Podiatry Coding & Billing Alert

Hint: Bill POS 12 for home visits.

A recent National Government Services (NGS) service-specific prepayment review for JK Part B podiatrists (Specialty 48) in downstate and Queens, New York revealed why Medicare payers reduced or denied claims podiatrists billed with home visit codes 99348-99350.

The review resulted in the Medicare payer reducing or denying more than 82 percent of the claims in January, February, and March.

Here are the Codes the Review Focuses On

The NGS prepayment review centers on the following evaluation and management (E/M) codes:

• 99348, Home visitfor the evaluation and management of an established patient, which requires at least 2 of these 3 key components: an expanded problem focused interval history; an expanded problem focused examination; medical decision making of low complexity …
• 99349, … a detailed interval history; a detailed examination; medical decision making of moderate complexity …
• 99350, … a comprehensive interval history; a comprehensive examination; medical decision making of moderate to high complexity …

Don’t fret: NGS gave specific reasons for the reductions and denials, and we’ve got tips to help you avoid making some of these same mistakes in your own practice.

Mistake 1: You submitted incomplete and/or illegible documentation.

When referring to illegible notes in the past, this often meant you couldn’t read the physician’s handwriting, but in this age of electronic records, illegible documentation has taken on a new meaning, says Marcella Bucknam, CPC, CCS-P, COC, CCS, CPC-P, CPC-I, CCC, COBGC, manager of clinical compliance with PeaceHealth in Vancouver, Washington.

Transcription errors, blanks left in transcribed notes the physician never fills in, poorly used templates that create incomprehensible sentences, and using speech recognition software (e.g., Dragon) that creates nonsense are all factors that contribute to incomplete, incorrect, and illegible notes, according to Bucknam.

“Coders who work with the same doctor or doctors over the years get to know their style or what they ‘really mean’ and go ahead and code as though the documentation was correct,” Bucknam says. “Then a payer asks for a copy of the record, and someone who doesn’t already know what’s going on can’t figure out why the patient was seen or what care was provided.”

Jodi Dibble, CPC, medical record coder II of physician services at the Florida Hospital New Smyrna in New Smyrna Beach, Florida agrees that electronic medical records (EMRs) have created many new issues with documentation errors like cloning, cut and paste, and over documentation.

Machelle Morningstar, CPC, COC, CEMC, COSC, AHIMA-approved ICD-10-CM/PCS trainer and owner/consultant at Morningstar Coding and Reimbursement Consultants in Charleston, South Carolina emphasizes how important it is that your documentation is legible and complete.

“Incomplete and/or illegible documentation may lead to liability issues,” Morningstar says. “Issues may include the wrong medication given, another physician or healthcare professional providing the wrong treatment, and coding/billing errors due to lack of correct documentation.”

Tip: Double-check that your documentation is legible and complete.

“Documentation that follows a consistent format, such as a SOAP note, has a much higher chance of inclusion of elements needed for not only coding/billing, but also provides a clearer path for providers that may come after initial treatment and need clear documentation in order to proceed with further treatment,” Morningstar says.

Bucknam shares how coders can collaborate with their physicians to sustain legible documentation.

“Medicare states that when a physician signs his note, he is stating that the information in the note is correct and complete,” Bucknam says. “But when you read the note later, you know that the doctor never read through it. It was signed without reading, and it’s not a good record for billing or for patient care.”

Reviewing the medical record before it goes out the door is the key to avoiding this error, according to Bucknam.

“If there is a referral or a test result or something that needs to be included, be sure it is there,” Bucknam says. “If the note is unsigned, get it signed before you send it.”

Mistake 2: You billed place of service (POS) 16 for visits/services the physician rendered in the patient’s home.

You should only use home service codes 99341-99350 to report E/M services the physician provides for a patient who lives in a private residence such as a private home, apartment, or townhome, according to the Medicare Claims Processing Manual, chapter 12, section 30.6.14.

Tip: Use POS 12 (Home) for home visits.

The home services codes apply only to POS 12, and you cannot report home service codes for E/M services the physician provides in settings other than the patient’s private residence, according to the Medicare Claims Processing Manual chapter 12, section 30.6.14.

Avoid POS 16: On the other hand, the 2017 CPT^® manual defines POS 16 (Temporary lodging) as “a short-term accommodation such as a hotel, campground, hostel, cruise ship, or resort where the patient receives care.”

Mistake 3: You filed duplicate services/claims.

To avoid making this mistake, make sure you submit a legitimate second service, not a duplicate claim.

Medicare has a strict policy to not pay duplicate claims for the same service encounter, according to the January 2015 Medicare Quarterly Provider Compliance Newsletter. Medicare will pay for the first claim that is approved and deny subsequent claims for the same service as duplicates.

Tip: If you haven’t been paid for a first claim, check the claim’s status with your MAC. If you discover an error on your initial claim, follow the MAC’s instructions on how to correct the error instead of submitting a second claim for the same service.