Wiki Incomplete documentation responsibility

[rchojnowski]

Hello, I work in a healthcare organization with 30+ practices and multiple providers in each. All the coders work remotely with only 2 still located onsite in a practice. If a claim denies for timely filing because a provider did not complete documentation timely even after being reminded by coding, coding is held responsible. Wouldn't this responsibility fall on the practice managers? Are coders held responsible for provider incomplete documentation in any other organization (not private practices) besides ours?

 

[amyjph]

The provider is responsible for their documentation, not coders. Further, that large of an organization/practice must have a compliance policy and procedure on documentation and signature requirements. If a coder notices incomplete/missing documentation and queries and reminds the provider and they still don't do it...?

Is there more to this story than is being stated?

Is an EHR used where there is an "in-basket" or queue of missing/incomplete notes? Is there a dictation log of "to-do"?

I have seen practices actually fine the provider if their documentation is missing or incomplete and causes a charge lag greater than a set time.

 

[rchojnowski]

The provider is responsible for their documentation, not coders. Further, that large of an organization/practice must have a compliance policy and procedure on documentation and signature requirements. If a coder notices incomplete/missing documentation and queries and reminds the provider and they still don't do it...?

Is there more to this story than is being stated?

Is an EHR used where there is an "in-basket" or queue of missing/incomplete notes? Is there a dictation log of "to-do"?

I have seen practices actually fine the provider if their documentation is missing or incomplete and causes a charge lag greater than a set time.

The providers have a task worklist and a sign Que for draft documentation. We do have a policy for the providers with a timeframe they are expected to complete their documentation within. There is no provision for a fine if not complied with unfortunately.

 

[sls314]

The providers have a task worklist and a sign Que for draft documentation. We do have a policy for the providers with a timeframe they are expected to complete their documentation within. There is no provision for a fine if not complied with unfortunately.

In addition to the queue, I'd start keeping a spreadsheet of claims being held up by documentation. I'd talk to your manager about emailing it to the provider, practice manger, and any other appropriate management/supervisory staff at a set interval (weekly? biweekly? monthly?) and perhaps include verbiage about timely filing.

The coding manager at one of our locations sends this out to each provider every Monday. There's a column for the dollar amount, so the provider can see the financial impact if they don't complete the documentation. (It didn't paste here as nicely formatted as it looks in the email, but at least you get the gist.) Claims don't drop off the list until the documentation is complete.

The text of the email says that through X date, there are Y claims for $Z dollars outstanding. Put it back on them and make it clear that coding can't send out claims with no documentation.

SITE	PATIENT NAME	ACCOUNT NUMBER	CPT	DOS	QTY	$	PHYSICIAN	STAFF RESPONSIBLE	NOTES
XYZ Practice	Martin, Angela	987654321​	99999​	10/19/2022​	1​	8300.9​	John Doe, MD	PHYSICIAN
XYZ Practice	Vance, Phyllis	987654321​	88888​	10/19/2022​	3​	2022.36​	John Doe, MD	PHYSICIAN
XYZ Practice	Hudson, Stanley	987654321​	77777​	10/19/2022​	1​	1027.6​	John Doe, MD	PHYSICIAN
XYZ Practice	Philibin, Darryl	987654321​	66666​	10/27/2022​	1​	1204.9​	John Doe, MD	PHYSICIAN
XYZ Practice	Bernard, Andy	987654321​	55555​	11/3/2022​	1​	1017.2​	John Doe, MD	PHYSICIAN
XYZ Practice	Martinez, Oscar	987654321​	44444​	11/7/2022​	1​	1204.9​	John Doe, MD	PHYSICIAN
XYZ Practice	Howard, Ryan	987654321​	33333​	10/3/2022​	1​	1204.9​	John Doe, MD	PHYSICIAN
XYZ Practice	Wallace, David	987654321​	22222​	11/8/2022​	2​	2409.8​	John Doe, MD	PHYSICIAN
					11​	$ 18,392.56

 

[rchojnowski]

In addition to the queue, I'd start keeping a spreadsheet of claims being held up by documentation. I'd talk to your manager about emailing it to the provider, practice manger, and any other appropriate management/supervisory staff at a set interval (weekly? biweekly? monthly?) and perhaps include verbiage about timely filing.

The coding manager at one of our locations sends this out to each provider every Monday. There's a column for the dollar amount, so the provider can see the financial impact if they don't complete the documentation. (It didn't paste here as nicely formatted as it looks in the email, but at least you get the gist.) Claims don't drop off the list until the documentation is complete.

The text of the email says that through X date, there are Y claims for $Z dollars outstanding. Put it back on them and make it clear that coding can't send out claims with no documentation.

SITE	PATIENT NAME	ACCOUNT NUMBER	CPT	DOS	QTY	$	PHYSICIAN	STAFF RESPONSIBLE	NOTES
XYZ Practice	Martin, Angela	987654321​	99999​	10/19/2022​	1​	8300.9​	John Doe, MD	PHYSICIAN
XYZ Practice	Vance, Phyllis	987654321​	88888​	10/19/2022​	3​	2022.36​	John Doe, MD	PHYSICIAN
XYZ Practice	Hudson, Stanley	987654321​	77777​	10/19/2022​	1​	1027.6​	John Doe, MD	PHYSICIAN
XYZ Practice	Philibin, Darryl	987654321​	66666​	10/27/2022​	1​	1204.9​	John Doe, MD	PHYSICIAN
XYZ Practice	Bernard, Andy	987654321​	55555​	11/3/2022​	1​	1017.2​	John Doe, MD	PHYSICIAN
XYZ Practice	Martinez, Oscar	987654321​	44444​	11/7/2022​	1​	1204.9​	John Doe, MD	PHYSICIAN
XYZ Practice	Howard, Ryan	987654321​	33333​	10/3/2022​	1​	1204.9​	John Doe, MD	PHYSICIAN
XYZ Practice	Wallace, David	987654321​	22222​	11/8/2022​	2​	2409.8​	John Doe, MD	PHYSICIAN
					11​	$ 18,392.56

We already do this and have been for over a year to no avail. We have done out due diligence, so not sure why coding dept is still being held accountable.

 

[amyjph]

Agree with Susan. I have done weekly lists with this and the financial impact. Put it in dollars.

 

[rchojnowski]

Agree with Susan. I have done weekly lists with this and the financial impact. Put it in dollars.

We do.

 

[nickelclaw]

I might suggest taking it up with the billing or rev cycle manger in dollars and reason for hold up.

 

[sls314]

We already do this and have been for over a year to no avail. We have done out due diligence, so not sure why coding dept is still being held accountable.

When you say "held accountable" what specifically is happening? Is the department being penalized in some way? The coding manager should be pushing back on that.

 

[nickelclaw]

When you say "held accountable" what specifically is happening? Is the department being penalized in some way? The coding manager should be pushing back on that.

Agree

 

[rchojnowski]

When you say "held accountable" what specifically is happening? Is the department being penalized in some way? The coding manager should be pushing back on that.

I am the coding supervisor. That is why I am looking into if this happens at any other organization to help support my argument that this is not a coder responsibility in a large organization.

 

[nickelclaw]

I wish you the best of luck hopefully teaming up with billing or rev cycle proving loss in revenue will lock it in

 

[sls314]

I am the coding supervisor. That is why I am looking into if this happens at any other organization to help support my argument that this is not a coder responsibility in a large organization.

Ah, gotcha!

I would definitely push back on that. Your staff can't code if the documentation isn't being done. If those claims end up untimely, that's certainly not a coding department issue. It's completely out of your control, and I'd definitely say that it isn't typical at other organizations.

Some organizations even withhold paychecks for physicians who aren't in compliance with timely documentation. Not completing documentation is a big deal beyond just being able to bill the claims. I'd bring this to the attention of compliance, if you haven't already.

 

[sls314]

Here are a few excerpts from our compliance policy, including the part about provider pay withholding. (It would take several steps for a provider to get so far behind that their paycheck was withheld. But if it gets to that point, it would get enforced.)

(1) Providers are responsible for complete and accurate documentation in the patient medical record.
(2) All patient treatment records will be completed and signed off in the medical record within 3 business days unless additional time is needed to acquire testing results or outside documentation. This includes hospital, nursing home, and other types of off-site visits (Out of office encounters).

(4) All Providers and Manager receive weekly reports of unlocked encounters.
(5) Provider’s office is responsible for monitoring their Unlocked/Encounters Without
Claims reports.
(a) Providers and office managers will receive reports on a weekly basis to
their {Company Name} email accounts.
(b) Providers and/or Offices that have unlocked patient treatment notes that
are 10 days or older will be asked to submit an action plan of how they
plan to become compliant with the policy. This plan must be submitted to
the Compliance Committee within 7 days of notification that they are
noncompliant.
(c) Physicians that do not successfully complete their action plan will have
their pay withheld until they are compliant with the policy.