Over the past several weeks, we have seen unprecedented changes to rules, edits, and other measures traditionally put in place to stave fraud, waste, and abuse in the healthcare industry. The changes happen so fast and so often with Telehealth services, I could be presenting a Webinar one day, and within hours it can be considered dated with new changes and direction from CMS.
Also, the floodgates have been opened when it comes to the Telehealth services, not only on what is considered Telehealth but the expanded rules on who are the approved qualified providers.
I have always believed that there was a place for Telehealth before COVID-19 and tried to encourage practices to open their minds to the concept, at least for established patients. Now the rules from the Medicare perspective were a bit behind the technology curve and were very limited in their reimbursement policies. But since the PHE (Public Health Emergency) was declared, physicians and other healthcare providers have been thrown into the telehealth fire, and it has been mandatory for them to engage in this delivery of services to stay solvent.
Unfortunately, each week, we see another iteration of the rules being changed. The most current iteration involves the allowance of telemedicine and telehealth by nearly any practitioner, including physical therapy, occupational therapy, and speech and language therapy. At some point, however, the continued relaxing of rules will undoubtedly become permanent rules to some extent. I do expect some rollbacks of course, but without having a crystal ball, I firmly believe that it is more difficult to take something away after it has been given than to give something that was not previously available.
Now in saying that, and being an auditor, the Evaluation and Management services have always been an easy target for CMS to use for audit target practice and there has to be a fraud and abuse line drawn at some point, because of all of the money being paid for telehealth services. Also, where is that line on what can “really” be delivered digitally? When I start getting calls (and I have) from Acupuncturists asking how they can tap into the telehealth delivery, I had to throw the question back, Where is the line that gets drawn on the use of this technology? Can acupuncture services, physical therapy, and/or occupational therapy truly exist in a virtual environment? I do not know the answer, but there are certainly treatment modalities that require that special “hands-on” that only comes from true face to face care, and having a parent or patient friend in the background as the acting agent for the on-the-phone provider seems a bit suspect to me. Just as a dentist is not able to perform a procedure in a virtual environment, there has to be a limitation placed on how telemedicine and telehealth are really implemented.
In a recent blog post, on Advizehealth.com, I read a discussion that the author had with someone, and there was an analogy made between taking a virtual yoga class via a social media platform and having a physical therapist oversee exercises in the home. Their main contention was that physical therapists can take empirical measurements, make hands-on corrections, and take action with the patient to ensure that the patient is making progress. Keep in mind that Medicare is very specific regarding the circumstances under which it will pay for such therapies. Please understand that I am by no means taking issue, per se, with physical, occupational, or speech therapy modalities. But I agree with that blog post, in that, each instance where telemedicine and telehealth are expanded to peripheral treatment regiments really will have additional collateral consequences.
My main concern is when audits start flooding in. A contact of mine, on a popular business social medial platform, who is also a retired HHS fraud investigator, recently wrote an article on the “when” audits return, not “if”. Mr. Rubenstein wrote, “Evaluation and Management audits have always been on payers’ radars, and the future telemedicine audits are going to be no different. Big money is being paid out, and big money will be sought for poor documentation.” I invite you to read his article; it will change your mindset on compliance and make sure that you are doing things right from the get-go.
Read the full source article at:
The practice of cloned or copy and pasted documentation is a significant issue in the use of electronic health records (EHRs). A recent study in the Journal of the American Medical Association, found that of hundreds of progress notes examined by researchers, just 18% were newly entered by clinicians (Wang, 2017).
Medicare (CMS), defines cloned documentation as “multiple entries in a patient’s health record that are exactly alike or similar to other entries in the same patient’s health record or another patient’s health record” (CMS, n.d.) Terms used for duplicative documentation also includes cloning, copy and paste, copy forward, macros, and save notes as a template.
Let me explain:
There are several issues with “cloned noting” that can be a red-flag for a potential audit in your clinics and offices as well.
First, Inappropriate use of cloned documentation can damage the trustworthiness and integrity of the record for patient care. There are also reimbursement implications of cloned documentation that lack patient-specific information necessary to support medical necessity requirements for services rendered to an individual patient.
The OIG (Office of Inspector General) issued the following statement in 2013, concerned with copy and paste practices:
Copy-pasting, also known as cloning, allows users to select information from one source and replicate it in another location. When doctors, nurses, or other clinicians copy-paste information, but fail to update it or ensure accuracy, inaccurate information may enter the patient’s medical record and inappropriate charges may be billed to patients and third-party health care payers. Furthermore, inappropriate copy-pasting could facilitate attempts to inflate claims and duplicate or create fraudulent claims.
Over documentation is the practice of inserting false or irrelevant documentation to create the appearance of support for billing a higher-level of service. Some EMR/EHR. Technologies auto-populate fields when using templates built into their system. Other systems generate extensive documentation on the basis of a single click of a checkbox, which if not appropriately edited by the provider, may be inaccurate. Such features can produce information suggesting the practitioner performed more comprehensive services than were actually rendered.
Since the beginning of EHR/EMR implementation many reputable sources have weighed in on the risks associated with copy and paste practices. AHIMA, several MAC contractors, such as Noridian and FCS Options, and Palmetto have voiced their opinions loudly.
Noridian Healthcare Solutions, LLC (the biggest MAC payer in the U.S.), created a local coverage determination (LCD) guidance on using E.H.R. templates when documenting a patient encounter, specifying:
Documentation to support services rendered needs to be patient specific and date of service specific. These auto-populated paragraphs provide useful information such as the etiology, standards of practice, and general goals of a particular diagnosis. However, they are generalizations and do not support medical necessary information that correlates to the management of a particular patient. Part B medical records are seeing the same auto-populated paragraphs in the HPIs of different patients. Credit cannot be granted for information that is not patient specific and date of service specific.
The integrity of the health record should be protected at all costs. Our consultants at NSCHBC can assist you in how to incorporate policies and procedures to protect your records.
It is never too late to be proactive with continued implementation of EHRs that continue to come with the risk of misuse copy and paste functionality. We are here to provide guidance on this issue and make sure you are complaint in your practices, ensuring the integrity of documentation used for patient care. We invite you to search our consultant panel on the “Find A Consultant” tap of the NSCSBC website. We are here to help.
Do you magically become a professional when you obtain a certificate that says you attended school for a certain amount of time? There are ways to represent professionalism, but what does it really mean to you?
Let’s examine what it means to be professional:
Merriam-Webster Dictionary defines professionalism as:
The conduct, aims, or qualities that characterize or mark a profession or a professional person.
They also define a profession as:
A calling requiring specialized knowledge and often long and intensive academic preparation.
Being a professional is potentially a combination of acquired education in addition to a few other qualities. Not all professionals have the top degrees in their field of expertise. However, these individuals have dedicated many hours of time and effort to master the knowledge they need to be successful and they recognize the importance of sustaining that knowledge by keeping it up to date.
For example, Certified Professional Coders (CPCs®) seek ways to earn Continuing Education Units (CEUs) to maintain their credentials and to keep current with medical coding changes and healthcare regulations. (Those of you on listening to my CodeCast Podcast to receive the latest changes, updates, and current medical business issues are hopefully entertained as well!)
Another important step to professionalism is to look the part that you are trying to emanate. This means portraying your outward appearance in the best possible light.
Dress for success does not always require a three-piece suit. If it did then I would be out of the club for sure!
Be polished and dressed appropriately for the environment you work in. Whether you are the slacks and blouse gal, the khaki’s and polo guy, or the scrubs and an office uniform, make sure your hair is brushed, teeth are clean, your face is washed, and you look presentable: not only to patients walking in, or physician you’re meeting with, but for your fellow employees as well.
Also, make sure you always have mints with you, not gum… especially if you drink coffee. No one will tell you so I will!
You need an Altoid… and for those of you that brush your teeth, but feel the need to take a bite of your kid’s Peanut Butter Captain Crunch on the way out the door, you need not one, but two mints. (That’s all I’m saying!)
Being a professional not only requires specialized knowledge, but also the highest level of competency.
You can depend upon a professional to accomplish the task set before them:
That’s why I decided to start the Codecast® Podcast. If I can help one of you, inspire one of you, or make you feel like you are on the right path professionally, then that only makes me better personally and professionally.
Professionals exhibit qualities such as honesty and integrity. They are true to their values, even when it means taking the road less traveled.
If you know me at all, I am someone who colors outside the lines, but within the bounds of professionalism. I always try and look at everyone’s point of view, not just mine, and where can I improve and find opportunities to share with you.
Being a healthcare professional provides the opportunity to achieve professionalism every day. We learn from each other; but even more importantly, there’s always a chance to pass what we have learned on to someone else.
We demonstrate excellence in how we relate with others, as well as how we perform our responsibilities. We recognize teamwork as an important component of our professional conduct. We show the diversity that enhances learning and knowledge which is so important to professionalism
Medical coders succeed through the most difficult obstacles because we are determined to identify as professionals. Although being a certified medical coder is only one of many professions, all professions have their own criteria to demonstrate professionalism ― but the root definition of professionalism in each one remains consistent.
Sometimes the smallest things can make all of the difference when you are a boss, supervisor, administrator, team leader, manager, etc, trying to have the face of credibility but also respect.
One way to keep that respect, is to learn when you need something or you need someone of your team members to respond to you, there is a way to email and then is a way to “Email like a Boss”.
Follow these 9 steps and you will find your emails will have a managerial tone that will reap more respect than in the past.
So let’s not say this. When you email. I can see the writer starting off with “Sorry for the delay…” but that just means you aren’t meeting your deadlines. Try, “Thank you for your patience… I have completed and attached…”
This shows your took your time and it is correct.
How many times have you thought this? It can be exasperating I know when your staff or even your physicians so not have respect for your schedule. So you may start an email like, “What works best for you?” Well if it is your schedule too, try this instead: “Could you do ____: _______ on _________? That is best for me”.
No one likes a boss who thinks out loud that way. Also, when you say in an email, “No problem, no worries…” that really sounds like it was a problem but I did it anyway. Try, “I am always happy to assist, let me know if you need anything else.”
That should get at least a thank you.
Of course you do. You have been working there how many years now? So why start an email with, “I think maybe we should….?” That doesn’t say that you know what you are doing. Instead, “It would be best if we ________________…”
Do not rewrite your email for 40 minutes wasting even more time. Send a quick note, “It would be easier if we discussed this in person. Please come to my office at __________” Remember, you’re the boss.
Or, “Hopefully that makes sense?”
This only annoys the person on the other end, because what if it doesn’t? Be open to feedback, your email should say, “Let me know if you have any questions or need a clarification.”
So, you sent an email days ago, and still haven’t hear and are ready to say, “Where the heck are we on this?” or “Just wanted to check in.” Never say the either but the latter means the staff doesn’t have to be accountable. Your email should be direct and it calls them out on their lack of communication.
Nothing bothers be more then being ignored and no follow up.
Instead of saying, “I made a small error,” or “Ahhh sorry! My bad. Totally missed that,” give credit where credit is due.
“Nice catch! Updated file attached. Thanks for letting me know.” That shows you also respect your staff and their knowledge well and they will keep it to themselves.
People like spreading the negative more than the positive.
You have a personal appointment to attend to and your immediate boss is not that flexible.
If it is important, take control as a boss, “I will need to leave for ___________ at _____:_____. “
Simple as that. But be honest.
Hopefully, you can see with these little tweaks to your email, your approach, and how you come across will not only lend to your credibility, but also to your professionalism.
A career as a remote coder allows you to work remotely in the healthcare field and use your computer skills to access what you need to fulfill the job requirements of an onsite coder or billing professional.
Remote medical coders are typically set up through their employer’s/medical practice’s IT department to access the patient medical records remotely and the practice management software for billing and coding. Most tasks are data entry input related, but many remote coders that work outside the healthcare facility, typically from home, have additional tasks beyond the data entry of codes, and some employers do ask that the remote coder be onsite at least 2-4 times a month.
Successful remote coders will need to be attentive and pay close attention to details to avoid making mistakes. For those working from home, who can set their own hours, will also need to be disciplined and focus to stay on track to meet deadlines. The table below gives you and idea of the educational requirements for most remote coders.
|Degree Required||Associates degree common, or coding certification equivalent|
|Education Field of Study||Health Information Technology (HIT), Revenue Cycle Management (RCM) or Professional and/or Facility Coding|
|Certification||Most healthcare employers require a “coding certification” of some kind to prove experience in the field of coding, billing and reimbursement, and health IT**|
|Key Responsibilities||Use ICD-10 and CPT codes corresponding to various diagnoses and procedures and enter them into medical software, keep records, insurance claim submission and follow up.|
|Job Growth (2014-2024)*||15% (for all coding professionals, medical records and health information technicians)|
|Median Salary (2017)*||$37,110 (for all medical records and health information technicians)
$41,500 (for most coding professional remote positions with minimum 3-years experience)
*Source US Labor Statistics
** See below for Certification options
If you want to get “certified” as a coder (there is not a specific certification for remote coders), and I highly recommend you do, there are many options. For hospital facility coders, AHIMA (American Health Information Management Association ~ www.ahima.org ) has several certification options, such as CCS (Certified Coding Specialist), RHIT (Registered Health Information Technician) and CCA (Certified Coding Associate) to name a few.
The AAPC (American Academy of Professional Coders ~ www.aapc.com ) has physician based certifications, also known as “pro fee” coding certifications such as the CPC (Certified Professional Coder) and AAPC offers specialty certifications in areas like, Cardiology (CCC), Interventional Radiology (CIRCC), E/M coding (CEMC) and more. There are other certification options from Board of Medical Specialty Coding (www.medicalspecialtycoding.com), QPro formerly PAHCS (www.QPro.com)
Although the implementation of remote coding can be straightforward and seemingly easy to implement, you need to address a number of issues before sending coders home. These included:
Before implementing a remote coding program, ask ALL of the workers who will be working at home to sign a written telecommuting agreement. This establishes expectations for everyone involved, including managers and coders who will have very little direct supervision. It also establishes what the coders can expect from support and management staff.
The agreement should address issues such as:
If all of these issues are outlined at the start, there will be much less confusion, which will contribute to the program’s overall success.
To recognize and reinforce the importance of the confidentiality of the online record, a separate confidentiality agreement should be developed and incorporated. This document should address the office location within the home, the need for a separate secure location that will not be accessible when the coder is not working, the security of the information on the PC (and a computer that no one in the family has access to), and the need to sign off the application when the coder is not physically in front of his or her PC. Once the employee has reviewed and signed this agreement, there should be no questions regarding expectations about confidentiality and security.
Before implementing a remote coding system, here is a sample of questions to ask:
Being allowed the opportunity to be a remote coder, and not have to commute, deal with weather or traffic, office drama, coming in sick, etc, is a privilege not a right. If you are given the opportunity, it is up to you to respect the process and make sure you have what it takes to be a successful remote healthcare professional.
My daughter has one more semester of student teaching before she is a full-fledged high school teacher at 23 years old. After countless hours of hard work, test preparation and college classes to achieve her undergrad degree and now her post-grad credential, my girl is about to embark on the most significant growth journey of her life and I am so excited for her.
Of course, none of this would have been possible had she not reached for the stars and put herself out there.
Sadly, as adults, we get to a point in our careers where we stop pushing ourselves. We plateau and settle for less, incorrectly believing our time for growth has passed and that it’s too late.
But it doesn’t have to be that way. American author Zig Zigler famously said:
There are 3 C’s in life: Choice. Chance. Change. You must make a choice to take a chance, or your life will never change.
If you’d like to make career progress, (and honestly who doesn’t want that?), look at these elements:
Choice is all about shifting your mindset. It can be so tempting to ride that wave of familiarity, especially if everything in your career or job is going well. But at some point, you’ll decide that good isn’t good enough. Maybe you have that, nagging feeling in the pit of your stomach telling you something needs to give. You want something more, something different, something new, even if you’re not sure what that is.
When you make a conscious choice to do something, you’re taking the first step toward growth. Action is empowering and contagious; inaction breeds stagnation.
Have you been going back and forth in your mind about taking a leap of faith? Maybe harboring some fear about the unknown? This is understandable, but don’t let it paralyze you. Challenging yourself to leave your comfort zone helps you stretch your wings, gain new skills and insight, experience and confidence.
Still unsure about taking that chance? Ask yourself if what you are doing today is getting you closer to where you want to be tomorrow. Remember any shot you don’t take you will miss 100% of the time.
Change sometimes gets a bad rap. You have heard me say in the past on my podcast, “change isn’t good, good change is good”, because change is often seen as a disruptor. When one thing changes, others usually follow suit. But if you flip that around, you’ll see that change is the antithesis to the status quo. Change shakes things up and breathes new life into old methods and routines. We’re forced to get out of ruts we may not even know we’ve been in, to view things differently with a fresh perspective. It’s about envisioning what’s possible, not just what is.
That being said, change requires a degree of focus and intentionality. If you want something you’ve never had, you have to do something you’ve never done. It’s not too late.
Remember, it starts with a choice; choose wisely.