September/October 2012 MBJ

MEDICAL BUSINESS JOURNAL

Sept/Oct 2012 Issue 6 Volume 3

The Monthly Newsletter for the Informed Healthcare Professional

In this Issue 2.......................................................………….............................................New Learning Platform 2.......................................................................….......………................Medical Audit Certification 2.........................................................................................………………………...........Gain CEUs 3..........................................................................................................................CMS News Updates ICD-10 Delay New Procedure Codes Collaborative Initiative 4.......................................................................................................….…..The Dispensary of Hope 5...................................................................................…...............2013 Psychotherapy CPT Codes 8.....................................................................................................…......Recovery Audit Contractor 8................................................................…..... Introducing the 2013 RMA Certification Program 9.......................................................…….….................Interview with Secretary Kathleen Sebelius 10........................….........................................................…....................Donate your Coding Books

MEDICAL BUSINESS JOURNAL Sept/Oct 2012

Medical Management Institute Updates Introducing the RMA Medical Auditing Certification

Continuing Education Contribute for CEUs

The Medical Management Institute is proud to introduce the 2013 Registered Medical Auditor (RMA) Certification Program. This is a 6 month, online, work at your own pace program, available on the new learning system Learner Nation. For more information on this program and how to enroll (with a member discount) check out the article on page 8 of this issue. As always, please feel free to speak with a member services representative at 866-892-2765, or email info@mmiclasses.com.

As stated in the last MBJ, we are now administering CEUs for contributing articles.

We are always looking for a new perspective, story, or update, especially from our loyal students and alumni. Details follow:

Learner Nation New learning platform The Medical Management Institute is shifting over to a groundbreaking new learning platform called Learner Nation. With this change, you will want to take note that you will be receiving emails from “hello@learnernation.com.” Please don’t delete these! These emails will contain important information such as log in instructions for CEU courses and programs, as well as any receipts or paid invoices. Feel free to email info@mmiclasses.com with any questions or concerns!

Learner Nation is a powerful yet simple learning management system, offering interactive learning tools to help engage the user. The image to the far right is a screenshot of part of the online program.

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Benefits (if your work is chosen): • 2 CEUs for 1 page article (790 words, 10 pt font) • 4 CEUs for 2 page article (1,580 words, 10 pt font) • Your work in a nationally distributed publication Topics to write about • Coding updates • Industry news • Upcoming events • Helpful resources • “Day in the life of a…” (medical coder, manager in a physician’s office, etc.)

For more details: For more details on what to write about or how to submit work, contact Carleigh Benscoter by email at mbj@mmiclasses.com, or call 866-892-2765 extension 240.

ICD-10 Delay The implementation date is Oct.1, 2014

The only new ICD-9-CM code added for 2013 is 00.95- injection or infusion of glucarpidase

The implementation date of ICD-10 was officially delayed from October 1, 2013 to October 1, 2014 by final rule CMS-0040 F issued on August 24, 2012. This delay was originally proposed in April, and was put in place to allow healthcare organizations (small organizations in particular) the time needed to prepare for the transition. This delay will also allow for covered entities to be able to avoid costly obstacles.

This new implementation date is part of the process of simplifying administrative regulations.

New Procedure Codes Three new codes Because of the partial freeze implemented by the ICD-9-CM Coordination and Maintenance Committee, there were only limited code updates to both the ICD-9-CM and ICD-10 code sets on October 1, 2012. The only new ICD-9-CM code added for 2013 is 00.95-

injection or infusion of glucarpidase.

This code was implemented on October 1, 2012 because it was not finalized in time to be included in the FY 2013 IPPS/LTCH PPS proposed rule, previously discussed at the March 5, 2012 ICD-9-CM Coordination and Maintenance Committee meeting. There were

MEDICAL BUSINESS JOURNAL Sept/Oct 2012

CMS News Updates

also two new ICD-10-PCS codes for Introduction of Glucarpidase via percutaneous approach, which are 3E033GQ (into peripheral vein) and 3E043GQ (into central vein).

Although these were the only additions, there were 262 title revisions. Check them out by visiting www.cms.gov.

costly and avoidable hospitalizations for this population that often has the most complex health care needs.� It On September 27, CMS announced will be run collaboratively by the seven cooperative agreement awards CMS Medicare-Medicaid partnering with 145 nursing facilities Coordination Office and the center to implement the Initiative to Reduce for Medicare and Medicaid Avoidable Hospitalizations among Innovation, both created by the Nursing Facility Residents. According Affordable Care Act. Implementation to Acting Administrator Marilyn will begin later this year at 145 Taverna, this initiative and the nursing facilities. For more enhanced level of collaboration it will information on the initiative, visit generate among a variety of http://innovations.cms.gov/ providers is “the key to reducing initiatives/rahnfr/.

Collaborative Initiative Improves care

7 Organizations were Selected Alabama Quality Assurance Foundation, Alegent Health, HealthInsight of Nevada, Indiana University, The Curators of the University of Missouri, The Greater NY Hospital Foundation, Inc., UPMC Community Provider Services

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MEDICAL BUSINESS JOURNAL Sept/Oct 2012

The Dispensary of Hope

Working to empower the poor & vulnerable

By Carleigh Benscoter, ARHCP

“We believe that providing access to affordable medicine empowers poor and vulnerable individuals with a renewed freedom to achieve their dreams. Our mission is to provide affordable medicine to every patient, on every continent…starting right here.” This is the Dispensary of Hope’s mission statement, a notfor-profit social venture working to provide sustainable access to medicine for underinsured communities.

“We believe that providing access to affordable medicine empowers poor and vulnerable individuals with a renewed freedom to achieve their dreams. Our mission is to provide According to a study in the May-June issue of affordable medicine to every patient, on the Journal of the American Board of Family every continent...starting right here.”

Medicine, there is currently around $2 billion in The Dispensary of Hope sample medications going unused each year.

The idea behind this organization is to work with healthcare providers, clinics, and The physician practice benefits as well, pharmaceutical companies nationwide to completely bypassing the “de-logging” process obtain unused and soon-to-be expired of disposing of expired drugs by donating them pharmaceutical sample medications, and to instead. The donor practice simply places the redistribute these to low-income and uninsured drugs in a secured box provided by the service (shipping costs covered), and you are then sent patients at safety net clinics. an itemized receipt of all the medications you According to dispensaryofhope.org, the charity donated. uses two programs to provide patients with Learn more about this innovative instant and continued access upon receiving organization by visiting donated sample medications; the Instant Access dispensaryofhope.org/ Program and the Continued Access Program.

Need meds, but don’t have a prescription?

Contact a local access site to get the medical care you need and the medications to help you get better. Visit dispensaryofhope.org to see the list of access sites.

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The Instant Access Program gives the patient immediate access to medications at a clinic or pharmacy, while the Continued Access Program provides the patient with access to medications on an ongoing basis.

By Daniel Street, CCS, Chart Auditor

The American Medical Association has announced that there will be significant changes for the coding and billing of almost all psychiatric services beginning on January 1, 2013. These changes will require significant modifications to behavioral health agencies’ workflows, billing processes, and practice management systems.

The summary below is from a chart published by the AMA. Most significantly, code 90862 (Pharmacologic Management) has been eliminated, probably with the expectation that psychiatrists will use general evaluation and management codes (99xxx series) instead. These codes are used by most physicians, but have not generally been used in the behavioral health setting.

In addition, AMA accepted the following coding changes: • Establishment of code for pharmacologic management with concurrent deletion of code 90862; • Revision of Psychiatry guidelines; • Addition of code 908XE for interactive complexity; • Deletion of codes 90804-90809, 90810-90815, 90816-90822, 90823-90829, 90857; • Addition of codes 908P10, 908P10X, 908P20, 908P20X, 908P30, 908P30X, • 908CP2, 908CP2 for psychotherapy; and • Revision of codes 90875, 90876 The Medical Management Institute encourages behavioral health agencies to develop an action plan to: • Update charge forms and masters • Ensure that electronic systems are updated

• Provide training and technical assistance to clinical and business office staff • Establish communication with payers regarding changes

The American Psychiatric Association is attempting to notify payers of these impending changes. However, given that psychiatry has not generally used evaluation and management codes, it is possible that initially there will be some confusion and rejection of claims, or other adverse action.

MEDICAL BUSINESS JOURNAL Sept/Oct 2012

2013 Psychotherapy CPT Codes Effective January 1, 2013

Beginning January 1, 2013, all mental health professionals must use new CPT® code numbers for psychotherapy when billing clients and filing health insurance claims with all third-party payers, including Medicare, Medicaid and all private health insurance carriers. Information about Medicare payment rates associated with the new codes is expected to be released in November when the Centers for Medicare and Medicaid Services (CMS) announces the final Medicare fee schedule for 2013.

Importantly, the coding changes in store for 2013 involve only the psychotherapy family of codes — the codes found in the Psychiatry section of the 2013 CPT® manual. There are no changes to other codes that psychologists use, such as testing or health and behavior codes.

Following are 2 documents covering the 2013 Psychotherapy CPT codes, provided by the American Psychological Association Practice Organization.

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MEDICAL BUSINESS JOURNAL Sept/Oct 2012

Putting Your Practice Assessment to Work

2013 Psychotherapy CPT速 Codes for Psychologists Effective January 1, 2013

Diagnostic interview procedures 90791

Psychiatric diagnostic evaluation Psychotherapy

90832

Psychotherapy, 30 minutes with patient and/or family member

90834

Psychotherapy, 45 minutes with patient and/or family member

90837

Psychotherapy, 60 minutes with patient and/or family member

90845*

Psychoanalysis

90846*

Family psychotherapy without the patient present

90847*

Family psychotherapy, conjoint psychotherapy with the patient present

90849*

Multiple-family group psychotherapy

90853*

Group psychotherapy (other than of a multiple-family group)

90785

Interactive complexity add-on code Add-on code to be used in conjunction with codes for primary service: psychiatric diagnostic evaluation (90791); psychotherapy (90832, 90834, 90837); and group psychotherapy (90853) Psychotherapy for crisis

90839

Psychotherapy for crisis, first 60 minutes

90840

90863

Add-on for each additional 30 minutes of psychotherapy for crisis, used in conjunction with code 90839 Pharmacologic management add-on code Pharmacologic management, including prescription and review of medication, when performed with psychotherapy services; used only as add-on to primary psychotherapy code (90832, 90834, 90837)

* The codes shaded in orange are the same for 2012 and 2013

Current Procedural Terminology速(CPT) copyright 2011 American Medical Association. All Rights Reserved.

The CPT manual is available for purchase from the American Medical Association online or by calling toll-free, (800) 621-8335.

For complete information on the 2013 psychotherapy codes, visit www.apapracticecentral.org/codes.

For additional questions, email us at praccodes@apa.org.

American Psychological Association Practice Organization Practitioner Helpline: 800-374-2723 TDD/TTY: 202-336-6123

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Crosswalk of 2012 Psychotherapy CPT® Codes to 2013 Codes Effective January 1, 2013

2012 Code

2013 Code(s)

Diagnostic interview procedures 90801, Psychiatric diagnostic interview 90791, Psychiatric diagnostic evaluation examination Psychotherapy 90804, outpatient psychotherapy 20-30 min 90832, Psychotherapy, 30 minutes with patient 90816, inpatient psychotherapy 20-30 min and/or family member 90806, outpatient psychotherapy 45-50 min 90834, Psychotherapy, 45 minutes with patient 90818, inpatient psychotherapy 45-50 min and/or family member 90808, outpatient psychotherapy 75-80 min 90837, Psychotherapy, 60 minutes with patient 90821, inpatient psychotherapy 75-80 min and/or family member 90845,* Psychoanalysis

90845, Psychoanalysis

90846,* Family psychotherapy without the patient present 90847,* Family psychotherapy, conjoint psychotherapy with the patient present

90846, Family psychotherapy without the patient present 90847, Family psychotherapy, conjoint psychotherapy with the patient present

90849,* Multiple-family group psychotherapy

90849, Multiple-family group psychotherapy

MEDICAL BUSINESS JOURNAL Sept/Oct 2012

Putting Your Practice Assessment to Work

90853,* Group psychotherapy (other than of a 90853, Group psychotherapy (other than of a multiple-family group) multiple-family group) Codes for interactive services 90802, Interactive psychiatric diagnostic 90791 plus interactive add-on code (90785) evaluation All current interactive psychotherapy services 90785, Add-on code to be used in conjunction (90810 – 90815, 90823 – 90829) with appropriate psychotherapy code based on length of the session 90857, Interactive group psychotherapy 90853 plus interactive add-on code (90785) Pharmacologic management add-on code 90862, Pharmacologic management, including 90863, Pharmacologic management, including prescription, use and review of medication with prescription and review of medication, when no more than minimal medical psychotherapy performed with psychotherapy services; used only as add-on to principal psychotherapy code (90832, 90834, 90837) * The codes shaded in orange are the same for 2012 and 2013 Current Procedural Terminology®(CPT) copyright 2011 American Medical Association. All Rights Reserved.

The CPT manual is available for purchase from the American Medical Association online or by calling toll-free, (800) 621-8335.

For complete information on the 2013 psychotherapy codes, visit www.apapracticecentral.org/codes.

For additional questions, email us at praccodes@apa.org.

American Psychological Association Practice Organization Practitioner Helpline: 800-374-2723 TDD/TTY: 202-336-6123

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MEDICAL BUSINESS JOURNAL Sept/Oct 2012

Recovery Audit Contractor Audits 101

By Daniel Street, CCS, Chart Auditor

Do the names Diversified Collection Services, CGI Group, Connolly, HealthDataInsights, and PRG Shultz ring a bell? Sounds like a friendly Medical Consulting Company down the street. In reality, these could be your practice's worst nightmare! These groups are contractors for the Medicare RAC audit program. The RAC program is the CMS’s cost containment program aimed at reducing improper payments with the Medicare program. RACs collected over $797 million in Medicare overpayments in Fiscal Year 2011.

The contractor accomplishes its mission by auditing providers looking for overpayments and in theory underpayments. We say "in theory" for underpayments, because these contractors are compensated based on a percentage of monies recovered and underpayments are actually an offset.

The bad news is that the contractors have an incentive to find the overpayments and ignore the underpayments. Add this to the fact that the RAC auditor uses a sampling methodology to determine the amount of the overpayment. If they find an overpayment for a particular billing code in a sample of claims, they can then extrapolate against all of your claims with that billing code. You can see that this formula can easily result in a significant overpayment calculation. So, what can you do if you receive a letter from one of these RACs?

First, don’t panic. It’s going to happen to almost every practice sooner or later. Contact an attorney.

Second, understand the rules of a RAC audit. To conduct the audit, RACs will request patients’ medical records. RACs link the number of records they request from a practice to your NPI number. For a practice with two to five physicians, RACs can examine 20 records per billing NPI, per 45-day period. RACs limit record requests from solo practitioners to 10 records per 45-day period. In addition, CMS guidelines permit RACs to review physicians’ evaluation and management (E/M) coding and documentation for up to three years prior to the date of the initial payment.

Third, ask for an extension so you can audit yourself first or hire an external auditing company to come in and do it for you. Make sure that when responding to a RAC audit you submit all records in a timely manner and meet all deadlines. You can send additional information with your response that describes your practice, expertise, and any adverse selection of patients with severe conditions that may have affected the billing and coding of your claim.

Fourth, appeal if the RAC audit does not match up with your internal audit or you feel there may be other circumstances making the RAC audit in any way inaccurate.

Introducing: The Registered Medical Auditor Certification Program Medical Management Institute

RMA Program

Learner Nation

Through the Medical Management Institute’s online certification program, you will understand coding concepts and medical record auditing as seen through a medical auditor’s eyes.

This program is on the new groundbreaking learning platform called Learner Nation. Learner Nation uses interactive learning tools to accommodate every learning style, uses a points and reward system to keep you motivated, and integrates Facebook to create a one-of-a kind learning community.

This course covers: • • • • • •

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Human anatomy, medical and clinical terminology Medical record audit environment & resources Healthcare payors 101 Compliance plans & leadership management Audits (internal & external) Audit examples, sample forms & templates

Enroll Now Visit promos.mmiclasses.com/rma-mbj/ to check out the program and have your questions answered. If you enroll from there, you will receive a $100 discount! Or you can place the order over the phone by calling 866-892-2765, using promo code “MBJAudit100” for the discount.

Secretary of HHS, Kathleen Sebelius on ICD-10-CM Delay BC Advantage

BC Advantage (BCA): Some health care providers and physician practices in particular, have seen the shift to ICD-10-CM diagnostic coding as an expensive, timeconsuming, and unnecessary burden since it was first announced. Originally, it was to be implemented in October 2013, and HHS has now extended the implementation date to October 2014. What is the rationale for this one-year delay?

provide cost effective approaches to delivering health care, and supply us with information for better research.

Any further delay would postpone the opportunity to reap those benefits.

BCA: What, if any, effect does the potential ICD-11 coding system have on the current and future status of ICD-10?

Secretary Kathleen Sebelius (KS):Let me begin by saying that a number of providers and provider associations support the transition to ICD-10. They recognize that ICD-9 is outdated and that the industry's use of ICD-10 will provide data to improve health care, provide cost effective approaches to delivering health care, and supply us with information for better research.

But at the end of last year and early this year, three issues emerged that led us to reconsider the compliance date for ICD-10. First, the industry's transition to Version 5010 had some hiccups. Second, providers expressed concern that other statutory initiatives were stretching their resources. Lastly, after examination of data, we felt providers were not yet ready for the ICD-10 transition.

In the April 2012 proposed rule, which proposed delaying ICD-10 implementation, we examined a number of options. Based on our analysis and public comments on that proposed rule, we found that to go forward with the original compliance date could risk disruptions on a number of levels, while a delay of any more than a year would incur costs that could not be justified. Many sectors of the U.S. health care industry, including providers, have invested heavily in order to meet the regulatory requirements, and continued delays would negatively affect every level of the health care industry.

BCA: What would you tell skeptical health care providers who put off training because they expect additional implementation delays?

KS: We do not expect any further delays of the ICD-10 compliance date. The delay until October 1, 2014 is based on a number of very specific circumstances, and we want to ensure that ICD-10 is implemented without further delay because further delays would be costly to the industry at large. ICD-10 is integrated into other ehealth initiatives and, as stated earlier, we anticipate it will contribute to improved quality and outcomes data,

MEDICAL BUSINESS JOURNAL Sept/Oct 2012

Excerpt from BC Advantage’s Exclusive Interview

Secretary of Health & Human Services, Kathleen Sebelius

KS: ICD-11 is still in an early stage of development and isn't available in a version that can be analyzed in any comprehensive sense. Right now, we’re focused on the implementation of ICD-10 so that patients, providers, researchers, and the nation as a whole can benefit from this new coding system.

To read the entire interview, visit www.billing-coding.com. BC Advantage goes on to ask about ICD-10, ICD-11, RAC and ZPIC programs, Medicare, Affordable Care Act, The HEAT (Joint effort program between DOJ, HHS, and CMS) Program and much more. Subscribe to BC Advantage Magazine today, and receive 6 x ICD-10 webinars at no additional cost. Visit www.billing-coding.com/subscribe.

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MEDICAL BUSINESS JOURNAL Sept/Oct 2012

Books for Soldiers Donate your books!

Do you have any coding books lying around not being used? Donate them to the deployed men and women of our armed services!

Booksforsoldiers.com is a nonprofit organization dedicated to supporting those in the US military who are deployed outside the United States. Military personnel are invited to make requests, and members read the requests and fill them. Booksforsoldiers.com receives no government support, and limited corporate support. It is made possible due to the generosity of its members.

You can send your books, along with any old DVDs and supplies directly to a platoon. Just visit booksforsoldiers.com to learn more and get involved.

Save Books for Soldiers

DONATE MEDICAL BUSINESS JOURNAL Medical Management Institute Preston Ridge Road Suite 380 Alpharetta, GA 30005 866-892-2765 www.mmiclasses.com info@mmiclasses.com

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You can donate old books, DVDs, and even supplies directly to the platoons requesting them, or you can donate money directly to the organization. www.booksforsoldiers. com.

Editor-in-Chief: Carleigh Benscoter Copy Editor: Rob Hassett, RMC, Julia Scott, RMC, Carleigh Benscoter Contributors: Bobby Keene, Rob Hassett, Carleigh Benscoter, Daniel Street, CCS Layout and Design: Carleigh Benscoter The Medical Business Journal is a monthly source of up-to-date information on all issues aecting the healthcare industry. Its content ranges from medical coding and billing to healthcare reform legislature and beyond. The MBJ is not aďŹƒliated in any way with the Department of Health and Human Services, Medicare, or the Centers for Medicare and Medicaid Services. This publication is designed to provide accurate and authoritative information with regard to the subject matter covered. It is sold with the understanding that the publisher is not engaged in rendering legal, accounting or other professional services, and is not a substitute for individualized expert assistance. The CPT codes, descriptors, and modifiers are copyrighted by the American Medical Association. For more information, please call MMI at: (866) 892-2765