Podiatry Coding & Billing Alert

Hint: The documentation must support your use of modifier 25.

Correctly reporting home visit codes 99348-99350 can be challenging. For example, how much do you know about Medicare’s physician signature requirements? Follow these expert tips to avoid making a potentially costly mistake.

Heads up: In Vol. 9 No. 7 of Podiatry Coding & Billing Alert, you learned three common mistakes podiatrists make regarding claims billed with home visit codes 99348-99350, per a recent National Government Services (NGS) service-specific prepayment review. Now, learn even more about reporting for home visits to protect your reimbursement.

When Your MAC Calls, Always Answer

Error 1: You didn’t respond to a documentation request.

Never put off providing the medical documentation your MAC asks for.

Tip: When your MAC performs a prepayment review or audit and asks for specific documentation to support your claim, you should know which code(s) the payer wants to see support for, turn the appropriate documentation in, and submit this requested information in a timely manner.

Don’t Forget the Physician’s Signature

Error 2: The physician’s signature was missing from the submitted documentation.

Missing physician signatures is a vital issue coders should be aware of, says Christine Marcelli, CPC, CPPM, CSFAC, practice manager at Stark County Foot & Ankle Clinic in Canton, Ohio.

“In my opinion, coders are often busy making sure the actual ‘codes’ are correct and that the necessary documentation is there, and they end up overlooking something simple like a physician signature,” Marcelli says. “Coders need to double-check that the physician signature is there and is legible.”

Making this error means you are looking at another denial and remit and another 30-60 days in delay of payment, Marcelli adds.

According to the Medicare Program Integrity Manual Chapter 3.3.2.4, for medical review purposes, the author must authenticate any services he provides or orders. The manual identifies either a handwritten or electronic signature as appropriate methods of authentication.

Handwritten signatures: “A handwritten signature is a mark or sign by an individual on a document signifying knowledge, approval, acceptance, or obligation,” according to the Medicare Program Integrity Manual Chapter 3.3.2.4. In certain situations, signature logs and signature attestation statements may be deemed acceptable.

Electronic signatures: The Medicare Program Integrity Manual Chapter 3.3.2.4 recognizes that providers who use electronic systems should be aware that alternative signature methods could lead to abuse. To be safe, physicians should always check with their attorneys and malpractice insurers about using alternative signature methods.

Tip:  Check with your physicians and confirm their understanding of Medicare’s signature requirements. Physicians also need to make sure they are signing their own notes and not mistakenly signing another physician’s notes.

Bonus tip: Marcelli adds another tip to ensure you don’t forget your physician’s signature in the documentation.

Put a self-audit system in place and have a check sheet in sight so you can glance over it when coding, Marcelli says. This way you can make sure you complete everything you need before submission.

“It is easy to get distracted by staff members, patients, and physicians, and this will help you to remember not to overlook things,” Marcelli adds.

Ensure the Documentation Supports Modifier 25 Use

Error 3: You reported visits with modifier 25 indicating the evaluation and management (E/M) service was a significant, separately identifiable service; however, the documentation lacked the data to support the use of modifier 25.

Modifier 25 (Significant, separately identifiable evaluation and management service by the same physician or other qualified health care professional on the same day of the procedure or other service) is an often misunderstood modifier.

Tip: Remember, modifier 25 is used only on an E/M service that is “separate and significant from another procedure or service at the same encounter,” explains Melanie Witt, RN, CPC, MA, an independent coding expert based out of Guadalupita, New Mexico.

This does not mean that a different diagnosis is required, but the note must clearly indicate that the E/M dealt with issues that were not part of the other services even though it may have been for the same condition. The visit must be separately identifiable from the procedure, such that it is clear that the two services were medically necessary at the time they were both rendered.

Don’t forget that the E/M service must not only be separately identifiable, but also above and beyond the usual care.

On modifier 25 claims, “the physician must show, by documentation in the medical record, that on the day he performed the procedure, the patient’s condition required a separately identifiable E/M service above and beyond the usual care associated with the procedure that was performed,” says Mary I. Falbo, MBA, CPC, CEO of Millennium Healthcare Consulting Inc. in Lansdale, Pennsylvania.

When you append modifier 25, ensure the situation meets the following requirements, which the medical documentation should always support:

• Only append modifier 25 to E/M service codes 99201 (Office or other outpatient visit for the evaluation and management of a new patient, which requires these 3 components …) through 99499 (Unlisted evaluation and management service).
• Use modifier 25 only when your provider’s documentation proves that he performed a medically necessary and “significant, separately identifiable” E/M service in addition to the originalprocedure.
• Your physician must include a separate history, examination, and medical decision-making (HEM) for the E/M service in his documentation.
• The E/M service must occur on the same calendar day as the original procedure, for the same patient.
• The procedure following the E/M would be a minor procedure, meaning that it has a zero or 10-day global period.