Corporate Compliance

*Q Codes
*Nurses and nebulizer treatments

Compliance Monitor, January 5, 2004

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Vol. 6, No. 105


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ONE-STOP COMPLIANCE

Solve all of your biggest challenges—AUDITING, KICKBACKS, STARK, HIPAA,TRAINING, AND MEASURING EFFECTIVENESS with reporters who get the stories and ideas you need to comply and help your organization's bottom line!

"Strategies for Health Care Compliance," a 12-page monthly newsletter, helps you thrive in the ever-changing compliance environment by providing easy-to-understand compliance advice and analysis of the latest regulations. Each month, this newsletter offers how-to tips, features about your peers, policies and procedures, and tools for improving the efficiency and effectiveness of your corporate compliance programs. To learn more, click here or call 800/650-6787.

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

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 Kate Alvarez at kalvarez@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

Q Codes

Q: "In the National Correct Coding Guide, Q0081 is the comprehensive code and 90784 is a component code. Are there any situations in which we can submit bills to Medicare for 90784 with a modifier on the same date of service as Q0081? Do the CCI edits apply to commercial payers as well?"

A: The Centers for Medicare and Medicaid Services (CMS) assign "Q" codes as temporary codes for procedures, services, and/or supplies. When the permanent code is developed, the temporary "Q" code is deleted.

The "Q" code Q0081 is for infusion therapy for drugs other than chemotherapeutics, on a per visit basis. Medicare and Medicaid recognize the "Q" code, but other insurance plans do not.

CPT code 90784 is for therapeutic or diagnostic injection given either subcutaneously or intramuscular and intravenously.

There are situations in which you might use both codes on the same day. For example, a patient comes into a physician office with dehydration and a medical problem and the physician gives an injection and rehydrates the patient with an IV saline solution. In this situation, you would use both codes Q0081 and 90784. Codes 90784 and Q0081 are mutually exclusive codes and therefore do not require a modifier.

CCI edits only apply to Medicare patients. While many insurance carriers have incorporated their own "versions" of CCI edits into their specific health plans, these can vary by carrier and are not always comprehensive. So it's safe to keep in mind that CCI edits are not necessarily applicable to non-Medicare plans.

This question was answered by Michael O'Connell, MHA, FACMPE, CHE, Senior Director, Cleveland Health Network MSO, LLC.
moconnell@msopbs.com

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WE NEED YOUR EXPERTISE!

Join the Compliance Monitor Team! Compliance Monitor Q&A relies upon experts just like you to answer pressing compliance questions. We're looking for 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 Kate Alvarez.


PRACTICAL INFORMATION AND STRATEGIES TO HELP YOU MANAGE OIG FOCUS AREAS FOR 2004

E/M coding. Consultations. Incident-to services and supplies. Long distance physician claims. Office of Inspector General (OIG) enforcement officials have turned their attention to physician practices, and these four high-focus areas, carried over from last year, are not going away. Plus, the OIG includes eight more topics for physician practices in 2004. It's a task just to understand all the issues and stay on track with your compliance program.

HCPro can help you with your physician practice compliance efforts. Attend the 90-minute live audioconference, "2004 OIG Work Plan for Physician Practices: How to Get Ready and Stay in Compliance."

This program will be held on Friday, January 23, 2004. Click here to register or learn more, or call 800/650-6787 and mention source code EZ24175C.

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Tell us about your financial policies.

Click here to take our quick survey on your financial policies and procedures.

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Pay-per-view article: Residents and coding training make a healthy mix

First and second year residents are consumed with their clinical education and subsequently disregard coding and reimbursement issues, says Diane Brooks, CPC, coding compliance manager for Montgomery Hospital in Norristown, PA.

However, Brooks says that in the third year of residency, "they really want to spend some time with me-when they're getting out into the real world." It's at that point in their education that residents realize the impact that reimbursement can have on their careers.

To find out more about training residents on the reality of coding, order the pay-per-view article " Residents and coding training make a healthy mix." The cost is $10. Subscribers to the online version of Briefings on Coding Compliance Strategies have free access to this article. Subscribers to the print edition can find it in their December issues.

A $30 steal!

You can read this article and much more in December's issue of Briefings on Coding Compliance Strategies. Your cost: five stories for only $30! You'll also learn why the NCVHS recommendation is a big step forward for ICD-10 implementation, how ED coders can help recover reimbursement and improve compliance, how bridging the gap in coders' clinical knowledge benefits everyone, and you can check out this month's coding Q&A.

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E/M training for a fraction of seminar costs

Does your physician staff understand the CMS and CPT guidelines for E/M coding? A higher code means more money, but if clinicians don't code appropriately, facilities could put reimbursement and compliance at risk. Coding inaccuracties can even have legal consequences.

The Evaluation and Management Training Kit will help medical professionals understand current documentation guidelines and meet documentation goals by providing more detail and insight into what those guidelines mean. It offers concrete examples of both poor and excellent documentation practices. When they understand what needs to be done--and why it needs to be done--they will have fewer documentation errors. That translates to better hospital record-keeping, improved patient care, and a reduced risk for noncompliance.

These handbooks are sold in packages of 10 for $75. Each package also includes a set of laminated cards that emphasizes the four essential elements that need to be documented for every patient encounter.

For information or to purchase, CLICK HERE or call our Customer Service Department at 800/650-6787 and mention Source Code EB24674B.

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Nurses and nebulizer treatments


Q: "Ours is a small rural hospital (not critical access) with two respiratory therapists (RTs) on staff. We work our shift, and take call during the night shift. Can the Respiratory Care department charge Medicare or other insurance companies for nebulizer treatments (SVN's) when the nursing staff on the 11-7 shift give the treatments? Can the nursing staff charge for the payments in both inpatient and emergency room settings?"

"We charge the first treatment as an "initial treatment", whether the RT or the nurse gives it, but we do not charge when the nurse gives subsequent treatments, because that is not done for any other scheduled medications. Why would the RT treatment be an exception?"

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 to 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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Share the news

You've been benefiting from our informative e-mail newsletter, so why not pass on this resource to your peers? Sign up a colleague and get $20 off your next purchase on HCPro's Healthcare Marketplace!

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Send your comments and questions about Compliance Monitor Q&A to:

Kate Alvarez
Editorial Assistant
kalvarez@hcpro.com



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