Archive for the ‘OASIS-C’ Category

CODING 2012: ICD-10-CM is Upon Us Next Year

Friday, February 17th, 2012

Agency leaders know that now more than ever, coding is driving payment and is a focus of audit by RACs, MACs, and Z-PICs. It is imperative that the primary diagnosis, primary secondary diagnosis, and sequencing of all codes clearly delineate the picture of the patient and his/her condition. The codes are the Table of Contents in the home health chapter of the book known as the patient clinical record.

Agency leaders want appropriate payment and compliance. Equally important, they want to retain that payment received. At VNAA’s 30th Annual Meeting In early May, 2012 preparing for ICD-10 will be discussed in depth, but what are some of the general concepts and constructs that differ from ICD-9 CM? To prepare for this grand change, what should you do? Commit to learning about ICD-10 CM. It impacts more than just the coding department. Everyone in your agency will be impacted.

CMS is preparing. While Home Health Agencies were focusing on new CY 2011 regulations and plenty of changes last year, agency leaders were aware that there was a change to Version 5010 for handling electronic claims. CMS will still accept Version 4010 claims for a short period. This billing change was necessary in preparation for ICD-10 CM scheduled for October 1, 2013.

The ICD-9 CM Coordination and Maintenance Committee

“Recognizing the ICD-9-CM as a dynamic statistical tool that must be flexible to meet expanding classification needs, the ICD-9-CM Coordination and Maintenance Committee was created as a forum for proposals to update ICD-9-CM.  A representative from the National Center for Health Statistics (NCHS) and one from the Centers for Medicare and Medicaid Services (CMS) co-chair the ICD-9-CM Coordination and Maintenance Committee meetings.  Responsibility for maintenance of the ICD-9-CM is divided between the two agencies, with classification of diagnoses (volumes 1 and 2) by NCHS and of procedures (volume 3) by CMS”. (http://www.cdc.gov/nchs/icd/icd9cm_maintenance.htm).

The ICD-9-CM Coordination and Maintenance Committee’s role is advisory. The Director of NCHS and the Administrator of CMS make all final decisions. Final decisions are made after the December meeting and become effective October 1 of the following year. Official code revision packages, which are referred to as addenda, are available from this site.

The transition to ICD-10 is a major change for the industry. To better effect that transition as well as the Version 5010 to handle electronic claims, the ICD-9-CM Coordination and Maintenance Committee proposed and accepted a partial freeze. This freeze identifies:

  • The last regular annual updates to ICD-9-CM and ICD-10-CM were made October 1, 2011
  • Limited updates to ICD-10 CM for October 1, 2013 (ICD-10-CM is expected to be fully in use in Home Health by 2013)
  • Full regular updates to ICD-10 CM to be reinstituted October 1, 2014

What is ICD-10 CM?

  • ICD-10 CM is the US “Clinical Manifestations” of the World Health Organization (WHO) ICD-10 Code Set.
  • ICD-10 PCS is a US creation for procedure codes only that will essentially be used in the acute care setting.
  • ICD-10 CM brings the US in alignment with the worldwide coding system.
  • ICD-10 CM offers greater coding specificity and accuracy.
  • IVD-10 CM offers increased capability to measure healthcare quality, safety, and efficiency.

Transaction version changes (X12 version 5010) must be in place to handle the new codes and its seven digits, thus the changes for billing this year.

CMS states, ICD-10 is markedly different from ICD-9 and they expect adjustment reaction to cause slowing in payment. Many coding experts believe that, with proper planning, that need not be the case.

“ICD-10 requires changes to almost all clinical and administrative systems. It requires changes to business processes.”  Per CMS

Why Must We Change to ICD-10?

  • ICD-9-CM is over 30 years old.
  • ICD-9 CM has no more room to add new codes or keep pace with current classification of Medical conditions or technological advances.
  • ICD-9 CM is not always precise or unambiguous.

US mortality data is being reported in ICD-10 thus making comparison of mortality and morbidity difficult.

ICD- 10 CM offers:

  • Lower Costs through increased efficiencies
  • Synergistic effects with the Electronic Health Record (EHR)
  • Clearer recognition of medical advances
  • Clearer recognition of technological advances

What are some of the Differences between ICD-9-CM and ICD-10-CM?

ICD-9-CM

17 chapters and V and E code chapters

13,000 disease codes plus V and E codes

3,000 procedure codes in Volume 3

3-5 digits in disease codes

Essentially numeric system

Codes usually do not indicate timing                                                                                            encounters

No differentiation between left/right

ICD-10-CM

21 chapters- V and E codes in disease chapters

68,000 disease codes, including V and E codes

87,000 procedures codes in ICD-10-PCS

3-7 digits in disease codes

Alphanumeric system

Codes specify initial and subsequent encounters

Differentiates between the right and left

Solid understanding of  anatomy, physiology,  and diagnostics will be a must.

In May, come to the session:  Start Preparing NOW for ICD-10 CM Coding and receive a plan for your coding teams’ educational preparation needs with examples of how to review anatomy, physiology, and diagnostic essentials.  It may seem like ICD-10 is far away but, an additional 55,000 diagnostic codes, a change in chapters, and required increased coding specificity to the 7th digit means increased risk for payment and more importantly, increased risk for payment retention. If your payment retention becomes in question, can the MACs, RACs, or Z-PICs be far behind? Could you survive what is coming with the coding preparation you have right now?

This article was written by Susan J. Carmichael MS, RN, CHCQM, COS-C, FAIHCQ, Susan is the Executive Vice President, Chief Clinical Officer and Chief Compliance Officer for Select Data, a national firm providing Revenue Cycle Management services, software, and process solutions to the home health industry for over 20 years. Susan has held C Level positions for nonprofit, and publicly traded home health firms. She has taken agencies to both the American and NASDAQ Stock Exchanges, has grown multi-state Medicare-Medicaid/Private Duty/Staffing agencies by both acquisition and native growth, and is credited with growing one firm from billing $114.00 (first week) to $515,000 per week in less than five years. Susan’s latest publication was The Remington Report, July/August, 2010Recovery Audit Contractors (RACs): Seven Major Changes to the Permanent Program and in the September/October issue: The RAC Attack: How to Prepare and Manage the Audits. Susan is a frequent requested speaker at state association conferences on industry topics, including OASIS, Coding, RACs/MACs/MICS/Z-PIC audits, and Corporate Compliance program essentials.

VNAA is proud to have Select Data as an Associate Member and Member Update Sponsor. Please support our sponsors like Select Data that support VNAA by visiting their Website and checking out their services.

The New Survey Protocols: Are You Ready or How Did You Do?

Tuesday, January 31st, 2012

The CMS new survey protocols have been in effect for over six months. The revised Home Health Agency Survey Protocols and New State Operations Manual are available online. The new survey process is data-driven and patient outcome-oriented with a focus on patient visits and personnel interviews. Though it appears less structured, it is very process-driven.

The new tiered system directs surveyors to focus on quality of care. A detailed list of surveyor probes are provided, outlining questions that may be asked throughout the survey process. Agencies should review the questions outlined for surveyors in order to prepare for the survey process. Preparation for this process will reinforce other patient focused processes. Are you ready? Visit www.cms.gov/Surveycertificationgeninfo/downloads/SCLetter11_11.pdf to read more.

CMS stated surveyors would cite more deficiencies under the new process. After one year, it will be interesting to view the stats.

The Key Focus Areas

Patient Rights

Assessments

Plan of Care

Outcomes and Improvement

Infection Control

The survey process is guided by interpretive guidelines and survey protocols established to provide guidance for surveyors. The surveyor will review the assessment, the medication profile, and physician orders and then evaluate the established plan of care with review of that implementation of the plan of care. Patient and personnel interviews should support the findings of the clinical record.  Prepare personnel for survey interviews so they are familiar with terminology and types of questions they may be asked. Support the interviewees by having them understand that they are the experts in care delivery. They are merely verbalizing the assessment, the care, and the outcomes expected or achieved.

All surveyors are required, by CMS, to utilize these guidelines when evaluating an agency as to compliance with Federal regulation. Remember, the guidelines do not replace regulation and are not allowed to be the basis of any citation, but they provide guidance.  Violations are to be based upon clinical record reviews, interviews with patients, caregivers, and personnel, as well as the agency’s practices in relationship to regulation and agency policies.

“The survey and certification process provides a method for CMS to evaluate HHA compliance with the Conditions of Participation (CoPs), ensuring that patient services provided meet minimum health and safety standards and a basic level of quality. The HHA survey process incorporates an approach that is patient-focused, outcome-oriented and data-driven making it more efficient and effective in assessing, monitoring, and evaluating the quality of care delivered by an HHA…” (Appendix B, p.6).

The surveys are required to have at least one RN on the team.  Surveyors are required to attend the HHA Training Course prior to any survey. They are then required to be in an observational role as part of the training.

Preparing for the Survey

Appoint at least one person, in your agency, to become very familiar with the new survey process. You may want that person to be OASIS certified to readily discuss OASIS conventions. Develop a thorough process-oriented clinical orientation. Be certain all policies and procedures are current and personnel have had the appropriate inservices.

Have a third party or internal coding expert available to answer any questions regarding diagnoses coding conventions, manifestations, and sequencing. A coding audit by an external review agency may give you some peace of mind.

Be certain your clinical lead has reviewed and audited Starts of Care, Resumptions of Care, Recertifications, and Discharges. Be certain the assessments are well documented and the care plans adequately support that proposed Plan of Care.

Be certain the billing (revenue cycle management) audits include the compliance processes that prevent inappropriate billing without a physician order and evidence of all detailed and signed visit notes.

Types of Surveys

The survey process provides for a standard survey, a partial extended survey, and an extended survey. All HHAs must undergo a standard survey.

Initial Certification

The initial certification requires compliance with SS Act 1861(0) (4) as well as 2180 regarding licensing requirements. In addition, follow the guidelines of SS2008 “Early Surveys of New Providers and Suppliers”.

The State Agency (SA) surveyor or the National Accrediting Organization (AO) inclusive of Joint Commission, CHAP, or ACHC with deeming authority conducts the initial certification. At the time of that survey, the HHA must

  • Be operational and have completed the Medicare Enrollment 855A verified by the assigned MAC.
  • Provide nursing and one other therapeutic service (42 CFR 484.14(a).
  • Meet the new capitalization requirements and have completed an OASIS test submission.
  • Have provided care to a minimum of 10 patients requiring SKILLED care.

Standard Survey

This survey is to be a review of the quality of care and services furnished by the HHA as measured by the medical, nursing, and rehabilitative care indicators. The new changes require this survey to review compliance with regulations most related to high-quality patient care. These highest priority standards (regulations) are called Level 1 standards addressing 9 of the 15 CoPs. The thinking is that if the agency is in compliance with these standards, it is in compliance with all CoPs.

Therefore,  “the surveyor can make a determination  that the HHA is in compliance with all CoPs when, after a review of the Level 1 standards, and after completing the required clinical record reviews, home visits, and interviews with patients and HHA staff, he/she does not discover any findings which would support a deficiency citation.”

Partial Extended Survey

This survey occurs when a standard level survey identifies a non compliant Level 1 standard and/or a deficiency practice may exist at a standard or conditional level not examined at the standard survey.  During this survey, the surveyor reviews at a minimum, the Level 2 standards under the same condition which are related to the non compliant Level 1 standards. See Table 1 Level 1 and Level 2 Standards.

Extended Survey

This survey includes a review of all conditions. It may be conducted at any time at the discretion of CMS and is required to be conducted when any conditional level deficiency is identified. The surveyor is required to review all agency policies, procedures, and practices related to the substandard care (one or more condition –level deficiencies).

Recertification Survey

All HHAs are mandated (SS1891) to have a recertification performed no later than 36 months from a previous recertification survey. These surveys are standard unless a Level 1 citation is leveled.

Now, you know the types of surveys. The following chart lists the standard and partially extended surveys with their related priority standards and G-tags. The more you know about the new process, the better prepared you will be for your next survey.

Level 1 and Level 2 Standards Appendix B

Table 1

Conditions                            Standard Survey                Partial Extended Survey

Level 1                                   Level 2

484.10

Patient Rights                          G107, G109                             G101, G108, G111, G114

484.12

Compliance with                     G121                                        G118

Federal, State, Local

Laws

484.14 Organization,               G123, G133, G143,                 G124, G125, G127, G138,

Services and                             G144                                       G139, G150

Administration

484.18 Acceptance                 G157, G158, G159                      G160, G162, G163

Of Patients, Plan of Care,       G164, G165, G166

Medical Supervision

484.30 Skilled                          G170, G172, G173,                     G169, G179

Nursing Services                     G174, G175, G176,

G177

484.32 Therapy                        G186, G187, G188                      G190, G193

484.36 Home Health Aide      G224, G229                               G212, G215, G225, G226, G230

Services                                                                                     G232

484.48 Clinical Records          G236                                        G239

484.55 Comprehensive          G331, G332, G334,                  G339, G341

Assessment of Patients          G445, G336, G337,

G338, G340

The Performance Improvement Plan; Silent but Powerful

Thursday, January 19th, 2012

Among RACs, MACs, MICs, and Z-PIC concerns, along with new survey protocols, new CY 2012 regulations, the advent of 5010, Accountable Care Organizations, and looming ICD-10 CM, what tools can a leader utilize to help mitigate risk? One such tool is the agency Performance Improvement Plan.

Some agencies treat these plans as necessary evils while others embrace the strength of the process and its ability to reduce risk. Recently, we have been asked about initiating a workable, useable, beneficial program.

The Purpose

The purpose of a Performance Improvement Program, Plan, or Process (PIP) is to outline a process that needs improvement. The team that will review the improvement process needs to baseline the present processes seeking efficiencies or other outcomes. This Performance Improvement Plan should support the organization Mission and its Corporate Plan.

Quality Concepts

·            The PIP is established to benefit the organization. It should address an issue or issues that require improvement.

·            The entire organizational team chosen for this Program should be actively included in all phases.

·            Focus on patient or operational outcomes, but try not to take on too many projects at once.

Suggested Patient Care Functions

·            Rights and Responsibilities

·            Ethics and Compliance

·            Assessment and OASIS

·            Adequate Documentation of Care

·            Patient Education and Re-Teaching

·            Continuum and Care Transitions

Agency/Organizational Operations

·            Leadership

·            Ethics and Corporate Compliance

·            HIPAA Privacy and Security

·            Management of Resources

·            Appropriate and Current Policies and Procedures

·            Infection Control

·            Supportive Environment Conducive to Optimum Employee Performance

·            Safety

·            Fiscal Soundness

Responsibility

The Board of Directors approves the Agency Administrator position and the Performance Improvement Program supports with adequate resources and financial support. The Agency Administrator oversees the program or appoints a delegate and assures the Program is continuous, is providing meaningful process monitoring and improvement. Annually, at minimum, results are reported to the BOD.

The Process and the Design

Processes should approach an issue that requires improvement. Processes are designed to be in alignment with the agency mission and strategic plan. They should also be based on evidenced based processes or best practices. They may be benchmarked against other organizations.

Measurement

There needs to be a sound way to collect data. The data will be collected, measured, and analyzed. The goal is to decide the statistical control methods, agree upon how the data will be collected, and determine how it will be measured. Is the agency seeking to evaluate a present process? Design a new process? Assess Performance? Identify areas of Improvement?

Over what period of time will you collect data? Will you evaluate your methods of collection and tools of measurement? Will you evaluate unusual occurrences? Will you keep drilling down until you locate the root cause of the issue?

Assess

The agency should be assessing for improved efficient processes. Will you analyze and discuss new processes so the best process is chosen. Who will be involved? How will they be involved? Will you reevaluate the new processes? When?

Improvement

Buy- in comes with improvement. Be certain that the new processes are truly an improvement. For each issue resolved or impacted, be certain there are clear recommended actions with a responsible party named who will monitor the new processes. Have a timeframe delineated for evaluation as well as evaluation of the “improvement.” Be certain everyone knows the expected outcome. Survey results and identify satisfaction levels.

Buy- In

Buy- in can drive motivation and success. It is important that employees see results for the extra work of the PIP. This process can be applied after Organization Risk Assessments. It teaches problem resolution and hones skill sets. It encourages team building and drives results in an organized fashion. Organizational learning is essential for success. This is one simple way of achieving positive results while reinforcing respect and value for each employee.

Recently, I was speaking with an agency leader, whose firm is known for its Performance Improvement Projects. She has two teams. The key is fun as they attack real problems. Each team identifies projects that impact improved care, outcomes, impact employee morale, or directly impact costs. They present two projects each to the BOD or the Professional Advisory Committee. This allows many to be involved,

Each team defends their chosen project as to benefits derived. They defend the value of the project. Each year the BOD presents a cash bonus and dinner to the team with the best project over the past 12 months. The Leader stated employees via to be on the committees and the PIP are becoming more creative. They are “attacking real problems and finding real solutions we all can live with.” Employees see they are impacting positively on their agency; its care and reputation. They also see the value of group dynamics, peer pressure, and improved performance.

For 2012, the employees have proposed a third team. Leadership is thrilled at that proposal and the fact that she frequently hears, “That should be referred to the PIP, because we can do better.”

Educational Videos: RACs, MACs, Z-PICs, Part II of IV

Thursday, January 19th, 2012

RACs, MACs, Z-PICs, Part II of IV

CERTS – (Comprehensive Error Rate Testing) To better calculate the performance of the FIs and MACs, as well as to look at the reasons for their errors, CMS decided to look at a number of additional rates. The additional rates include

—   provider compliance error (how well providers prepared claims for submission)

—   paid claims error rates (measures how accurately FIs and MACs make coverage, coding, and other claims payment decisions). CERTs randomly select a sample of about 100,000 claims each reporting period.

—  CERTs review the claims for proper Medicare coverage, coding, and billing rules, and if not in compliance, they assign an overall error rate.

CERTs also identify if providers received overpayment letters or notices of adjustments to be made for claims that were overpaid and underpaid. CERTs are considered the Quality Improvement specialists who track and trend the performance of fiscal intermediaries and Medicare Administrative Contractors.

Z-PICs – Zone Program Integrity Contractors will perform Medicare Program integrity functions for CMS. They will interact with each MAC to handle fraud and abuse issues within their jurisdictions. ZPICs are seen to consolidate the work of present CMS Program Safeguard Contractors (PSCs) and Medicare Drug Integrity Contractors (MEDICs) and are divided into 7 zones.

The Z-PICs act with the Department of Justice and FBI and act as the investigators when fraud is very strongly thought to have been found. The Z-PICs have the power to suspend claims for up to a year and the agency has no appeal recourse during that time.  That power can cripple or financially devastate an agency.

HEAT –This auditing body is considered the more aggressive investigator of essentially DME and Home Health.  There has been expansion of DOJ/CMS/HHS Inspector General Medical Strike forces to Baton Rouge, Brooklyn, Detroit, Houston, LA, Miami-Dade, and Tampa Bay and as recently as September, 2011, they have struck, arresting 91.

The HEAT is the technologically oriented auditing body using state of the art analytics to expand the CMS Medicaid provider audit program. This program leadership has meetings with top anti-fraud leaders in Congress/Law enforcement/Private sector.

CMS states that their mission includes, “providing additional resources to our civil enforcement efforts under the False Claims Act to increase dollars recovered; data sharing, including access to real time data; detect patterns of fraud through technology; strengthening partnerships among Federal agencies between public and the private sectors.”

Clearly, with all of the auditing bodies, CMS is making a bold statement; fraud and abuse will not be tolerated.. Unfortunately, in this kind of environment, innocent casualties can occur. Agencies need to take action now.

Educational Videos: RACs, MACs, Z-PICs, Part I of IV

Thursday, January 19th, 2012

RACs, MACs, Z-PICs, Part I of IV

CMS has Unleashed the Auditors

Annually, CMS receives 1.2 billion claims. That breaks down to 4.3 million claims per work day, 574,000 claims per hour, and 9,579 claims per minute. Fraud and abuse are on the rise and the pressure is on.

CMS has unleashed the age of the auditor with the advent of the RACs, MACs, CERTs, MICs, Z-PICs, and now, the HEAT.

RACs- The contingency motivated Recovery Audit Contractors (retrospectively focused). The RAC Demonstration Project of 2005-2007 recovered over $1.3 billion, mostly due to medically unnecessary services (45%), incorrect coding (35%), and insufficient documentation (10%). With four RAC approved firms covering specific geographic regions, these auditors are expected to continue their positive recovery program. The RAC demonstration project yielded a cost of only 22 cents for every $1.00 recovered. They are now in place and ready to go at measure. Certain RACs have been held back until all MACs were in place. That is now completed.

MACs – Medicare Administrative Contractors have been transitioning in and replacing the Regional Home Health Intermediaries (RHHIs). There are 15 MACs with 4 focusing only on DME claims. Though providers fear the RACs, they are well aware of the power of the MAC. This auditing body can impose “severe administrative action” such as up to 100% prepayment review, payment suspension, and use of statistical sampling for over payment estimation of claims (current and prospective focus). MACs have power and Congress is encouraging them to use it.