Make sure your postop office visit documentation measures up.

The OIG has once again set its sights on several new targets to go with the upcoming new year, and this time the feds will be double- and triple-checking your E/M documentation.

On Oct. 1, the OIG published its 2011 Work Plan, which outlines the areas that the Office of Audit Services, Office of Evaluations and Inspections, Office of Investigations, Office of Counsel to the Inspector General, Office of Management  and Policy, and Immediate Office of the Inspector General will address during the 2011 fiscal year. When the OIG targets an issue in its Work Plan, you can expect the agency to carefully review and audit sample claims of those services.

The Work Plan “describes the specific audits and evaluations that we have underway or plan to initiate in the year ahead considering our discretionary and statutorily mandated resources,” the document indicates.

On the agenda for next year, the OIG has indicated that its investigators will “review the extent of potentially inappropriate payments for E/M services and the consistency of E/M medical review determinations.” The OIG also plans to hone in on whether payments for E/M services performed during the global periods of other procedures were appropriate.

In addition, the OIG will scrutinize Medicare payments for Part B imaging services, outpatient physical therapy services, sleep testing, diagnostic tests, and claims with modifier GY on them (Item or service statutorily excluded, does not meet the definition of any Medicare benefit or, for non-Medicare insurers, it is not a contract benefit).

The OIG also intends to “review Medicare payments for observation services provided during outpatient visits in hospitals” to assess whether hospitals’ use of observation services affects Medicare beneficiaries’ care.

Keep your compliance plan up to date with tips from Part B Insider,...

CMS clears up flu shot coding confusion.

You’ve heard the advantages of participating in CMS’s Electronic Health Record (EHR) Incentive Program (including $44,000 per-physician bonus incentives over a five-year period), but you may not be sure how to enroll.

CMS staffers cleared up that confusion during an Oct. 5 open door forum, where CMS’s Rachel Maisler indicated that you must register on CMS’s EHR incentive program’s Web site, which will open in January 2011 for the Medicare program.

In addition, you must be enrolled in CMS’s PECOS system and have an NPI, and you must use certified EHR technology. You can find details on how to determine which EHR systems are certified on www.healthit.hhs.gov.

Key dates: During the call, CMS reps also announced important dates involved in EHR participation. “Attestation, which is how you will report the objectives and measures for meaningful use and clinical quality measures, will begin in April of 2011, and we expect the first payments will be made in May of 2011,” Maisler said.

Look for Combined Flu Shot

Flu vaccine: Now that the H1N1 immunization is part of the regular flu vaccine, a caller asked the CMS officials whether a new code will be developed to describe the combined flu shot, but CMS officials noted that no such code will be issued.

“We’re continuing to use the same codes as last year, and my understanding is the H1N1 is part of the regular flu vaccine this year, so you’d bill what the appropriate flu vaccine code is,” said CMS’s Amy Bassano, during the call. High-dose flu vaccine code 90662 (Influenza virus vaccine, split virus, preservative free, enhanced immunogenicity via increased antigen content, for intramuscular use) has been added to the roster of codes that can be billed to Medicare, Bassano confirmed.

RACs: Another caller...

Don’t miss out on extra pay when global period resets.

Just because you routinely append modifiers to your claims doesn’t mean you’re filing correctly and getting the most appropriate pay. Brush up on your modifier know-how with these tips for three of the trickiest choices: modifiers 58, 78, and 79.

Selecting between these modifiers can be carrier-specific in some situations, says Jacqui Jones, office manager for Benjamin F. Balme, MD, PC in Klamath Falls, Ore.

Remember All Possible Uses for 58

The descriptor for modifier 58 seems self-explanatory: Staged or related procedure by the same physician during the postoperative period. Coders sometimes trip, however, when they forget that modifier 58 actually applies to subsequent procedures that fall into one of three categories:

Planned or anticipated (staged):  A good example might be an infected hand that has to be debrided several times over the course of a couple of weeks. You won’t use a modifier on the first procedure, but will add modifier 58 on the subsequent procedures.

More extensive than the original procedure: The physician manipulates a patient’s ulnar fracture. An x-ray at the follow-up appointment shows that the reduction failed, so the physician completes pinning or an open reduction with internal fixation (ORIF). Code the procedure as needed (with 25545, Open treatment of ulnar shaft fracture, includes internal fixation, when performed, for example) and append modifier 58.

Therapy or treatment following a surgical or diagnostic procedure: This could apply to a soft tissue biopsy followed at a later date by malignant tumor excision.

You’ll only append modifier 58 to the second procedure if it occurs during the first procedure’s global period. The date of the second procedure resets the global period. You should expect 100 percent reimbursement for procedures you file with modifier 58.

Verify ‘Surprise’ Before Reporting 78...

Only report primary procedure – except for 99455 edits.

The latest version of the National Correct Coding Initiative (CCI) edits went into effect October 1, and introduced a slew of pairings involving two new Category III “T” codes for transforaminal epidural injections:

• 0228T – Injection(s), anesthetic agent and/or steroid, transforaminal epidural, with ultrasound guidance, cervical or thoracic; single level
• 0230T – Injection(s), anesthetic agent and/or steroid, transforaminal epidural, with ultrasound guidance, lumbar or sacral; single level.

Explanation: “The new Category III codes 0228T-0231T have added the addition of ultrasound guidance to transforaminal epidural injections,” says Susan Vogelberger, CPC, CPC-H, CPC-I, CMBS, CCP-P, CEO of Healthcare Consulting and Coding Education in Boardman, Ohio. “That will eliminate the need to code the ultrasound independently.” The existing, Category I codes for transforaminal epidural injections of anesthetic and/or steroids (64479-64484) include only the injection itself.

Even Simple Procedures Rule With NME Edits

CCI classifies the bulk of edits involving 0228T and 0230T as non-mutually exclusive.

No breakage: The rationale behind the new bundling edits falls to “standards of medical/surgical practice.” Most edits carry a modifier indicator of “0,” which means you cannot break the edit with a modifier and report both codes during a single encounter.

Examples of common procedures that override the accompanying 0228T or 0230T codes include:

• Incision and drainage (such as 10060, Incision and drainage of abscess (e.g., carbuncle, suppurative hidradenitis, cutaneous or subcutaneous abscess, cyst, furuncle, or paronychia); simple or single)
• Foreign body removal (such as 10120, Incision and removal of foreign body, subcutaneous tissues; simple) Lesion paring (such as 11055, Paring or cutting of benign hyperkeratonic lesion (e.g., corn or callus); single lesion)
• Skin tag removal (beginning with 11200, Removal of skin tags, multiple fibrocutaneous tags, any area; up to and including 15 lesions)
• Lesion shaving (including 11300,

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