Proposed Changes To E&M Services Documentation, Coding, & Payment



Proposed Changes To E&M Services Documentation, Coding, & Payment

Billing, coding and compliance issues have a direct financial effect on many of Fuoco Group’s medical and healthcare clients. Respected compliance expert Jean Acevedo, of Acevedo Consulting, is a fellow healthcare professional in the Palm Beach County Medical Society’s “Circle of Friends” along with Fuoco Group. We offer to you her comments to the Centers for Medicare & Medicaid Services Department of Health and Human Services about the proposed changes to Evaluation & Management Services documentation, coding and payment.


“Please accept my comments regarding the proposed changes to Evaluation & Management (E&M) Services documentation, coding and payment. In formulating these comments, I have considered the following: reduction of administrative burden, beneficiary access to care, payment implications, and any apparent program integrity issues.

Over the last 20+ years, I have had the pleasure of educating physicians on E&M documentation and coding, reviewing their documentation for accuracy proactively, and assisting them in appealing Medicare and other third-party payer audits. Over this time period I have seen the evolution of visit documentation from short, handwritten progress notes to the sometimes 7-page progress notes generated by many EMRs. With the aging of our population and longer life spans, along with more care being   provided in outpatient settings as the criteria for hospital inpatient has become more stringent, I have also seen the increasing patient complexity physicians are dealing with in their offices. This allows me to agree with some of CMS’s underlying premises outlined in CMS-1693-P. However, this experience also allows me to know where some of the proposals will create confusion and be detrimental not only to physicians, but also to Medicare beneficiaries.

Home Visits: I agree with removing the requirement that, for a home visit to be payable, the practitioner must document why a patient could not have been seen in the office. This proposal would cover CPT codes 99341 – 99350; visits at the patient’s private residence. With the stated rationale, it would seem that visits to patients residing in ALF/domiciliary care settings (E&M codes 99324-99337) should also have this documentation requirement be removed. From a program integrity standpoint, perhaps a requirement – found in some of the MACs’ LCDs - that there be documentation the patient, patient’s caregiver or treating clinician requested the initial home/ALF visit should be implemented when the visiting practitioner has not been treating the patient previously. This could help prevent an unscrupulous provider from providing what Medicare has sometimes called “gang visits” in this vulnerable patient population.”

Jean Acevedo, LHRM, CPC, CHC, CENTC, AAPC Fellow, can be reached at 561-278-9328. Visit www.acevedoconsultinginc.com to learn more from a strategic partner in healthcare.


Contact Us: No matter what your niche or specialty, perhaps it’s time to consider an accounting ally in the healthcare industry with medical practice financial expertise. In addition to tax and accounting services, Fuoco Group’s New Financial Dialogue includes a 360 degree business advisory program. All designed to take the burden off you and your physician partners because worrying about costs, reimbursements, margins, operations and finances shouldn’t be keeping you awake at night!
 

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