Grab a Bunch
by AJ Riviezzo
When obtaining the authorization for the ablation, we also recommend obtaining the authorization for any additional services you routinely provide. Let us presuppose in your practice you average one phlebectomy for every two ablations and one to two medically necessary sclero procedures for every ablation. When obtaining the authorization for the ablation, we would recommend going forward and obtaining the all of the necessary authorization for the phlebectomy and the sclerotherapy as well.
Using the above assumptions, for two ablations we would also ask for two phlebectomies and four sclerotherapy authorizations; for four ablations, you would request four phlebectomies and eight sclerotherapy authorizations. It is usually much easier to obtain the authorizations for the attendant services up front than after you have initiated treatment.
One thing to remember is that authorizations are typically time sensitive. The authorization for some of these attendant services could expire before you are able to use them. If so, you can typically ask for the authorization termination date to be extended. If not, you can also just request a new authorization. As they have previously authorized the service, it tends to be very easy to obtain a new authorization.
If you never use an authorization, no problem. If you do not have an authorization and need one, big problem.
Wednesday, February 23, 2011
Tuesday, January 25, 2011
Coding Clarification
Stabs 1 - 9
by Cheryl Nash and AJ Riviezzo
In the past, there have been some variances in the code used for noting less than ten stabs performed during a phlebectomy. The new guidelines have clearly defined using the 37799 code. You must note the number of stabs actually performed in block 19 of the CMS-1500 billing form or electronic version of the same.
Reimbursement may be interesting as this is generic code without hard-wired pricing tied to the code (one reason you have to note the number of stabs). As with the sclerotherapy injections noted above, this is a surgical procedure and it requires a procedure note stating where, how and why the phlebectomy was performed.
by Cheryl Nash and AJ Riviezzo
In the past, there have been some variances in the code used for noting less than ten stabs performed during a phlebectomy. The new guidelines have clearly defined using the 37799 code. You must note the number of stabs actually performed in block 19 of the CMS-1500 billing form or electronic version of the same.
Reimbursement may be interesting as this is generic code without hard-wired pricing tied to the code (one reason you have to note the number of stabs). As with the sclerotherapy injections noted above, this is a surgical procedure and it requires a procedure note stating where, how and why the phlebectomy was performed.
The History and Physical
Your Presentation of the Patient to the Payer
by AJ Riviezzo, MBA
We have been noting, for several years now, the importance of documentation to ensure your practice can survive an audit. We now have a real life customer that has been on the receiving end of a ZPIC audit. The key issue upon which the audit rested was indeed the History and Physical documentation.
While this practice had been performing a more than sufficient examination of their patients, the data was primarily contained in a patient completed form and a physician completed form with minimal narrative elements. It was this lack of narrative report that deemed the documentation as insufficient to support the recommended course of treatment. In essence, while the data was obtained it was not verbalized in a way that Medicare's audit team would accept as appropriate.
Whether or not you are writing your own History and Physicals or using an EMR such as StreamlineMD or Sonosoft, there are some essential components that must be included in your report. Medicare has detailed three key components. These are:
1. History - The history must contain a Chief Complaint, a history of the present illness, a review of systems (ROS) and a past family and social history (PFSH). The extent of the above, which is obtained and documented, is dependent upon clinical judgment and the nature of the presenting problem. In other words, the documentation needs to clearly support why you are treating the patient.
The patient self-report elements (ROS and PFSH) need to be incorporated into your History and Physical by reference which both acknowledges the report was reviewed and considered regarding the patient's potential course of treatment.
Per CMS guidelines, "The Chief Complaint is a precise statement describing the symptom, problem, condition, diagnosis or other factor that is the reason for the encounter. Documentation requires that the medical record should clearly reflect the Chief Complaint." Under the Chief Complaint you should list the history of the present illness (HPI). Again per CMS guidelines, "The HPI is a chronological description of the development of a patient's present illness from the first sign or symptom or the previous encounter to the present. It contains the following elements: location, quality, severity, duration, timing, context, modifying factors, and associated signs and symptoms." For phlebology, you should describe four or more of these elements so as to include conservative therapy attempts.
It is this section in which most physician's documentation appears to fall short. We strongly recommend performing at least a self audit of this section of your H and P.
2. Examination - A standard examination should be performed including vital signs, general appearance, cardiovascular system, skin, and each extremity at a minimum. If the body area or organ system is normal, a notation indicating negative or normal is sufficient. However, if the organ system or body area is abnormal or symptomatic you must describe your findings in sufficient detail. For the phlebology practice you need to ensure robust documentation of any findings that pertain to the CEAP (Clinical, Etiologic, Anatomic, Pathophysiologic) classification system for venous disease.
3. Medical Decision Making - For each encounter, an assessment, clinical impression or diagnosis should be documented. This may be stated or implied in documented decisions regarding the patient's care management plan or needed further evaluation. If a diagnostic service (test or procedure) is ordered, planned, scheduled, or performed at the time of the office visit, the type of service should be documented. For a phlebology practice, this means the diagnostic ultrasound needs to be noted as ordered and why. The results of any diagnostic tests should be documented in the H and P as well.
If you are performing the diagnostic ultrasound prior to performing the H and P, the decision for ordering the diagnostic test and the results should be clearly documented.
When you are noting the plan of care, the documentation must also contain a mention of any risk of significant complications, morbidity or mortality. A reference to ulcerations or DVT's would be appropriate in this section along with any patient specific risks.
A practice needs to ensure these elements are met in their documentation. While this is time consuming and not terribly exciting, it is much better to spend that little extra effort now then when facing an audit. We again recommend you perform a self-audit or have someone external review your documentation to ensure compliance.
by AJ Riviezzo, MBA
We have been noting, for several years now, the importance of documentation to ensure your practice can survive an audit. We now have a real life customer that has been on the receiving end of a ZPIC audit. The key issue upon which the audit rested was indeed the History and Physical documentation.
While this practice had been performing a more than sufficient examination of their patients, the data was primarily contained in a patient completed form and a physician completed form with minimal narrative elements. It was this lack of narrative report that deemed the documentation as insufficient to support the recommended course of treatment. In essence, while the data was obtained it was not verbalized in a way that Medicare's audit team would accept as appropriate.
Whether or not you are writing your own History and Physicals or using an EMR such as StreamlineMD or Sonosoft, there are some essential components that must be included in your report. Medicare has detailed three key components. These are:
1. History - The history must contain a Chief Complaint, a history of the present illness, a review of systems (ROS) and a past family and social history (PFSH). The extent of the above, which is obtained and documented, is dependent upon clinical judgment and the nature of the presenting problem. In other words, the documentation needs to clearly support why you are treating the patient.
The patient self-report elements (ROS and PFSH) need to be incorporated into your History and Physical by reference which both acknowledges the report was reviewed and considered regarding the patient's potential course of treatment.
Per CMS guidelines, "The Chief Complaint is a precise statement describing the symptom, problem, condition, diagnosis or other factor that is the reason for the encounter. Documentation requires that the medical record should clearly reflect the Chief Complaint." Under the Chief Complaint you should list the history of the present illness (HPI). Again per CMS guidelines, "The HPI is a chronological description of the development of a patient's present illness from the first sign or symptom or the previous encounter to the present. It contains the following elements: location, quality, severity, duration, timing, context, modifying factors, and associated signs and symptoms." For phlebology, you should describe four or more of these elements so as to include conservative therapy attempts.
It is this section in which most physician's documentation appears to fall short. We strongly recommend performing at least a self audit of this section of your H and P.
2. Examination - A standard examination should be performed including vital signs, general appearance, cardiovascular system, skin, and each extremity at a minimum. If the body area or organ system is normal, a notation indicating negative or normal is sufficient. However, if the organ system or body area is abnormal or symptomatic you must describe your findings in sufficient detail. For the phlebology practice you need to ensure robust documentation of any findings that pertain to the CEAP (Clinical, Etiologic, Anatomic, Pathophysiologic) classification system for venous disease.
3. Medical Decision Making - For each encounter, an assessment, clinical impression or diagnosis should be documented. This may be stated or implied in documented decisions regarding the patient's care management plan or needed further evaluation. If a diagnostic service (test or procedure) is ordered, planned, scheduled, or performed at the time of the office visit, the type of service should be documented. For a phlebology practice, this means the diagnostic ultrasound needs to be noted as ordered and why. The results of any diagnostic tests should be documented in the H and P as well.
If you are performing the diagnostic ultrasound prior to performing the H and P, the decision for ordering the diagnostic test and the results should be clearly documented.
When you are noting the plan of care, the documentation must also contain a mention of any risk of significant complications, morbidity or mortality. A reference to ulcerations or DVT's would be appropriate in this section along with any patient specific risks.
A practice needs to ensure these elements are met in their documentation. While this is time consuming and not terribly exciting, it is much better to spend that little extra effort now then when facing an audit. We again recommend you perform a self-audit or have someone external review your documentation to ensure compliance.
Sclerotherapy Injections
One Lump or Two?
by Cheryl Nash and AJ Riviezzo
Many practices are in the habit of automatically using the CPT code 36471 - sclerotherapy injection. We would caution selecting the correct code based on the number of veins injected. Code 36471 is used for injection into two or more veins. If only one vein is being injected, regardless of the number of injections, you should use CPT code 36470 - sclerotherapy injection, single vein. Reimbursement is, of course, a bit less than the 36471, sclerotherapy injection, multiple veins (by about $30).
You can still perform bilateral injections even if one injection is into multiple veins and one is into only one vein. Coding would be 36471 (RT or LT) and 36470 (RT or LT). Do not forget to bill for your diagnostic ultrasound prior to the procedure when you re-map the leg (93970 or 93971) and for the utrasound needle guidance if performed (76942 RT or LT).
Finally, Medicare and the commercial payers treat this as a surgical procedure. There should be a procedure report for your non-cosmetic sclerotherapy injections stating where, how, and why the injection was performed.
by Cheryl Nash and AJ Riviezzo
Many practices are in the habit of automatically using the CPT code 36471 - sclerotherapy injection. We would caution selecting the correct code based on the number of veins injected. Code 36471 is used for injection into two or more veins. If only one vein is being injected, regardless of the number of injections, you should use CPT code 36470 - sclerotherapy injection, single vein. Reimbursement is, of course, a bit less than the 36471, sclerotherapy injection, multiple veins (by about $30).
You can still perform bilateral injections even if one injection is into multiple veins and one is into only one vein. Coding would be 36471 (RT or LT) and 36470 (RT or LT). Do not forget to bill for your diagnostic ultrasound prior to the procedure when you re-map the leg (93970 or 93971) and for the utrasound needle guidance if performed (76942 RT or LT).
Finally, Medicare and the commercial payers treat this as a surgical procedure. There should be a procedure report for your non-cosmetic sclerotherapy injections stating where, how, and why the injection was performed.
Tuesday, December 14, 2010
January Marketing Tip
Medicare Appreciation Month
by Marcy Riviezzo and AJ Riviezzo
Unless we have completely scarred you off from seeing Medicare patients, January is a good month for treating your Medicare patients. The reason for this is deductibles. Your commercial patients have typically just entered their new deductible cycle for the year. They may be reticent to begin treatment on something that is a bit elective. Medicare members typically have a secondary policy that absorbs their small deductible.
Reach out to your referring PCP's. Let them know that January is your Medicare appreciation month. It is an 'excuse' to re-market to these physicians, their office manager, and their referring coordinator.
Also reach out to your existing patients and database. Send a letter to all of your current and former Medicare patients thanking them for having chosen your practice for receiving their care. In it you can mention it is Medicare Appreciation Month and that you would be happy to meet their friends or neighbors if they have a need for your services. You might offer them a $10 gift card (see above limitations) for any of their referrals as a further thank you.
Finally, there are likely some retirement communities in your area. Find out if they have a physician day or similar program in which you can participate. Spend an hour or two explaining venous disease and answering the communities questions. You can bring a portable ultrasound machine and show how it works by using a volunteer. This type of outreach has proven very successful for a number of practices.
by Marcy Riviezzo and AJ Riviezzo
Unless we have completely scarred you off from seeing Medicare patients, January is a good month for treating your Medicare patients. The reason for this is deductibles. Your commercial patients have typically just entered their new deductible cycle for the year. They may be reticent to begin treatment on something that is a bit elective. Medicare members typically have a secondary policy that absorbs their small deductible.
Reach out to your referring PCP's. Let them know that January is your Medicare appreciation month. It is an 'excuse' to re-market to these physicians, their office manager, and their referring coordinator.
Also reach out to your existing patients and database. Send a letter to all of your current and former Medicare patients thanking them for having chosen your practice for receiving their care. In it you can mention it is Medicare Appreciation Month and that you would be happy to meet their friends or neighbors if they have a need for your services. You might offer them a $10 gift card (see above limitations) for any of their referrals as a further thank you.
Finally, there are likely some retirement communities in your area. Find out if they have a physician day or similar program in which you can participate. Spend an hour or two explaining venous disease and answering the communities questions. You can bring a portable ultrasound machine and show how it works by using a volunteer. This type of outreach has proven very successful for a number of practices.
Free Screenings
Federal Anti-Kickback Laws
by AJ Riviezzo, MBA
Our last email contained information regarding ZPIC audits. This generated a discussion with Dr. Calcagno regarding potential concerns with performing free screenings on federal health care program patients (Medicare, Medicaid, TriCare, CHAMPUS, VA, CHP or Indian Health Service). It turns out there is some cause for concern. The Office of the Inspector General (OIG) is potentially concerned with free screenings as it may constitute an impermissible kickback to the patient.
The OIG does allow a nominal incentive to be given. The nominal value is typically set at $10.00 per item or $50 total per year per 65 Fed. Reg. 24400, 24410-24411 dated April 26, 2000. A pretty low value which I am sure has not been adjusted for inflation.
Our recommendation is to establish a value for your 'education services' at $10.00. In essence, that is what the free consultation is... education services. You are providing a small bit of information about the underlying issues and current treatment methodologies for their possible condition. As a matter of course, you adjust these services down to zero for all patients.
A thank you to Dr. Calcagno for creating such an interesting discussion.
by AJ Riviezzo, MBA
Our last email contained information regarding ZPIC audits. This generated a discussion with Dr. Calcagno regarding potential concerns with performing free screenings on federal health care program patients (Medicare, Medicaid, TriCare, CHAMPUS, VA, CHP or Indian Health Service). It turns out there is some cause for concern. The Office of the Inspector General (OIG) is potentially concerned with free screenings as it may constitute an impermissible kickback to the patient.
The OIG does allow a nominal incentive to be given. The nominal value is typically set at $10.00 per item or $50 total per year per 65 Fed. Reg. 24400, 24410-24411 dated April 26, 2000. A pretty low value which I am sure has not been adjusted for inflation.
Our recommendation is to establish a value for your 'education services' at $10.00. In essence, that is what the free consultation is... education services. You are providing a small bit of information about the underlying issues and current treatment methodologies for their possible condition. As a matter of course, you adjust these services down to zero for all patients.
A thank you to Dr. Calcagno for creating such an interesting discussion.
Diagnosis Coding
A New Delay Scenario
by Cheryl Nash and AJ Riviezzo
When coding (diagnosis) for a diagnostic ultrasound and new patient visit, we recommend coding with the patient's presenting complaints and symptoms. For example, if the patient has swelling of the legs as well as pain in the legs then you would use the ICD-9 codes for these two elements (729.81 and 729.5 respectively). After you have reviewed the patient's condition and made a medical diagnosis you then begin using a more comprehensive diagnosis like Varicose Veins of Lower Extremities with Other Complications of Edema, Pain and Swelling (454.8).
United Healthcare and payers who use Ingenix as their data source for coding are now beginning to hold any claims with a primary diagnosis of Pain in Limb (729.5). They are automatically generating a letter to the patient as if the patient was in an accident. The patient is supposed to note the accident date and time and return the form. Since there was no accident, many of the patients are disregarding the letter. Throughout this process, your claim remains unpaid. I do remember when automation was supposed to help drive down health care costs...
We are, therefore, recommending a primary diagnosis (should the patient have these symptoms) of venous insufficiency (459.81) with pain in limb being your secondary or tertiary diagnosis. This will help ensure your claim is paid in a timely fashion without the delays associated with an accident investigation.
by Cheryl Nash and AJ Riviezzo
When coding (diagnosis) for a diagnostic ultrasound and new patient visit, we recommend coding with the patient's presenting complaints and symptoms. For example, if the patient has swelling of the legs as well as pain in the legs then you would use the ICD-9 codes for these two elements (729.81 and 729.5 respectively). After you have reviewed the patient's condition and made a medical diagnosis you then begin using a more comprehensive diagnosis like Varicose Veins of Lower Extremities with Other Complications of Edema, Pain and Swelling (454.8).
United Healthcare and payers who use Ingenix as their data source for coding are now beginning to hold any claims with a primary diagnosis of Pain in Limb (729.5). They are automatically generating a letter to the patient as if the patient was in an accident. The patient is supposed to note the accident date and time and return the form. Since there was no accident, many of the patients are disregarding the letter. Throughout this process, your claim remains unpaid. I do remember when automation was supposed to help drive down health care costs...
We are, therefore, recommending a primary diagnosis (should the patient have these symptoms) of venous insufficiency (459.81) with pain in limb being your secondary or tertiary diagnosis. This will help ensure your claim is paid in a timely fashion without the delays associated with an accident investigation.
Tuesday, November 16, 2010
Review the Payer Guidelines
Knowledge is Essential
by Cheryl Nash and AJ Riviezo
Most commercial insurances and Medicare have clinical guidelines they review one to two times per year. It is essential that you are operating under the most current guidelines. As the United example shows, the changes can be dramatic and result in denials.
One way to ensure you are reviewing your top payers on a regular basis is to see if they have a 'Next Review Date' listed on the current guidelines. You can place a note on your calendar to go to that payer's guidelines and see if there is a new publication of the guideline or if the date has been changed. Key elements to review are changes in documentation requirements, changes in medical necessity requirements, and changes in conservative therapy. Be sure to read the fine print. Sometimes the changes are in the addendums or are a few words hiding in the middle of what appears to be an unchanged paragraph.
by Cheryl Nash and AJ Riviezo
Most commercial insurances and Medicare have clinical guidelines they review one to two times per year. It is essential that you are operating under the most current guidelines. As the United example shows, the changes can be dramatic and result in denials.
One way to ensure you are reviewing your top payers on a regular basis is to see if they have a 'Next Review Date' listed on the current guidelines. You can place a note on your calendar to go to that payer's guidelines and see if there is a new publication of the guideline or if the date has been changed. Key elements to review are changes in documentation requirements, changes in medical necessity requirements, and changes in conservative therapy. Be sure to read the fine print. Sometimes the changes are in the addendums or are a few words hiding in the middle of what appears to be an unchanged paragraph.
ZPIC Audits
Is Phlebology Being Targeted?
by AJ Riviezzo, MBA
The new Zone Program Integrity Audits (ZPIC), which have been in the making for several years, have really begun to be conducted over the past three months. The goal of these audits is to detect fraud and abuse in Medicare claims. These audits are being done by sub-contractors on behalf of the Medicare Administrative Contractors (MAC). It also appears that these several sub-contractors are paid only on the 'found' dollars. This lends serious concerns regarding their processes and the neutrality of the review.
Further, the rules (like those surrounding the RAC audits) were never formalized by Congress. This is allowing the ZPIC sub-contractors to devise their own rules and regulations regarding the process. These rules are certainly not provider friendly to date. It has also created a significant variance between Zones on how these audits are being conducted. In one area it appears they are being treated much like the RAC audits with thirty charts being reviewed on a retrospective review. In another area, ALL claims are being reviewed with payments being denied prospectively, with virtually no feedback as to the reason why save the standard Medicare denial codes.
Attempts to gain further information have, to date, been difficult. One phlebology provider has basically been told that it is not the ZPIC contractor's responsibility to 'educate' the provider, and yet they are still holding essentially all payments prospectively. Thankfully this provider has a relatively small percentage of Medicare patients as part of their payer mix. For a provider with a large Medicare mix, this is tantamount to a forced closure.
Is phlebology being targeted? The author cannot state that it is. However, two phlebology practices are already in review that we know about. Given the small number of providers in review by these ZPIC contractors and given the even smaller percentage of all providers that perform ablations, it does give one serious pause for concern.
So what is a practice to do proactively? First, we recommend that you re-read your Local Coverage Determinations (LCD) regarding phlebology services for your area. Make sure your patients are meeting the medical necessity requirements outlined in the LCD.
Second, the LCD may also have documentation requirements that are specifically required on each chart or operative note. Please review your documentation against these requirements. You may also want to have an external agency conduct a chart-to-bill, bill-to-chart audit. Yes, you can do these on your own but it is a bit like proof-reading your own work. An outside eye will not overlook 'assumed' elements.
What are the next steps should your practice be contacted by ZPIC? The request from ZPIC will be for copies of your charts. We recommend sending, as quickly as possible, the copies requested. Typically they are requesting for a specific date of service. We recommend sending all of the documentation necessary for that specific date (e.g. Diagnostic Ultrasound, History and Physical, Operative Note, any other documentation). If they request records for multiple dates of service, send the same type of packet for each date of service. Do not assume they will copy the Diagnostic Ultrasound and attach it to each date of service. They will not do so. We also suggest that you immediately contact an attorney in your area with some ZPIC or at least RAC audit experience.
Now to the vaguely good news. Once ZPIC has denied your claims (recent experience shows a denial rate of over 95%), you can then appeal these denials through the Medicare system. Medicare has five levels of appeal that can be attempted. These are:
1. Redetermination. This goes through MAC and is basically to keep the claims open for additional appeal processes. On the average 50% of claim denials are overturned at this stage.
2. Reconsideration. These appeals go through a completely different department, usually a Physician panel, for review. These reviewers do not work for Medicare or the ZPIC contractor, and are not paid by the denial. (this is a completely independent review team).
3. Administrative Law Judge Hearing. Established for any outstanding claims over $130.00. This stage allows for a teleconference with a legal entity to discuss the medical necessity of the services, and functions like a peer-to-peer review. There is a high level of success at this stage of appeals.
4. Medicare Appeal Council Review. This is an independent team of professionals tasked with reviewing the decision made by the ALJ panel. Any contested issues found in the ALJ hearing will be reviewed here.
5. District Court. Established for any claims over $1260.00. You may request a review in district court.
The encouraging news is that at the 3rd level of appeal, if a physician's services may not have exactly met criteria set forth by the MAC, the claims may still be considered for payment if the physician is able to state, in a concrete fashion, as to why the services were necessary and prudent.
In short, these ZPIC audits are looking to be both unpleasant and expensive with few guidelines that are required to be followed. It appears the assumption is that fraud has been committed unless proven otherwise. Review your documentation, medical necessity assumptions, and the Local Coverage Determinations soon.
by AJ Riviezzo, MBA
The new Zone Program Integrity Audits (ZPIC), which have been in the making for several years, have really begun to be conducted over the past three months. The goal of these audits is to detect fraud and abuse in Medicare claims. These audits are being done by sub-contractors on behalf of the Medicare Administrative Contractors (MAC). It also appears that these several sub-contractors are paid only on the 'found' dollars. This lends serious concerns regarding their processes and the neutrality of the review.
Further, the rules (like those surrounding the RAC audits) were never formalized by Congress. This is allowing the ZPIC sub-contractors to devise their own rules and regulations regarding the process. These rules are certainly not provider friendly to date. It has also created a significant variance between Zones on how these audits are being conducted. In one area it appears they are being treated much like the RAC audits with thirty charts being reviewed on a retrospective review. In another area, ALL claims are being reviewed with payments being denied prospectively, with virtually no feedback as to the reason why save the standard Medicare denial codes.
Attempts to gain further information have, to date, been difficult. One phlebology provider has basically been told that it is not the ZPIC contractor's responsibility to 'educate' the provider, and yet they are still holding essentially all payments prospectively. Thankfully this provider has a relatively small percentage of Medicare patients as part of their payer mix. For a provider with a large Medicare mix, this is tantamount to a forced closure.
Is phlebology being targeted? The author cannot state that it is. However, two phlebology practices are already in review that we know about. Given the small number of providers in review by these ZPIC contractors and given the even smaller percentage of all providers that perform ablations, it does give one serious pause for concern.
So what is a practice to do proactively? First, we recommend that you re-read your Local Coverage Determinations (LCD) regarding phlebology services for your area. Make sure your patients are meeting the medical necessity requirements outlined in the LCD.
Second, the LCD may also have documentation requirements that are specifically required on each chart or operative note. Please review your documentation against these requirements. You may also want to have an external agency conduct a chart-to-bill, bill-to-chart audit. Yes, you can do these on your own but it is a bit like proof-reading your own work. An outside eye will not overlook 'assumed' elements.
What are the next steps should your practice be contacted by ZPIC? The request from ZPIC will be for copies of your charts. We recommend sending, as quickly as possible, the copies requested. Typically they are requesting for a specific date of service. We recommend sending all of the documentation necessary for that specific date (e.g. Diagnostic Ultrasound, History and Physical, Operative Note, any other documentation). If they request records for multiple dates of service, send the same type of packet for each date of service. Do not assume they will copy the Diagnostic Ultrasound and attach it to each date of service. They will not do so. We also suggest that you immediately contact an attorney in your area with some ZPIC or at least RAC audit experience.
Now to the vaguely good news. Once ZPIC has denied your claims (recent experience shows a denial rate of over 95%), you can then appeal these denials through the Medicare system. Medicare has five levels of appeal that can be attempted. These are:
1. Redetermination. This goes through MAC and is basically to keep the claims open for additional appeal processes. On the average 50% of claim denials are overturned at this stage.
2. Reconsideration. These appeals go through a completely different department, usually a Physician panel, for review. These reviewers do not work for Medicare or the ZPIC contractor, and are not paid by the denial. (this is a completely independent review team).
3. Administrative Law Judge Hearing. Established for any outstanding claims over $130.00. This stage allows for a teleconference with a legal entity to discuss the medical necessity of the services, and functions like a peer-to-peer review. There is a high level of success at this stage of appeals.
4. Medicare Appeal Council Review. This is an independent team of professionals tasked with reviewing the decision made by the ALJ panel. Any contested issues found in the ALJ hearing will be reviewed here.
5. District Court. Established for any claims over $1260.00. You may request a review in district court.
The encouraging news is that at the 3rd level of appeal, if a physician's services may not have exactly met criteria set forth by the MAC, the claims may still be considered for payment if the physician is able to state, in a concrete fashion, as to why the services were necessary and prudent.
In short, these ZPIC audits are looking to be both unpleasant and expensive with few guidelines that are required to be followed. It appears the assumption is that fraud has been committed unless proven otherwise. Review your documentation, medical necessity assumptions, and the Local Coverage Determinations soon.
United Health Care Update
Positive Change for Once
by Cheryl Nash and AJ Riviezzo
United Health Care, effective October 25th, 2010, has again revised their medical policy guidelines for ablations. The submission of color photographic prints is no longer required. Also, the submission of US prints is no longer required. It appears their system could not handle the massive amount of data they were receiving thus forcing a change.
The best news coming out of the new policies is that compression stockings are no longer required as a part of conservative treatment. A completed questionnaire addressing the degree and severity of pain still must be submitted for authorization. This questionnaire can be found at: https://www.unitedhealthcareonline.com
The bad news is that diameter sizes have not changed... it is still 5.5mm for GSV, 5mm for SSV. Only one measurement is required. If bleeding or ulceration is present vein sizes of a lower diameter will be accepted.
Perforator size for treatment has dropped to 3.5mm. Additionally, the notes must document the presence of venous stasis ulceration for laser or RF ablation of the perforator.
There are some other requirements so please read the policy for some of the various nuances.
by Cheryl Nash and AJ Riviezzo
United Health Care, effective October 25th, 2010, has again revised their medical policy guidelines for ablations. The submission of color photographic prints is no longer required. Also, the submission of US prints is no longer required. It appears their system could not handle the massive amount of data they were receiving thus forcing a change.
The best news coming out of the new policies is that compression stockings are no longer required as a part of conservative treatment. A completed questionnaire addressing the degree and severity of pain still must be submitted for authorization. This questionnaire can be found at: https://www.unitedhealthcareonline.com
The bad news is that diameter sizes have not changed... it is still 5.5mm for GSV, 5mm for SSV. Only one measurement is required. If bleeding or ulceration is present vein sizes of a lower diameter will be accepted.
Perforator size for treatment has dropped to 3.5mm. Additionally, the notes must document the presence of venous stasis ulceration for laser or RF ablation of the perforator.
There are some other requirements so please read the policy for some of the various nuances.
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