CMS Changes the Rules on Student Documentation
Joyce Will
RHIT, CDIP, CPC, CPCO, CDEO, AAPC Fellow
Physician Services Consultant
Health Information Associates
Anyone who has coded or reviewed documentation in a teaching facility is familiar with the Medicare Claims Processing Manual, Chapter 12, Section 100.1.1. This section of the manual contains the guidelines for teaching physicians.
Joyce Will, RHIT, CDIP, CPC, CPCO, CDEO, AAPC Fellow and Physician Services Consultant at Health Information Associates, touches on the upcoming changes CMS has made to these guidelines taking effect next month, in March 2018.
For years, teaching physicians have been following the rule which states: “the teaching physician may not refer to a student’s documentation of physical exam findings or medical decision-making in his or her personal note. If the medical student documents evaluation and management (E&M) services, the teaching physician must verify and redocument the history of present illness, as well as perform and redocument the physical exam and medical decision-making activities of the service.”
All of this changes in March 2018.
CMS has announced a major change to the teaching physician guidelines. The teaching physician will be able to verify documentation of any E/M component, performed by a medical student, rather than re-documenting this work.
This change does not mean the teaching physician is no longer required to perform the HPI, physical exam and medical decision-making components of an E/M service. It also does not change the requirement that any contribution and/or participation of a student must be performed in the physical presence of a teaching physician or resident.
So far, there has been no additional guidance on what will be an acceptable attestation by a resident or teaching physician when the documentation of a student is used to support a billable service.
Practices may want to contact their Medicare Administrative Contractor (MAC) for additional guidance prior to the March 5th effective date for this change.
Popular Posts
Query Tip: Query for Clinical Validation
When a practitioner documents a diagnosis that does not appear to be supported by the clinical indicators in the health record, a coder has four choices: (1) Code the diagnosis; (2) Ignore the diagnosis; (3) Generate a query to confirm clinical validation of a diagnosis; (4) Follow the facility’s escalation policy for clinical validation.
$30M Settlement for Medicare Advantage Upcoding
A California-based healthcare services provider and several of its affiliates have agreed to pay $30 million to resolve allegations they submitted inaccurate information about the health status of beneficiaries enrolled in Medicare Advantage Plans, according to the Department of Justice.
National Volunteer Week with HIA
Happy National Volunteer Week! This week we celebrate the impact volunteer work has on building stronger communities. We know that our staff have a positive impact while they’re on the job, and we are proud to share a few ways our #PeopleBehindTheNumbers are taking time to volunteer in their own local communities.
Challenges Facing ASCs in 2019
Scrutiny of coding compliance in the growing ambulatory surgical center (ASC) market has increased in recent years from both Medicare and private payers. This will only increase as the Centers for Medicare and Medicaid Services (CMS) moves towards value-based care.
Coding Tip: Acute Renal/Kidney Failure/Injury vs Dehydration as a Principal Diagnosis
Patients being admitted for acute renal failure due to dehydration have been happening for many, many years now. Typically what happens is a patient gets dehydrated for one reason or another. Once dehydration sets in, it can quickly start to affect many body organs. This can lead to acute renal/kidney failure/injury.
Subscribe to our weekly newsletter
Latest News
Query Tip: Query for Clinical Validation
When a practitioner documents a diagnosis that does not appear to be supported by the clinical indicators in the health record, a coder has four choices: (1) Code the diagnosis; (2) Ignore the diagnosis; (3) Generate a query to confirm clinical validation of a diagnosis; (4) Follow the facility’s escalation policy for clinical validation.
$30M Settlement for Medicare Advantage Upcoding
A California-based healthcare services provider and several of its affiliates have agreed to pay $30 million to resolve allegations they submitted inaccurate information about the health status of beneficiaries enrolled in Medicare Advantage Plans, according to the Department of Justice.
National Volunteer Week with HIA
Happy National Volunteer Week! This week we celebrate the impact volunteer work has on building stronger communities. We know that our staff have a positive impact while they’re on the job, and we are proud to share a few ways our #PeopleBehindTheNumbers are taking time to volunteer in their own local communities.
Challenges Facing ASCs in 2019
Scrutiny of coding compliance in the growing ambulatory surgical center (ASC) market has increased in recent years from both Medicare and private payers. This will only increase as the Centers for Medicare and Medicaid Services (CMS) moves towards value-based care.
Coding Tip: Acute Renal/Kidney Failure/Injury vs Dehydration as a Principal Diagnosis
Patients being admitted for acute renal failure due to dehydration have been happening for many, many years now. Typically what happens is a patient gets dehydrated for one reason or another. Once dehydration sets in, it can quickly start to affect many body organs. This can lead to acute renal/kidney failure/injury.
Are you making a $12.5M mistake?
In December 2018, a Pennsylvania for-profit hospital and health system, and its CEO agreed to pay a total of $12.5 million to settle allegations they submitted false claims to Medicare and other federal health care programs for orthopedic surgeries. The settlement resolves allegations that top executives exploited a loophole – AKA modifier 59 – that allowed them to double bill federal healthcare payers for surgeries and ignored coding consultants who advised them that they were improperly billing.
Find Your Routine: Don’t Leave Any Loose Ends
When it comes to coding and documentation, finding your own rhythm can lead to positive results. For our series, Find Your Routine, we interviewed our most productive coders and asked them what steps they take to find a rhythm that works for them. This week, we talked with Zahra Ghahremani, CCS, Coding Specialist at Health Information Associates, about the steps she takes to find her routine.
Query Tip: Be Consistent with Query Format
All queries require at least two elements – clinical indicators and a query question. Coders can also include multiple choice options for response or leave the query open-ended for a free text response. The order in which these elements are listed in a query is open to coder or facility preference.
HIA Gives Back to St. Jude, ASPCA in 2018
Giving back is an important part of the HIA mission. Each year, HIA employees take a consensus and choose three National charities to support. Individuals can volunteer a portion of their wages to one of the three organizations. HIA Corporate will match each individual donation up to five dollars. We are proud to share with you our 2018 contribution totals combined with HIA matching funds.
Coding Tip: Unspecified Condition Codes and Combination Codes
One area that coders struggle with is when to report a separate condition code when an already assigned combination code includes the condition. For example, if an obstetric patient is admitted and delivers, and the physician documents “obstetric patient delivered with anemia,” should both code O99.02 Anemia complicating childbirth and D64.9, Anemia, unspecified be coded or should only O99.02 be assigned?
Find Your Routine: Set a Pattern, Follow it
When it comes to coding and documentation, finding your own rhythm can lead to positive results. For our series, Find Your Routine, we interviewed our most productive coders and asked them what steps they take to find a rhythm that works for them. This week, we talked with Donna Cowan, RHIT, CCS, Coding Specialist at Health Information Associates, about the steps she takes to find her routine.
Query Tip: Choosing Reasonable Options for Response
The key to choosing reasonable options for a query response is to remember that the query must stand alone. Any clinical indicators supporting the options must be included in the query itself. In this week’s Query Tip, we provide examples of two queries in which the options for response are not reasonable based on clinical indicators used by coder.
Coding Tip: Obstetric Tidbits for PCS
Last week, we looked at tidbits for reporting the ICD-10-CM codes for pregnancy/obstetric records. Now we will look at some for the ICD-10-PCS reporting of these records. In reporting the appropriate ICD-10-PCS codes a coder must know what is included in the terminology of products of conception (POC).
American Heart Month 2019
Chances are, we all know someone affected by heart disease and stroke, because about 2,300 Americans die of cardiovascular disease each day, an average of 1 death every 38 seconds. But together we can change that.
Coding Tip: Pregnancy, Childbirth, and the Puerperium Tidbits
There was a time when coding delivery records was considered simple. Many times, these types of records were given to the newer coders. However, as coding becomes more complex, this is no longer the case. With the implementation of ICD-10-CM came more codes for very detailed and specific issues that occur during pregnancy, childbirth and the puerperium.
Find Your Routine: Work Each Chart the Same Way
When it comes to coding and documentation, finding your own rhythm can lead to positive results. For our series, Find Your Routine, we interviewed our most productive coders and asked them what steps they take to find a rhythm that works for them. This week, we talked with Allison Curry, RHIT, CCS, Coding Specialist at Health Information Associates, about the steps she takes to find her routine.
Query Tip: Avoid Repetition in Clinical Indicators
One way to shorten a lengthy query is by avoiding repetition in the supporting documentation. Does the same diagnosis really need to be mentioned multiple times in the clinical indicators? Is it necessary to list the results of a chest x-ray twice? Does listing the same documentation multiple times give further specification or explanation to the query?
National Non-Smoking Week 2019
Tobacco use can lead to tobacco/nicotine dependence and serious health problems. Quitting smoking greatly reduces the risk of developing smoking-related diseases. Tobacco/nicotine dependence is a condition that often requires repeated treatments, but there are helpful treatments and resources for quitting.
Part 5 – New 2019 CPT Codes: Category III, Evaluation and Management, etc.
This is Part 5 of a five part series on the new 2019 CPT codes. For the remaining areas we will just briefly summarize the section. Due to the intricate nature of these sections in CPT, it is recommended that the coder read the entire section notes associated with the new codes.
Part 4 – New 2019 CPT Codes: Lymphatic, Digestive, Urinary and Nervous System
This is Part 4 of a five part series on the new 2019 CPT codes. In this series we will explore the CPT changes for FY 2019 and include examples to help the coder understand the new codes. There is 1 new lymphatic code, 2 new digestive system codes with 3 deletions, 3 new urinary system codes with one deletion and 7 deleted nervous system codes with 2 revisions.
Part 3 – New 2019 CPT Codes: Cardiovascular System
This is Part 3 of a five part series on the new 2019 CPT codes. In this series we will explore the CPT changes for FY2019 and include examples to help the coder understand the new codes. There are 9 new cardiovascular CPT codes added with 2 deletions and 3 revisions.
Find Your Routine: Know Your Client Workflow
When it comes to coding and documentation, finding your own rhythm can lead to positive results. For our series, Find Your Routine, we interviewed our most productive coders and asked them what steps they take to find a rhythm that works for them. This week, we talked with Tilina Sablan, RHIT, CCS, Coding Specialist with Health Information Associates, about the steps she takes to find her routine.
Part 2 – New 2019 CPT Codes: Musculoskeletal System
This is Part 2 of a five part series on the new 2019 CPT codes. In this series we will explore the CPT changes for FY2019 and include examples to help the coder understand the new codes. There are 4 new musculoskeletal CPT codes added with 2 deletions and 0 revisions.
Most Common DRG’s with Recommendations 2018: Part 5
In part 5 of our series, we look at DRG 64—Intracranial hemorrhage or cerebral infarction with MCC. For this DRG recommendation the majority (almost all) were recommended to DRG 65 (Intracranial hemorrhage or cerebral infarction with CC) with deletion of the reported MCC.
Most Common DRG’s with Recommendations 2018: Part 4
The majority of the recommendations from DRG 190 (Chronic obstructive pulmonary disease w/MCC) was to DRG 189 (Pulmonary edema and respiratory failure) with re-sequencing of respiratory failure as the PDX or adding as a new code and sequenced as PDX.
Most Common DRG’s with Recommendations 2018: Part 3
The majority of the recommendations from DRG 853 (Infectious & parasitic disease with O.R. procedure with MCC) were to DRG 871 (Septicemia w/o MV 96+ hours with MCC) with deletion or revision of the PCS code. Some of these required physician query.
Most Common DRG’s with Recommendations 2018: Part 2
The majority of the recommendations from DRG 872 (Septicemia w/o mechanical ventilation 96+ hours w/o MCC) were to DRG 871 (Septicemia w/o mechanical ventilation 96+ hours with MCC) with the addition of an MCC to the account. Not all of these required a physician query and were present in the medical record documentation without any clarification needed prior to coding.
Most Common DRG’s with Recommendations 2018: Part 1
The majority of the recommendations from DRG 871 (Septicemia w/o MV 96+ hours with MCC) were to DRG 872 (Septicemia w/o MV 96+ hours w/o MCC) with the recommendation to delete the reported MCC or query for clarification to support the MCC that had been reported.
Top 5 ICD-10 New Year’s Resolutions
Every year, we make plans to live a healthier, more organized, and balanced life. For some of us, we end up falling short of those expectations. This year, to keep us on track with our New Year’s goals, we have put together a few of the most common New Year’s resolutions along with their ICD-10 diagnoses codes. Check out our tips and tricks for a healthy 2019!