Most physicians are familiar with the MIPS quality models: These are the Physician Quality Reporting System (PQRS) measures that we’ve been reporting for years with the old Medicare value-based purchasing program. What we don’t know much about are the new cost efficiency models in MIPS, which are based solely on hospital and physician ICD-10-CM/CPT claims data rather than a clinical abstraction of our medical records.
Documentation and coding based on time requires knowledge about the general principles of E/M documentation, common sets of codes used to bill for E/M services, and E/M services providers.
Physicians may be angry at the increased documentation, coding, and billing workflow and compliance activities they must perform to be successful in new reimbursement models. However, to avoid accustations of fraud and upcoding, they must develop their own OIG-recommended compliance plan and be open to rigorous feedback and advice.
Currently, there are no national guidelines for how facilities should assign evaluation and management (E/M) levels in the emergency department (ED). Under Medicare’s ambulatory payment classification (APC) system, facilities create their own internal guidelines for determining the ED visit level, and each facility must follow its own system to demonstrate compliance.
This week's note reviews pre-service coverage analysis processes in light of the recent CMS decision to delegate the target, probe, and educate medical review strategy to the Medicare Administrative Contractors.
Patient care continues to move from the inpatient setting to outpatient. With this change, the challenge of securing comprehensive documentation that articulates the services rendered and the patient care provided now needs to extend across the care continuum.
