Friday,
September 5, 2003
Vol. 6, No. 71
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On Complianceinfo.com
Sample compliance policies and procedures. (For subscribers to Strategies for Health Care Compliance only)
Sample audit programs. (For subscribers to Health Care Auditing Strategies only)
The OIG Work Plan for Fiscal Year 2003
Ask the Expert
Compliance Hot Topics: Billing and Coding, EMTALA, Stark, HIPAA
Question of the Week
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Welcome to Compliance Monitor Q&A!
Our mission is to answer your difficult compliance questions-and your simple ones, too. To submit a question, send it to Compliance Monitor Q & A editor Melissa Osborn at mosborn@hcpro.com.
We hope you enjoy this service and we welcome your feedback.
This week's questions
Pay-per-view article
Quick survey
Questions and Answers
What rules apply for non-physician staff and evaluation and management codes?
Q:
Can hospitals use evaluation and management codes to bill for consultations performed by hospital ancillary or nursing staff, such as respiratory therapists?
A:
While there is one evaluation and management (E&M) code that non-physician, outpatient point-of-service staff may use (99211), current procedural terminology (CPT) rules clearly state that ancillary hospital staff cannot use the E&M codes. "Professional services are those face-to-face services rendered by a physician and reported by a specific CPT code," the rules say.
CPT also offers codes for evaluation services performed by physicians and physical and occupational therapists in the 97001 - 97006 range.
However, Program Memorandum (PM) AB-98-15 (CR 202) outlines the circumstances under which Medicare will reimburse hospitals for services provided there by physician assistants (PA), nurse practitioners (NP), and certified nurse specialists (CNS). As of January 1, 1998, PAs, NPs, and CNSs may provide services traditionally performed by physicians, such as physical examinations or X-ray interpretation. Therefore, hospitals can bill E&M codes for inpatient services rendered by these providers, as long as the services are included in the provider's scope of practice in the state in which the provider practices. This rule comes from section 4511 and section 4512 of the Balanced Budget Act of 1997, which removed the restriction on the areas and settings in which Medicare will pay for the professional services of NPs, PAs and CNSs.
According to that PM, "certain professional services furnished by NPs or CNSs in rural health clinics and federally qualified health centers (FQHC) are included in the payment to the facility. Examples of services payable under the facility payment include the following: visit codes, surgeries, interpretations of diagnostic tests, and services and supplies incident to their professional services, such as injectable drugs." If the inpatient facility is not a rural health clinic or FQHC, it can bill appropriate inpatient E&M codes, but it is essential for the hospital to check with the state to verify the provider's scope of practice.
Of note: Commercial carriers may have different rules. Find the information regarding use of E&M codes by ancillary staff by either reviewing contracts or contacting the provider services department of each plan.
This question was answered by Barbara Aubry, RN, CCM, CPC, a clinical business analyst for Info-X-Inc.
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Tell us about your financial policies!
Click here to take our quick survey on your financial policies and procedures!
Improving outpatient documentation
Did you know that four types of encounters account for over 90% of the facility-based outpatient visits? If your facility is busy with emergency department, diagnostic testing, ambulatory surgery, and observation visits, there are plenty of opportunities to miss appropriate reimbursement due to documentation errors, not to mention chances to fail to meet compliance standards.
You need the new book, "Guide to Outpatient Clinical Documentation Improvement: The First Step in Revenue Cycle Management" by Ruthann Russo, JD, MPH, RHIT.
For more information, CLICK HERE and save 10% when you order on line. You may also call our Customer Service Team at 800-650-6787. Please mention source code EB23108A when you call.
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JOIN THE COMPLIANCE MONITOR TEAM!
Are you a compliance expert? We're looking for compliance experts in coding, billing, documentation, HIPAA, EMTALA, Stark, laboratories, and many other areas of compliance. If you are interested in answering questions from your peers, please e-mail Compliance Monitor editor Melissa Osborn.
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Pay-Per-View article:
Radiology: Aggressive mammography audits boost detection and cancer analysis
Perform clinical audits of mammography services to make sure your organization is doing its best to detect and analyze cancer. By understanding and comparing the data in your mammography medical audits, you can better translate that information into usable and valuable data to strengthen your mammography practice and improve quality of care. Measuring your audits against nationally recognized standards is important, but it's more meaningful to learn how to evaluate the ongoing results. . . .
To find out how to audit clinical trials, order the pay-per-view article "Clinical trials: 10 easy steps to assess your risk." 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 August issues.
A $30 steal!
You can read this article-and much more-in the August issue of Health Care Auditing Strategies. Your cost: Five stories for only $30! You'll also learn how to audit observation services, how to perform a marketing audit, how to assess your clinical trials, and how to use aggressive mammography audits to boost detection and cancer analysis.
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IMPROVE REIMBURSEMENT AND DOCUMENTATION
Get an EASY, STEP-BY-STEP KIT to increase medical records accuracy; improve reimbursement, reduce staff work time; and get all physicians, clinical staff, HIM personnel, and administrators on the same page with documentation improvement to comply with Medicare and other federal regulations.
Order the CDI (CLINICAL DOCUMENTATION IMPROVEMENT) SYSTEM FOR INPATIENT CARE(TM). Just call HCPro's customer service at 1 (800) 650-6787 (please mention source code EB22607B) or click here.
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Does Medicare allow prescriptions with stamped signatures?
Q:
Does Medicare accept prescriptions with stamped signatures, or does it require an original signature?
A: To read the answer to this question, click here.
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Quick survey:
Does your organization train employees on Medicaid compliance issues?
To submit your answer, go to the Question of the Week at
Complianceinfo.com.
Here are the answers to the last survey:
When will your organization begin auditing its HIPAA compliance program?
- Within the next six months: 68%
- In 7-12 months: 17%
- In 12+ months: 9%
- We do not plan to audit: 6%
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Network with your audit colleagues
"Audit Talk" is a new, moderated chat forum that members can use to post messages or questions for their peers 24-hours-a-day. "Audit Talk" offers a free forum to network, share ideas, and solve problems for those in the audit industry. Getting involved is easy. To subscribe, just send your request to this e-mail: owner-audit_talk@hcpro.com.
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Send your comments and questions about Compliance Monitor Q&A to:
Melissa Osborn
Managing Editor
mosborn@hcpro.com
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