HIM Briefings

Q: Can I leave a patient a voicemail about an MRI procedure, including the time and date? What should I do if someone else at the patient's home answers the phone? How much info can I leave with the other person, and how can I verify that person's identity and relation to the patient?

Observation services are an ongoing point of confusion for hospitals and patients, many of whom have become fearful of out-of-pocket costs and SNF coverage eligibility associated with outpatient observation services. Developing a workflow to comply with the Notice of Observation Treatment and Implication for Care Eligibility (NOTICE) Act and the Medicare Outpatient Observation Notice (MOON) is essential and is intended to help hospitals ease patients' concerns by clearing up the implications of observation.

The FY 2017 IPPS proposed rule released April 27 is replete with modifications and expansions to claims-based quality and cost outcome measures. Although many of these proposed changes are for future fiscal years, ICD-10 codes reported for current discharges will impact the future financial performance for our organizations.

Cost measures

Two new payment measures are proposed as additions to the efficiency and cost reduction domain beginning in FY 2021:

• Hospital Level, Risk-Standardized Payment Associated with a 30-Day Episode-of-Care for Acute Myocardial Infarction
• Hospital Level, Risk-Standardized Payment Associated with a 30-Day Episode-of-Care for Heart Failure

CMS cites the following site for full measure specifications: www.cms.gov/Medicare/Quality-Initiatives-Patient-assessment-Instruments/HospitalQualityInits/Measure-Methodology.html.

The risk adjustment methodologies used for these measures are similar to those used for risk-adjusted mortality. The payment measure is intended to be paired with the 30-day mortality measures, thereby directly linking payment to quality by the alignment of comparable populations and risk adjustment methodologies to facilitate the assessment of efficiency and value of care.

The baseline period for these measures is July 1, 2012, through June 30, 2015. The performance period for these measures is July 1, 2017, through June 30, 2019. Performance for these new measures will be scored using the methodology used for the Medicare Spending Per Beneficiary measure.

CMS expands on its interest to further integrate quality and cost measures to reflect value, and is seeking public input on potential approaches. Underlying present challenges in reflecting value are noted as follows:

• Currently, the HVBP assesses quality and efficiency separately through distinct performance measures in different domains, which as of FY 2018 are equally weighted to create the overall Total Performance Score. The four domains include:
  • Safety
  • Efficiency and cost reduction
  • Clinical care
  • Personal and community engagement
• The current scoring approach can permit a hospital to earn a higher payment adjustment relative to other hospitals by performing well on quality-related domains without performing well in the efficiency and cost reduction domain, or vice versa.
• Without a measure or score for value that reflects both quality and costs, the ability to assess value is limited.

My HIM career began like many others?in frank conversation with a high school guidance counselor regarding career direction. I wanted to pursue a career in healthcare, but wasn't interested in direct patient care. Focused exploration led me to discover a degree in health information technology at my local college. Now, 30 years later, I'm celebrating a long and successful HIM career.

When compared to data from past surveys, HCPro's 2016 HIM director and manager salary survey revealed a harsh truth that many HIM professionals already know: There has been little movement in HIM manager and director salaries over the years.

This column is devoted to restraint and seclusion documentation; it provides support for, and a tool for, 100% review of patients in restraints and/or seclusion.

The Joint Commission and CMS have a common goal of reducing the use of restraints and seclusion in hospitals. Hospitals have come a long way in meeting this goal, and requirements for improvement (RFI) usually are received because of poor documentation in the medical record. Generally, recommendations result from lack of physician orders, physicians not seeing patients on-site, incomplete orders as to the reason for restraints and/or seclusion, and care plans not including the goal to remove patients from restraints and/or seclusion.

Often during surveys, there will be no patients in restraints or seclusion and the surveyors will ask for closed records to review. Once the medical record is closed, little can be done to correct documentation. Therefore, a solid open record review is essential to avoid recommendations.

A process for reviews

Review of open records of patients in restraints and/or seclusion can be performed in several ways. Of utmost importance is the development of a method to identify patients in restraints and seclusion on a daily basis, and to review new and recurring patients until they are discharged. For example:

1.Nurses, clinical documentation specialists, and tracer teams (plus others?) can review medical records each day to ensure documentation compliance

2.If the hospital has an EMR, HIM staff can review open records online to identify discrepancies in documentation and report back to each unit

3.HIM and IT staff can collaborate to develop a method of importing information directly from the EMR to identify documentation errors

Any of these methods should eliminate errors as long as they are corrected as soon as possible before patients are discharged.

Certain phrases just stick with you. The longer you reflect on an idea, the more inspired you are by the ways in which the concept can become relevant to your needs. 

The new modifier -PO (services, procedures, and/or surgeries furnished at off-campus provider-based outpatient departments [PBD]) and the alternative payment provisions under the Bipartisan Budget Act Section 603 are both related to off-campus PBDs but define "off-campus PBD" slightly differently.

CMS recently published FAQs on modifier -PO, giving providers valuable guidance on how the modifier will apply to hospital services. Last week, CMS also indicated that it will wait until the CY 2017 OPPS proposed rule provides further guidance on Section 603. Nevertheless, some of the guidance related to modifier -PO seems to indicate that CMS is trying to bring the requirements in line with off-campus PBDs covered by Section 603, rather than simply relying on preexisting regulatory definitions of off-campus departments.

Modifier -PO was adopted January 1, 2015, with a required use date of January 1, 2016. It was originally adopted as a modifier to track statistics and information related to hospitals' off-campus PBDs. The modifier nominally applies to all items and services provided in an off-campus PBD, according to the Medicare Claims Processing Manual, but there are some significant exceptions.

The recent FAQs make it clear that modifier -PO does not apply to non-OPPS services. These services include therapy and a few other services still paid on other fee schedules, noted with a status indicator A under the OPPS, as well as dialysis, which is paid under the ESRD PPS. This guidance would dovetail with Section 603, which arguably only applies to services that would otherwise be payable under OPPS, exempting them from OPPS and providing alternative payment. Additionally, because critical access hospital (CAH) services are not paid under the OPPS, the modifier will also not apply to any services at PBDs of a CAH.

Similarly, the FAQs and other guidance indicate modifier -PO is not used for off-campus emergency departments. This guidance is in line with Section 603, which excludes the off-campus alternative payment methodology from items and services furnished at dedicated emergency departments.