Compliance CornerFY15 Q1OHSU Department of Anesthesiology and Perioperative Medicine

Norm Cohen MD, Suzanne Simmons MBA, Eileen Browning CPC

Agenda

• Overview FY15Q1Compliance• Procedure notes – authors and cosigners• Post op pain orders from surgeon• Concurrency for OB• Multiple cases on one anesthesia event • Breaks

Overview FY15Q1 Compliance

• Comparison FY14Q1 – FY15Q1

• Great improvement over the past year and from the break transition, Thank You!

FY14Q1

FY15Q1

% chng

Deficiencies w/o OL 1287 988 -23.0%Overlaps 187 350 87.0%

Total 1474 1338 -9.0%

Apr-14 May-14 Jun-14 Jul-14 Aug-14 Sep-14Overlaps by month 38 52 333 183 90 77

Procedure notes

• Procedure notes need to be authored by one of the clinicians performing the procedure. If documented by a CRNA or resident, cosign by the faculty required.

• If authored by another clinician not signed into the case, they are acting as a scribe and need to follow the OHSU scribe policy:– Scribe includes statement: “I (name) am

functioning as scribe for (provider name)in their presence.”

Fun and Games #1

Q. What one event needs to occur prior to placing a block or epidural for post op pain?

1) The surgeon needs to pay for the procedure.

2) Candy should be provided for all staff.

3) An order or request from the surgeon needs to be documented in the patient’s chart requesting

assistance with post op pain management.

4) An H&P update needs to be done prior to the procedure.

Post op pain orders from surgeon

• Medicare requirement as of November 2013 that surgeons order for post op pain be documented in the patient chart as well as anesthesiologists acceptance of the order.

• Our compliance rate leveled off at 85% of cases documented correctly.

• Responsibility falls on the regional team first if involved, otherwise the anesthesia team for the case.

Fun and games #2

Q. C-sections, tubal ligations, and labor epidurals are all considered the same when determining concurrency.

1) True

2) False

Concurrency for OB cases

• Placement or maintenance of an epidural for L&D is an allowable activity while medically directing.

• Labor neuraxial analgesics are not included for concurrency edit of number of cases medically directed simultaneously.

• C/S and BTL’s are considered surgical procedures and are included in concurrency and medical direction edits.

Multiple cases on one anesthesia event

• Increase in number of anesthesia events with two separate cases documented.– Predominantly OB and trauma bring-backs.

• If it is discovered too late to correct by opening an adhoc anesthesia event, use quick notes to identify 2nd case anes start and stop.

• Please advise billing (Eileen) via email.

Break Relief

• Revised break policy effective in June 2014. Working well most of the time now.

• The most common residual issue is overlapping time or solo provider time. Please remember:– Faculty may not work solo while medically directing a

resident. It is your responsibility to obtain coverage.– When coverage occurs the staff involved should

document so their minutes match exactly on the concurrent cases.

Questions????