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Q&A: Tracking denials

denials poll

Did you know 55% say CDI is involved in the denials management and appeals process?

Q: When looking at denials timelines, what information should be noted?

A: There are many critical time elements to capture during the denial appeals process. It is recommended that you add these to your denials database. If that is not possible, an alternative spreadsheet or database should be developed. The first date to track is the date that the denial or remittance advice (zero or underpayment) was received. The amount of time allowed to file your appeal will vary from payer to payer. When tracking timelines, it is important to note the: [more]

UnitedHealth Group, Inc. vs. the United States of America: The case for CDI

Brian-Murphy

ACDIS Director Brian Murphy

Part 4 (click here to view part 1, click here to view part 2, and click here to view part 3)

By Brian D. Murphy

In Part 1 of this series I introduced the developing story of UnitedHealth Group, Inc. vs. the United States of America. In Part 2, I detailed the facts of the case. Part 3 looked at the regulations and commentary regarding claims submission to Medicare Advantage and the ramifications for CDI. Part 4, discusses recent developments of the case.

Since I wrote my initial three parts of the developing case of UnitedHealth Group, Inc. vs. the United States of America there has been a huge development on the legal front. Round 1 of the case of UnitedHealth Group, Inc. vs. the Unites States of America is over, and the decisive winner (at least in the matter of one complaint filed by the DOJ) is United. [more]

UnitedHealth Group, Inc. vs. the United States of America: The case for CDI

Brian-Murphy

ACDIS Director Brian D. Murphy

Part 3 (to read part 1, click here. To read part 2, click here.)

By Brian D. Murphy

In part 1 of this series, I introduced the developing story of UnitedHealth Group, Inc. vs. the United States of America. In part 2, I detailed the facts of the case. Part 3 looks at the regulations and commentary regarding claims submission to Medicare Advantage and the ramifications for CDI.

Section III of the complaint United States of American ex rel. Benjamin Poehling, explains the payment methodology which UnitedHealth Group, Inc. allegedly manipulated for financial gain. The Medicare program pays Medicare Advantage (MA) organizations a pre-determined monthly amount for each Medicare beneficiary in the plan. The payment amount for each beneficiary is based on their particular risk adjustment factor (RAF) score, which among other factors including the beneficiary’s demographics is impacted by assigned Hierarchical Condition Categories (HCC). [more]

UnitedHealth Group, Inc. vs. the United States of America: The case for CDI, part 2

Brian-Murphy

ACDIS Director Brian Murphy

By Brian D. Murphy

In Part 1 of this series I introduced the developing story of UnitedHealth Group, Inc. vs. the United States of America, and my intent to write a series of articles on this civil fraud action. Why? Because I find this to be an incredibly interesting case with broad ramifications for CDI and coding departments.

So let’s review the basic at the facts of the case, starting with the who and when. [more]

Q&A: Denial management teams

Have CDI questions?

Have CDI questions?

Q: What guidance do you have for building a denial management team?

A: As with any team, it is important to have the right players working together with identified roles and responsibilities established for each. The members of the denials management team should be representative of departments with a direct tie to the various types of denials. Include the following groups: [more]

UnitedHealth Group, Inc. versus the United States of America: The case for CDI

Brian-Murphy

ACDIS Director Brian Murphy

By Brian Murphy

The work of a CDI professional can at times seem isolating and unimportant. Does it matter if a query gets answered? When we educate physicians and tell them what they document matters, are they listening?

Then a case comes along and demonstrates not just that the CDI profession does matter—but that it matters a lot.

That point was driven home to me while reading a May 16, 2017 court document, United States of America ex rel. Benjamin Poehling v. UnitedHealth Group, Inc., in which the Department of Justice (DOJ), alleges that UnitedHealth artificially increased Medicare Advantage (MA) reimbursement/Hierarchical Condition Category assignment by mining for non-supported diagnoses that were not documented/reported by the physician or through chart documentation.

The case is a qui tam—a lawsuit brought forward by a private individual. The plaintiff is Benjamin Poehling, the former Director of Finance for UnitedHealthcare Medicare & Retirement (and its predecessor Ovations), which was the group at United that managed its MA plans and its Medicare Part D prescription drug programs.

The lawsuit seeks to recover more than $1 billion under the False Claims Act. The total damages sought are unspecified but it’s a large case with a lot at stake.

This case has received quite a bit of coverage, too, from big newspapers like the New York Times and popular healthcare websites like Beckers Hospital Review and HealthLeaders Media.

There is a lot more to this case than this 103-page court document, though. In addition to Poehling’s case (filed in February 2017), another whistleblower, James Swoben, a former employee of Senior Care Action Network Health Plan and a consultant to the risk-adjustment industry, came forward with similar allegations in March.

In a very recent development, UnitedHealth Group’s lawyers are seeking to get the case dismissed, claiming that they are not required to validate the accuracy of diagnostic data submitted by healthcare providers.

I need to reiterate that, at this point, the claims asserted against UnitedHealth Group are only allegations and there have been no determinations of liability. It remains to be seen whether the case will even reach court.

However, the case ultimately resolves, it’s a very interesting, real-world, big-dollar example of the business of healthcare, raising the question of who is ultimately responsible for the accuracy of submitted diagnoses to Medicare (coders, CDI, administrative contractors, physicians?). It calls into question the oft-repeated adage that coders must code what the physician documents. It brings into even greater prominence the process of clinical validation, for which ACDIS recently released a new white paper.

Reading through these articles and the original court document, I thought to myself, if only UnitedHealth Group had a robust, compliant CDI process in place, this suit could have been prevented. More than anything, United States of America vs. UnitedHealth Group Inc. is confirmation that your work as a CDI professional matters, and that the broader CDI profession matters.

I plan to share my thoughts on this case in a series of blog posts here and I welcome your thoughts and commentary.

Editor’s note: To read the summary of the case, visit the DOJ website by clicking here. To read the court document in its entirety, click here. Brian Murphy is Director of the Association of Clinical Documentation Improvement Specialists (ACDIS). He can be reached at bmurphy@acdis.org.

 

 

Q&A: Documenting excisions in dermatologic settings

ask ACDIS

Have CDI questions?

Q: I work in dermatology and need to know what documentation is required for excisions. We are struggling with getting paid.

A: In dermatology, you often find vague documentation like “lesion” and “mass.” So the physician needs to be much more graphic as far as whether the lesion is red, itchy, scratchy, burning, and/or abnormally sized. If you can get the actual size of a lesion or a mass that they are going to excise, they also need to document the size of the excision.

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Guest Post: Addressing unspecified codes

Rose Dunn

Rose Dunn, MBA, RHIA, CPA, FACHE, FHFMA, CHPS

By Rose T. Dunn, MBA, RHIA, CPA, FACHE, FHFMA, CHPS

When CMS told the American Medical Association (AMA) physicians could have a one-year grace period to become comfortable with ICD-10-CM/PCS coding systems, they made a bad decision. The agreement allowed providers to be less conscientious about their diagnosis coding, leaving them to focus only on the first three characters of the code for medical necessity purposes. In actuality, some providers took the compromise as a license to map their superbill codes and submit “not otherwise specified” (NOS) and “not elsewhere classified” (NEC) codes to all payers.

Matthew Menendez of White Plume Technologies estimated in 2016 the average rate of unspecified code use at the time was 31.5%.

“Payers want the more detailed diagnosis information available in ICD-10. The reason that both government and commercial payers advocated for the migration to ICD-10 and invested millions of dollars to rewrite their adjudication processes was for the granular diagnosis data on their insured patient populations. Payers want to leverage detailed ICD-10 codes to drive down the cost of healthcare in the United States and if the provider community does not supply this data they will begin to deny claims,” Menendez said.

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Q&A: Rejections for claims for removing impacted cerumen

ask ACDIS

Ask ACDIS

Q: We have started receiving rejections for ED claims when the service involves removing impacted cerumen. We are reporting CPT® code 69209 (removal impacted cerumen using irrigation/lavage, unilateral) for each ear, and the documentation supports the irrigation/lavage rather than the physician removing the impaction with instruments. Our claims just started getting rejected in April. 

A: While your question doesn’t specify, it appears that you may be billing this with one line for the left ear with modifier -LT and one line for the right ear with modifier -RT. This code is included in the surgical section of CPT and correct coding requires that this be reported with modifier -50 for a bilateral procedure. In fact, there is a specific parenthetical note that states “For bilateral procedure, report 69209 with modifier -50”. 

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Book Excerpt: CDI’s role in inpatient-only procedure documentation

Mackaman_Debbie

Debbie Mackaman, RHIA, CPCO, CCDS

By Debbie Mackaman, RHIA, CPCO, CCDS

Connect CDI, utilization review, and case management before the patient is discharged

When a procedure converts to an inpatient-only procedure during the surgery, the documentation process may get a little more complex. Analyze what happened during the procedure itself. If the inpatient-only procedure is performed on an emergency basis, it’s likely the admission order was not obtained prior to the procedure. The outcome for the patient will determine the next steps. If the patient expires, no further action is required by the registration or operating room staff. The coding and billing teams take over resolution of the case.

If the patient does not expire, the surgeon should confirm the type of surgery originally scheduled and the reason for the needed change to the inpatient-only procedure. He or she should do so before the patient leaves the postoperative area. The care team needs to make a determination regarding the admission of that patient. Under current CMS guidance, the three-day payment window may apply in this scenario. The case should be held for billing purposes until a thorough post-discharge review can be completed.

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