87 percent error rate leads to drastic measures.
If you think CMS is only watching your E/M codes when it comes to the office or hospital, think again. One MAC recently reviewed nursing facility care claims and was stunned at the findings.
NGS Medicare, a Part B payer in four states, announced on Jan. 26 that it had recently audited claims for code 99310 (Subsequent nursing facility care, per day), and found that only 13 percent of these claims were billed correctly.
Based on the outcome of the audit, NGS said that it “will be implementing a prepay edit for CPT code 99310.”
Know these quick facts before you report this nursing facility care code in the future.
1. Check documentation for comprehensive interval history, comprehensive exam, and/or highcomplexity medical decision-making. CPT requires documentation of at least two of these criteria before you can bill 99310.
“I imagine that doctors are habitually visiting all their nursing home patients at one time and not documenting enough to meet the level-three code,” suggests Crystal S. Reeves, CPC, CPC-H with The Coker Group in Alpharetta, Ga. Indeed, the NGS report indicates that “most errors occurred because the services were billed at a higher level than was substantiated by the documentation.”
2. If you’re coding based on time, be sure to document the pertinent details.
Ever since 2008, CPT has published average time spent on the nursing facility codes, allowing you to report them based on time. However, in order for you to bill these visits based on counseling and coordination of care time, the patient must be present during the visit, and you must document the amount of time spent in counseling.
“Documentation must include time spent face-to-face (or on the floor/unit) counseling and/or coordinating care, as well as the total time of the encounter,” says Wendy Owens-Frierson, CHM, CHI, CPC with PRSS, Inc. in Miami, Fla.
Resource: To read the results from the NGS audit, go here.
Look for an in-depth article about time-based E/M coding in next week’s Part B Insider. Download 2 FREE sample issues here.
Available on CD: The biggest mistakes that coders make with nursing facility E/M codes.
Related articles:
- The Truth About Self-AuditsAnd one crucial step you should never miss. How many...
- E/M Challenge: Can I Report 99214 and +99354?Counseling representing more than 50 percent of E/M visit? Choose...
- CMS Will Offer New Modifier to Denote Admitting Physician on ClaimsPop the champagne cork & get ready for brand new...
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MACs are looking for ‘red flags’ to halt additional global period pay
Billing for additional services during a global surgery period is always tricky, but now you can expect special scrutiny for modifier 79 claims.
After the OIG got wind of fraudulent surgery billing with modifier 79 (Unrelated procedure or service by the same physician during the postoperative period), CMS contractors have been on the hunt for modifier 79 abuse. Implement our expert tips below to keep your 79 claims clean.
Obey Global Package Model
The starting point for clean modifier 79 claims is not breaching the global surgical billing concept. Once you understand the global package rules, you’ll know when you have an exception that warrants an additional claim with an appropriate modifier.
Know what’s included: The global package includes the preoperative visit the day before surgery, intraoperative services, postsurgical complications, and postoperative visits during the global period. It also includes post-surgical pain management services by the surgeon, and miscellaneous services such as dressing changes, suture removal, staples, etc., according to Donna Pisani, provider outreach and education consultant with National Government Services (NGS) during a global surgery conference call. NGS is a Medicare payer in 25 states.
Choose 79 for Distinct Procedure During Global Period
If your surgeon performs a service during the global period that the “package” doesn’t include, you can bill separately for the additional procedure — but you’ll have to use a modifier.
Key to 79: You’ll know that 79 is the correct modifier if the second procedure is for an unrelated condition during the global period of the first surgery. In other words, if the same surgeon must perform a separate, unrelated procedure for an unexpected medical condition during theglobal period of a previous procedure, you should append modifier 79 to the subsequent procedural code(s).
Tip: “If the second procedure takes place on a different body part, 79 is usually the correct modifier,” says Joseph A. Lamm, office manager for Stark County Surgeons in Massillon, Ohio.
Another clue that you should use 79 is if the surgeon links a second procedure to a totally different diagnosis and does not mention a “complication” or that the second procedure is staged or related to the first, according to Lamm.
Example: The patient is in the global period for a partial mastectomy (19301, Mastectomy, partial [e.g.,lumpectomy, tylectomy, quadrantectomy, segmentectomy]). During that time, the patient has an appendectomy (such as 44970, Laparoscopy, surgical, appendectomy) because of acute appendicitis. You should append modifier 79 tothe appendectomy code.
Scrutinize Your 79 Claims — Before Your Contractor Does
Thanks to abusive practices of some providers who used modifier 79 to bypass surgical bundling rules, the Office of Inspector General (OIG) “has asked all contractors to look at codes with modifier 79,” Pisani says.
Loophole: Although CMS established pre-payment edits to detect when providers unbundle services from the global surgical package, services billed with modifier 79 were excluded from those pre-payment edits. That’s why CMS has instructed contractors to “strengthen program safeguards” against fraudulent 79 claims.
“Be aware if you’re using modifier 79 that you’re using it appropriately, and your records reflect the documentation,” Pisani notes.
Resource: To read the CMS instruction on modifier 79 scrutiny, go here.
Distinguish Other Global Period Modifiers: Unrelated conditions aren’t the only reason your surgeon might perform a separate procedure during a global surgical period. If the second procedure is not unrelated to the initial surgery, you’ll have to turn to modifiers other than 79.
• Identify planned or staged: Call on modifier 58 (Staged or related procedure or service by the same physician during the postoperative period) when the surgeon performs a secondary surgery during the post-op period of another surgery and the subsequent procedure was planned or staged, Pisani notes.
• Distinguish related but not planned: Modifier 78 (Unplanned return to the operating room by the same physician following initial procedure for a related procedure during the postop period) applies to the service when the physician has to unexpectedly return the patientto the operating room (OR) for a related procedure during the postoperative period, Pisani says.
Remember OR restriction: Medicare will only pay for treating a complication during the surgical global period if treatment requires a return to the operating room. Modifiers 58 and 78 do not apply if the Medicare beneficiary does not return to the OR.
© General Surgery Coding Alert. Download your 2 FREE sample issues here.
To Bill or Not: What’s in the Global Surgical Period. An audio training event with Jean Acevedo, LHRM, CPC, CHC, CENTC.
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- Bone Up On ASC Orthopedic Coding With These Global Period, Modifier Tips 3 ways your physician claim better look different than...
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