Coding Strategy

Here are the pros and cons to help guide your decision.

Question: Our practice is considering accepting patients with PFFS plans. We’re heard that some patients are starting to have them, but we’re not sure whether we’re going to accept them or not. Are PFFS plans beneficial for us?

Answer: PFFS are Private Fee-for-Service plans, which are non-network plans. These plans let members receive care from any doctor or hospital that accepts the plan’s payment terms and conditions.

If your practice decides to accept these terms, you would become a “deemed” provider. Plan members can receive covered services from any deemed provider in the U.S. However, member patients must confirm that the provider is deemed every time a service is provided.

PFFS plans are different from Medicare Advantage plans because they do not require a doctor or hospital to contract with a health plan to provide services. This means that doctors or hospitals that do not agree to the PFFS plans’ terms and conditions may choose not to provide health care services to a plan member, except in emergencies.

Coming soon: Starting in 2011, PFFS plans will have to measure and report on their providers’ quality of care. But the catch is that they’ll also have to form provider networks with contracts.

In counties where there are two or more non-PFFS plans, PFFS plans will no longer be able to simply “deem” providers into the plan without a contract. Under current law, PFFS plans don’t have to prove they can meet access standards if they allow any willing qualified Medicare provider to participate, and they pay as traditional Medicare would pay.

One argument is that the network requirement would provide better access to care because there would be contracts between the providers of services and the plan. On the other hand, private FFS plans may limit the number of providers who participate, actually resulting in poorer access to care.

@ Medical Office Billing & Collections Alert (Editor: Joshua Thines).

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Save this option for when other collection methods have failed.

You’ve offered discounts, payment plans, and more,but you still haven’t received payment from a patient. You may be forced to do a write-off at this point, says Steve Verno, CMMC, CMMB, NREMT-P, a medical billing consultant and educator in Orlando, Fla. Your practice is justified in writing off a patient’s balance in the following situations:

1. The cost of collecting a balance is more than what the patient owes. For example: A patient’s balance due is $3 after all insurance payments. The administrative cost to bill and collect is at least $15 per statement. “You don’t spend $15 to collect $3,” Verno says.

2. The provider uses all available methods to try to collect, including submitting the account to a collection agency.

3. The patient files for bankruptcy. This does not automatically initiate a write-off, however. The court could discharge the debt or establish a payment plan based on available assets. If you do receive a discharge of debtor notice, you can then write off the debt.

4. If the patient has Medicare, but there is no signed Advanced Beneficiary Notice of Non-Coverage (ABN) form on file for the specific date of service, and thus there is no GA (Waiver of liability statement on file) modifier on the claim, you will not be allowed to balance bill. So if Medicare won’t pay the claim due to medical necessity, you will be forced to write off the charges.

5. If the terms of your contract with the insurance company state that you cannot balance bill the patient if a claim is denied. The process may follow a similar outcome as in bullet point 4, resulting in a write-off.

6. The patient proves financial hardship, using the criteria mentioned in part one of “Don’t Let Patients’ Financial Hardship Become Yours” in the Vol. 10, No. 2 issue of Medical Office Billing & Collections Alert. Editor: Joshua Thines.

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You have two options depending on the next step.

Question: Our vascular office performs blooddraws and analysis for a local hospital. Can we bill for a lab draw in an office setting, and if so, what codes should we use?

Georgia Subscriber

Answer: If you’re sending your patients to an outside lab for both the blood draw and testing, you cannot report any blood draw codes. If your office collects the blood, you have two coding options, depending on the next step.

Option 1: Since it sounds like your practice has its own laboratory to perform blood tests, you can report 36415 (Collection of venous blood by venipuncture) for the venipuncture, assuming that the lab has Clinical Laboratory Improvement Amendments (CLIA) certification.

Option 2: If the collected blood specimen goes to an outside lab for testing, you should report 36415 for the blood draw and add modifier 90 (Reference [outside] laboratory).

Also keep in mind that most Medicare carriers allow one collection fee for each patient encounter, regardless of the number of specimens drawn. If an E/M service is provided and billed, most payers will bundle 36415 into the E/M service.

Finally, be sure to document the blood draw. All services administered to the patient, including the blood draw, must be documented in the patient’s medical record.

@ Medical Office Billing & Collections Alert. Editor: Leesa A. Israel, CPC, CUC, CMBS

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Make sure your documentation supports the additional substantial complexity of the hernia repair and mesh.

Question: A patient presented for a colectomy for colon cancer. The physician also discovered that the patient had a ventral incarcerated hernia that required a complex repair using mesh. Because of the separate work, we reported 44140 and then reported 49561 with modifier 59. The payer denied the claim. Were we wrong to append modifier 59?

Mississippi Subscriber

Answer: You might think you can append modifier 59 (Distinct procedural service) to the hernia repair code and bill it separately. After all, the hernia repair seems to qualify as a different reason for surgery than the colectomy — for example, if the patient has a recurrent hernia. But modifier 59 tells the payer the hernia repair happened at a separate session, which isn’t true in your case.

If the physician’s documentation proves justification, you might try …

… appending modifier 22 (Unusual procedural services) to the colectomy code because of the extra complexity, time, and effort required by the complex hernia repair with mesh.

The Correct Coding Initiative (CCI) considers hernia repair code 49561 (Repair initial incisional or ventral hernia; incarcerated or strangulated) to be part of partial colectomy code 44140 (Colectomy, partial; with anastomosis) because the hernia repair is integral to the closure. You may have to appeal for the additional money. So make sure the documentation supports the additional substantial complexity of the hernia repair and mesh implantation before appending modifier 22.

Verify co-pay early to save time, money

Question: A patient came to our office for a routine exam with the same insurance card she’s had for years. We charged her the standard copay of record. Then I found out her employer changed the terms of the insurance, so the copay she paid was short by $20. What went wrong?

Answer: You might easily assume that when a patient has the same insurance company, the copay is the same as it has always been. But unless you check first, you won’t know the patient’s coverage has changed until after the fact.

Best practice …Set up a process to verify each patient’s insurance information before every visit. The ideal time to verify with a patient or her insurance company is either before the appointment or when she arrives at your office. Devise a plan for how you will obtain patient information early on. Your options include connecting with the patient, a software program, or through the payer directly.

Finally, copy every patient’s insurance card every time. This simple step will put you in the clear for those times when a patient’s terms, copays, or precertification contact numbers have changed.

© Medical Office Billing & Collections Alert.

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