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* Cell phones and HIPAA: A bad mix?
* How do I bill for labs that don't fall under preventive medicine?
* Pay-per-view Article: Auditing for APCs: Is your facility billing and coding accurately?

Compliance Monitor, February 20, 2003

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Cell phones and HIPAA: A bad mix?

Q: Our patients regularly use cell phones and portable phones to make appointments or call in with questions. What is our responsibility under the Health Insurance Portability and Accountability Act (HIPAA) with mobile phones? We want to maintain confidentiality over the phone when interruptions occur, or when conversations overlap with other calls.

A: HIPAA requires your practice to maintain the confidentiality of patient information, but the authors of the regulation left room so you could apply it in a reasonable manner. Asking yourself what is "reasonable" may give you some direction, since you won't be able to stop your patients from using cell phones and portable phones. And, in many cases, you may be unable to detect the type of phone in use. Here are some tips:

1. If you know you are placing a call to a cell phone, it would be wise to notify patients that cell phones may not guarantee their confidentiality
2. Ask them for an alternative number where you can call to discuss confidential information
3. If patients ask you to continue calling their cell phone number, I would recommend documenting those instructions in their medical record

As part of your patient education regarding HIPAA, you can also put a notation on your patient registration form. State that cell phones and portable phones could represent a security risk due to interruptions or overlap and, therefore, your practice does not recommend their use for discussions of confidential information.

HIPAA's enforcement arm, the Office of Civil Rights, will continue to issue updates and clarifications regarding the privacy rule, so it's a good idea to monitor their announcements. Recent guidelines have helped clear up many misconceptions about the regulations, reinforcing issues as to what constitutes reasonable precautions by physicians.

This question was answered by Patricia Kroken, FACMPE, principal, Healthcare Resource Providers, LLC.

Auditing for APCs: Is your facility billing and coding accurately?

Since your facility depends on accurate and timely use of thousands of HCPCS/CPT codes that generate ambulatory payment classification (APC) groups, you need a system to check your billing and coding department's work. Accurate and complete coding is the single most important element driving your success in the APC reimbursement environment.

Go to "Auditing for APCs: Is your facility billing and coding accurately?" for the rest of this article. The cost is $10. Subscribers to the online version of Health Care Auditing Strategies have free access to this article. Subscribers to the print edition can find it in their February issues.

A $30 steal!

You can read this article-and much more-in the entire February issue of Health Care Auditing Strategies. Your cost: Four stories for only $30! You'll learn how to validate your compliance program's effectiveness through auditing, and how your managed care organization should comply with state prompt-pay regulations. You'll also find tips on how to how to audit inpatient bad debt. Choose between a PDF and HTML version for just $30. Online subscribers have free access to this issue; print newsletter subscribers can find it in their mailboxes.

Q: We have an internal medicine doctor at our facility who performs only Pap smears and collects specimen. The doctor is part of our practice's group. We send the Pap smears to an outside lab to be analyzed. How can we bill for or report the doctor's service? Of note: These are non-Medicare patients coming to us for only screening Pap smears. This is not part of preventive medicine and our facility does not bill for labs.

A: It appears, based on the information you've given, that the proper way to report this is as an office visit evaluation and management (E/M) service. From the information you provided, it does not appear as though the patient would qualify for the Preventive Medicine category of CPT codes for E/M services. Therefore, look at whether the patient is new or established to help you report this service to an insurance carrier. Once you determine that, then you need to decide which services the doctor is performing during that particular patient visit.

New patients:
If the patient is new to your office, and the physician does only a Pap exam and collection of smear-with no other problem-focused history or examination, etc-then I doubt whether the service is billable.

However, most treating physicians, while in the process of performing a pap exam and smear collection, usually perform some sort of problem-focused history and problem-focused examination. And most, use a straightforward medical decision. If this is the case, and your doctor properly documents it, then you can bill CPT code 99201 as the reportable service. Remember, you must have an appropriate amount of documentation to support the code.

Established patients:
If you're dealing with an established patient who has come to the office for a pap exam and smear collection-and no other type of examination is performed (i.e. weight and blood pressure measurements)-then you probably could report this as a 99211. It's more likely, though, that you could report CPT code 99212, since the pap exam and collection of smear would probably qualify for a problem-focused examination and straightforward medical decision making. CPT 99212 requires two of the three categories in order to report this service (the other category is a problem-focused history). Again, your doctor must record the proper documentation of the exam.

Proper documentation is required when reporting any type of office visit examination. It indicates the level of office visit E/M for which the service would qualify. Since your physician is performing a service (pap exam and collection of smear), report this to the carrier.

This question was answered by Rick Oliver, J.D., CHCO, CPC, MT (ASCP), director of compliance at AmeriPath, Inc..

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