Keeping Specialists Compliant POSSIBLE RISK FACTORS By Melody W. Mulaik, MSHS, CRA, FAHRA, RCC, CPC, CPC-H can sometimes be difficult to select a topic for this column that will appeal to all of our readers. my goal is to always write about something that is relevant to a billing company regardless of its coding model. This article, though, will highlight some key areas of concern that tend to impact “specialists,” or medical practitioners who focus on a particular class of disease or patients. Here is how this ties into billing. accompanying the designation of “specialist” comes the risk of feeling either protected or above other medical specialties when it comes to coding and billing practices. (Note that I indicated that this is a risk and not a generalization about all specialists.) This article, then, will focus on three coding and compliance risks that tend to exist for specialists in today’s healthcare environment: electronic medical records (emrs), evaluation and management (e&m) coding, and billing an e&m in conjunction with a minor procedure. The topics that follow could each be the subject of a separate column. For this article’s purpose, I will simply provide highlights that will allow you to facilitate evaluation and discussion in your organization and with your clients. RISK NUMBER 1: EMRs In the january/February edition of Billing, I wrote an article titled “Top 10 Coding and Compliance list for 2014.” Number two on that list was the improper use of emrs. although we are almost halfway through 2014, this placement is still warranted. With meaningful use incentives and the overall industry departure from the inefficiencies of paper, most physician practices have implemented emrs. even those groups that have not yet implemented a system are most likely in the final stages of selection. If you have a client who still refuses to implement an emr, you may be concerned about their long-term survival in the marketplace. They may even be looking to join or be purchased by a larger healthcare entity. either way, this could impact your contractual relationship and the need for your services, so I recommend you view the disinterest in using an emr as a red flag (but that is a subject for a different article). 34 HBma BIllINg • maY. juNe.2014 It is very important that emrs be used as a tool to capture clinical information for all necessary purposes to provide the best care for the patient. an emr is not a shortcut or a replacement for clinical decision making. It also is not the answer to just about any other problem that can exist in a physician practice. as we constantly say, there are some great emrs available, but there are some not-so-great ones as well. emrs should not be utilized to generate cloned notes, inappropriate templates, or other documentation that create concerns for their potential for fraud or abuse. The Office of Inspector general’s (OIg) 2014 Work Plan has finally been released, and, once again, this issue is on its target list. specifically, OIg highlights that “medicare contractors have noted an increased frequency of medical records with identical documentation across services.”1 The focus is not only on the services provided to a beneficiary for a specific encounter compared with other patients. It is also across multiple dates of services to ensure that each encounter is uniquely documented and not just pulled from a previous encounter without appropriate updating and validation. even though specialists may only treat a limited number of conditions or provide some of the same treatments for their patients, this does not mean that all of the clinical documentation should and would be the same for all patients. If you and I were to go to the same specialist for the same condition, wouldn’t you expect our medical record documentation to be different even if we received the same treatment? It is critical you understand how your clients are utilizing their emrs to ensure accurate and compliant billing practices. It is not in your clients’ best interest as their billing partner to reinforce the belief that just because someone is a specialist they are either exempt from certain compliance concerns or they are justified in doing whatever is easy to save time. as their partner, you want to provide support and guidance so that both of you may reap the benefits of your hard work. RISK NUMBER 2: E&M billing levels For your reference, this issue was number four on the “Top 10 It
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