The 2016 CPT® code update may have been relatively small compared to previous years, but the urinary and genital system sections did receive numerous changes to align them with other sections of the code book.
In celebration of our 30th year of delivering you the latest in HIM, we continue to reflect on what HIM was like 30 years ago, examine today's HIM landscape, and look to the future.
by Shannon Newell, RHIA, CCS, AHIMA-approved ICD-10-CM/PCS trainer
Approximately 800 hospitals across the country that perform inpatient total hip and knee joint replacements will be required to participate in the latest value-based payment initiative launched by CMS, the Comprehensive Care for Joint Replacement (CJR) model, which becomes effective April 1.
A recent Healthcare Financial Management Association webinar on the CJR noted it as one of the biggest Medicare changes since the implementation of diagnosis-related groups (DRG). Not surprisingly, various impacted parties continue to push for delays in implementation of the model. The CJR model holds participant hospitals financially accountable for the cost and quality of an episode of care and incentivizes increased coordination of care among hospitals, physicians, and postacute care providers.
The assignment of ICD-10 codes on both inpatient and outpatient claims impacts these outcomes by triggering which discharges are included in the program, the actual (or observed) complication rates for these patients, and?equally important but often overlooked?their risk-adjusted expected complication rates. If ever there was an opportunity for clinical documentation improvement (CDI) programs to step up to support their organizations with documentation that impacts both quality and financial outcomes, this is it!
Despite industry pushback and several delays, ICD-10 implementation has, against all odds, gone relatively smoothly for the vast majority of providers, leading CMS to tout its success in a recent blog post from Andy Slavitt, CMS’ acting administrator.
CMS won’t release guidance on the payment impact of Section 603 of the Bipartisan Budget Act of 2015 until the 2017 OPPS proposed rule, but the American Hospital Association (AHA) has weighed in with a letter to Congress urging the government to reject further site-neutral payment policies.
CMS giveth and CMS taketh away. More than $21 billion in payments under the Medicare EHR Incentive Program and more than $10.1 billion in Medicaid EHR Incentive Program payments has been doled out between 2011 and 2015?but not every payment remains with its intended recipient. Contractors will perform audits to ensure that those eligible for the program can support their attestation through examination of supporting documentation to back a claim that a provider or hospital has fulfilled the requirements for meaningful use.
CMS contracted Figliozzi and Company to conduct pre- and postpayment desk audits of the meaningful use program.
"What we have been seeing from our clients' experience is Figliozzi is attempting to perform audits on 5% of attestations submitted to CMS," says David Holtzman, JD, CIPP, vice president of compliance at CynergisTek, Inc., in Austin, Texas.
Holtzman also notes a spike in state Medicaid offices and the Office of Inspector General (OIG) performing audits for those attesting to meaningful use. These audits are conducted on site by a team of auditors.
"Both Medicaid and Medicare meaningful use audits are pass-fail audits," Holtzman says. "Therefore, if any requirement or measure is not met, the result is that the provider or hospital will not receive the incentive payment in the case of a prospective audit or will be required to return any payment received for the prior period as a result of the audit."
Under the Affordable Care Act, the latter would be considered an overpayment by Medicare or Medicaid, and the provider or organization would be required to return the incentive dollars within 60 days or face fines and penalties subject to the False Claims Act.
"There is increased attention by the U.S. Attorney's Office and the Office of Inspector General for investigating and prosecuting fraudulent attestations for meaningful use that results in incentive payments," Holtzman says. "I look at this as a claims recovery effort."
CMS may occasionally report on overall rates of audit failure by eligible providers and hospitals. However, it will not provide any specific guidance on how to resolve identified issues, Holtzman says. "Once the reporting year has ended, the attestation is filed or the hospital/provider selected for audit, no substantive changes are permitted," he says. "Best practices are to carefully review documentation for meaningful use attestation using internal experts or bring in a third-party reviewer to ensure accuracy."
As we celebrate our 30th year of delivering you the latest in HIM, we would like to invite you to celebrate the HIM profession with us. Each month this year, HIM Briefings (formerly Medical Records Briefing) will include a special feature that highlights the changes to our publication and the HIM profession over the years.
The Joint Commission's September 2015 Perspectives encourages "hospitals to design systems to ensure accurate and complete medical records." Although this is not a new concept, it becomes more important as more hospitals' medical records become electronic while still maintaining a certain amount of paper documentation.
HIM Briefings (formerly Medical Records Briefing) asked HIM and release of information (ROI) professionals about their ROI practices for its first quarterly benchmarking survey of 2016. (The survey was completed in October 2015.) We introduced several new questions this year about the medical record itself as well as ROI practices.
