! Accurate documenta^on and coding is the key to prompt and en^tled reimbursement, prac^ce profiling and contract nego^a^ons. It is cri^cal for both legal and financial reasons • The medical record chronologically documents the care of the paNent and is an important
element contribuNng to high-‐quality care
• The progress note updates the paNent’s clinical course of treatment and summarizes the assessment and plan of care
! But, the role of documenta^on has expanded…
• TradiNonally, documentaNon was used mainly by the provider as a source of informaNon to assist memory of paNent care from one episode to the next and support conNnuity of care.
• Today, documentaNon is also the primary means of communicaNon among an extended care team and externally to health plans and other agencies monitoring health care quality
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The spoken word perishes…the wri0en word remains
2012 DIABETIC FACT SHEET-‐UPDATED 3/2013
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hZp://professional.diabetes.org/admin/UserFiles/0%20-‐%20Sean/FastFacts%20March%202013.pdf
! Nearly 26 million children and adults in the United States have diabetes
! 79 million Americans have pre-‐diabetes
! 1.9 million Americans are diagnosed with diabetes every year
! Nearly 10% of the en^re U.S. popula^on has diabetes, including over 25% of seniors
! As many as 1 in 3 American adults will have diabetes in 2050 if present trends con^nue
! The economic cost of diagnosed diabetes in the U.S. is $245 billion per year
RAF SCORES ! Plans should not assume that the RAF scores assigned to their members are
accurate. Even if your RAF score seems good, that score may not truly represent the actual prevalence of chronic diseases in the MA popula^on you manage. You could be missing a significant opportunity to have the appropriate financial resources necessary to manage the popula^on
! Members are not always seen on a regular basis, which will result in low RAF scores
! Reality is the providers are strapped for ^me and see mul^ple pa^ents each day. Some^mes the importance of iden^fying the burden of disease in the popula^on they are managing can be lost.
! Physicians need to examine popula^on data about chronic condi^ons, which will help them focus not only on individual member screenings, but also on the en^re popula^on they manage. By doing so, they can bejer understand the true burden of disease in this popula^on of oben chronically ill members
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DATA VALIDATION AUDIT
! DVA – Data Valida^on Audit ! Data valida^on involves retrospec^ve comparison of diagnos^c data (ICD-‐9-‐CM) reported to the actual documenta^on within the medical record
! DVA’s should be performed for compliance , educa^onal purposes and to monitor and assess the quality of coding. During the review the auditor specifically verifies the following • Dates of service are within the data collecNon period • Provider signature/credenNals are present on the note for each DOS submiZed • The service was provided by an acceptable provider type and place of service • The diagnoses are properly supported by the medical record documentaNon and official coding guidelines were followed
• Billing codes without appropriate supporNng documentaNon is a compliance issue and creates risk for invesNgaNon as fraud
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COMMON DOCUMENTATION & CODING ISSUES ! Lack of suppor^ve documenta^on for
acute and chronic condi^ons (No MEAT)
! Diabe^c complica^ons, manifesta^ons and specificity missing or lacking Example: Diabe^c CKD, Stage CKD
! Incorrect specificity when selec^ng the ICD-‐9 code, the documenta^on should match the ICD-‐9 selected
! Coding resolved or history of diagnoses as ac^ve, may code resolving diagnosis
! Coding acute/current cancers without the status or ac^ve treatment documented
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! Metasta^c Cancer/ site not documented or coded (one of the highest HCCs)
! Acute stroke coded in the outpa^ent semng when most likely the residual or history of stroke should have been coded
! Fracture codes reported when the fracture isn’t in the acute phase
! Unconfirmed diagnoses coded example: probable, suspected, consistent with, rule out, rather code signs and symptoms un^l defini^ve
! Not documen^ng status codes yearly
• Ostomy Status Morbid Obesity
• AmputaNon Quadriplegia/Paraplegia
• Dialysis Status Non Compliance with Dialysis
ICD-‐10-‐CM DOCUMENTATION IMPROVEMENT
! ICD-‐10-‐CM does not require an increase in quan^ty of documenta^on, however high quality documenta^on will increase benefits of the new coding system which is increasingly being demanded by other ini^a^ves
! Analyze ICD-‐9-‐CM frequency data and focus educa^onal efforts on most frequently-‐coded condi^ons
! Preliminary ICD-‐10-‐CM CMS-‐HCC & Rx-‐HCC Model • hZp://www.cms.gov/Medicare/Health-‐Plans/MedicareAdvtgSpecRateStats/Risk-‐Adjustors.html
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ICD-‐10-‐CM – LET’S HAVE SOME FUN!
! Spacecrab Collision Injuring Occupant V95.43XA
! Dependence on other enabling machines and devices Z9989 • Do they mean Crackberry or Smartphone?
! Burn due to water-‐skis on fire V91.07S
! Swimming pool of prison as the place of occurrence of the external cause Y92.146
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FINISH LINE… QUESTIONS, THANK YOU!
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Next phase has to focus on compliance, education and systemic change.
AltegraHealth.com
(310) 874-‐0539
Carol Olson, CCS, CCS-‐P, CPC-‐I, CPC-‐H, CEMC, CCDS, AHIMA Ambassador ICD-‐10-‐CM PCS Approved Trainer Vice President of Educa=on & Consul=ng [email protected]