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Page 1: Presented by: David Klein, CPC, CPMA, CHC...On October 1, 2019 the 2020 ICD-10 codes went into effect. This year there were 273 new codes, 30 revised codes and 21 deleted codes, bringing

Presented by:

David Klein, CPC, CPMA, CHC

Page 2: Presented by: David Klein, CPC, CPMA, CHC...On October 1, 2019 the 2020 ICD-10 codes went into effect. This year there were 273 new codes, 30 revised codes and 21 deleted codes, bringing

THIS PRESENTATION WAS CREATED IN ORDER TO HELP HEALTH CAREPROFESSIONALS, MEDICAL BILLING PERSONNEL, CODERS AND OTHERSUPPORT PERSONNEL TO BETTER UNDERSTAND THE RAPIDLY CHANGINGMEDICAL/HEALTHCARE ENVIRONMENT. DOCUMENTATION, BILLING AND CODINGDECISIONS SHOULD NOT BE SOLEY BASED UPON INFORMATION CONTAINEDIN THIS PRESENTATION. INDIVIDUAL CIRCUMSTANCES , LEGAL AND ETHICALCONSIDERATIONS AS WELL AS PAYER POLICIES SHOULD ALWAYS BECONSIDERED WHEN DETERMINING A PARTICULAR COURSE OF ACTION. THISPRESENTATION AND CONTENTS HERIN SHALL NOT BE CONSTRUED AS LEGALADVICE NOR AS ESTABLISHING A CLIENT-ATTORNEY RELATIONSHIP.RESOURCES ARE PROVIDED FOR EDUCATIONAL AND AWARENESS PURPOSESONLY, AND AS SUCH, ARE PROVIDED STRICTLY AS SAMPLES. IF YOU HAVEQUESTIONS OF A LEGAL NATURE, YOU SHOULD CONTACT AN ATTORNEY ATLAW. THE PRESENTER MAKES NO WARRANTIES, EXPRESS OR IMPLIED,REGARDING ANY SUCH RESOURCES. RECORDING, COPYING OR OTHERWISEREPRODUCING THIS PRESENTATION IN ANY WAY IS STRICTLY PROHIBITEDWITHOUT PRIOR WRITTEN CONSENT FROM DK CODING & COMPLAINCE, INC.

DISCLAIMER & TERMS

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Page 3: Presented by: David Klein, CPC, CPMA, CHC...On October 1, 2019 the 2020 ICD-10 codes went into effect. This year there were 273 new codes, 30 revised codes and 21 deleted codes, bringing

It’s not Just Documentation that tells the Story

Everything we do in Practice Tells a Story, for

example:

✓ Cervical Sprain/Strain indicates whiplash injury

✓ Level 1 established Exam indicates a problem

that will self resolve

✓ -59 modifier indicates separate site/organ

system was treated

✓ Our fee schedule reflects how we value our

skills

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Page 4: Presented by: David Klein, CPC, CPMA, CHC...On October 1, 2019 the 2020 ICD-10 codes went into effect. This year there were 273 new codes, 30 revised codes and 21 deleted codes, bringing

Patient Responsibility Insurance Responsibility

Problem 1: Insurance is paying for less and less

What’s Happening

in the Health Care Industry?

The Line is Shifting

The Line is Getting Clouded

Problem 2:Benefits are getting more complex

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Page 5: Presented by: David Klein, CPC, CPMA, CHC...On October 1, 2019 the 2020 ICD-10 codes went into effect. This year there were 273 new codes, 30 revised codes and 21 deleted codes, bringing

The Impact on Practices

Page 6: Presented by: David Klein, CPC, CPMA, CHC...On October 1, 2019 the 2020 ICD-10 codes went into effect. This year there were 273 new codes, 30 revised codes and 21 deleted codes, bringing

MONEY

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Page 7: Presented by: David Klein, CPC, CPMA, CHC...On October 1, 2019 the 2020 ICD-10 codes went into effect. This year there were 273 new codes, 30 revised codes and 21 deleted codes, bringing

Compliance is like the speed limit →The faster you go the more likely you are to be pulled over...

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Page 8: Presented by: David Klein, CPC, CPMA, CHC...On October 1, 2019 the 2020 ICD-10 codes went into effect. This year there were 273 new codes, 30 revised codes and 21 deleted codes, bringing

CERT Audits

RAC Audits

Types of Post Payment Audits

Commercial/ZPIC Audits

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Page 9: Presented by: David Klein, CPC, CPMA, CHC...On October 1, 2019 the 2020 ICD-10 codes went into effect. This year there were 273 new codes, 30 revised codes and 21 deleted codes, bringing

Post Payment Audits are very seldom “Random”

How is a Practice Selected for an audit?

✓ Provider “profiling”

✓ Complaints from a disgruntled patient

✓ Complaints from a former employee

✓ Advertising

✓ Submitting claims for care of family

members and/or employees

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Page 10: Presented by: David Klein, CPC, CPMA, CHC...On October 1, 2019 the 2020 ICD-10 codes went into effect. This year there were 273 new codes, 30 revised codes and 21 deleted codes, bringing

• Any healthcare provider submitting claims to any third-party payer – regardless of participation status.

• If you are an in-network provider, the carrier’s right to audit you is usually set forth in your Participating Provider Agreement.

• If you are an out-of-network provider, the carrier’s right to audit you stems from case state statutes and/or regulations.

Page 11: Presented by: David Klein, CPC, CPMA, CHC...On October 1, 2019 the 2020 ICD-10 codes went into effect. This year there were 273 new codes, 30 revised codes and 21 deleted codes, bringing

The tools commonly employed by SIU Agents when conducting an Audit are:

• A request for production of records;• Submission of questionnaires/surveys to patients;• Conducting interviews with patients;• Conducting interviews of current and former

employees;• Telephone conferences and/or meetings with the

provider; and• In rare circumstances, sending an agent into a practice

undercover.

Page 12: Presented by: David Klein, CPC, CPMA, CHC...On October 1, 2019 the 2020 ICD-10 codes went into effect. This year there were 273 new codes, 30 revised codes and 21 deleted codes, bringing

Contact your Healthcare Attorney and/or a Certified Auditor and Coder

◦ Make sure they have experience with the type of audit you are undergoing.

◦ Attorney Client Privilege

Do not simply send in the records – you must have a game plan

◦ Many times Providers send in too little or too much

◦ Drawing attention to key aspects of documentation is critical

If you have audit insurance, make sure to contact the carrier to find out

◦ Ask if your attorney is on the panel or can be added

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Page 13: Presented by: David Klein, CPC, CPMA, CHC...On October 1, 2019 the 2020 ICD-10 codes went into effect. This year there were 273 new codes, 30 revised codes and 21 deleted codes, bringing

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Page 14: Presented by: David Klein, CPC, CPMA, CHC...On October 1, 2019 the 2020 ICD-10 codes went into effect. This year there were 273 new codes, 30 revised codes and 21 deleted codes, bringing

➢ Overutilization of E/M Codes

➢ No Transition from Passive to Active care

➢ Up-coding a service without justification

➢ Improper use of modifiers – e.g. -59 modifier

constantly used.

➢ Billing for Tests as a matter of course

➢ Pattern Billing

➢ Overutilization in general

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Page 15: Presented by: David Klein, CPC, CPMA, CHC...On October 1, 2019 the 2020 ICD-10 codes went into effect. This year there were 273 new codes, 30 revised codes and 21 deleted codes, bringing

Step 1:

Know the Rules and how you compare to your Peers to the best of your ability

Solving the Problem

Requires 3 Basic Steps

Step 2:

Lift the cloud… so the line can be seen and know where your reimbursement should be

Step 3:

Do everything you can to protect your Practice from Recoupment

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Page 16: Presented by: David Klein, CPC, CPMA, CHC...On October 1, 2019 the 2020 ICD-10 codes went into effect. This year there were 273 new codes, 30 revised codes and 21 deleted codes, bringing

Quality Payment Program

2

Documentation Errors By Chiropractic According to OIG 2005

Report

ElementPercentage of Documentation Errors

by Doctors of Chiropractic

Evaluation: Improper of missing 34%

Diagnosis: Improper or missing 33%

Treatment Plan: Insufficient 83%

Medical Necessity: not shown or miscoded

67%

Contraindications not checked 66%

While the Error rate reduced from 94% in 2005 to 51% in 2015 the

same issues seem to be affecting documentation by Chiropractors.

Page 17: Presented by: David Klein, CPC, CPMA, CHC...On October 1, 2019 the 2020 ICD-10 codes went into effect. This year there were 273 new codes, 30 revised codes and 21 deleted codes, bringing

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Page 18: Presented by: David Klein, CPC, CPMA, CHC...On October 1, 2019 the 2020 ICD-10 codes went into effect. This year there were 273 new codes, 30 revised codes and 21 deleted codes, bringing

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Page 19: Presented by: David Klein, CPC, CPMA, CHC...On October 1, 2019 the 2020 ICD-10 codes went into effect. This year there were 273 new codes, 30 revised codes and 21 deleted codes, bringing

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Page 20: Presented by: David Klein, CPC, CPMA, CHC...On October 1, 2019 the 2020 ICD-10 codes went into effect. This year there were 273 new codes, 30 revised codes and 21 deleted codes, bringing

Know The Rules

Page 21: Presented by: David Klein, CPC, CPMA, CHC...On October 1, 2019 the 2020 ICD-10 codes went into effect. This year there were 273 new codes, 30 revised codes and 21 deleted codes, bringing

There Is Way Too MuchMis-Information

The Code Definitions -- CPT-4 and ICD-10 – became “Federal Law” as a result of the HIPAA Transactions Rule in 2002. See 45 CFR 162.923(a), 162.1001-1011.

Three Coding Resources Every Office should have

AMA’s CPT, Professional Edition

HCPCS Level II (for DME and other items)

ICD-10-CM

*Consider also: AMA CPT Assistant

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Page 22: Presented by: David Klein, CPC, CPMA, CHC...On October 1, 2019 the 2020 ICD-10 codes went into effect. This year there were 273 new codes, 30 revised codes and 21 deleted codes, bringing

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Example:

Professional CPT Manual 2019

Page 23: Presented by: David Klein, CPC, CPMA, CHC...On October 1, 2019 the 2020 ICD-10 codes went into effect. This year there were 273 new codes, 30 revised codes and 21 deleted codes, bringing

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CPT Assistant, May 2010 page 9

Medicine: Physical Medicine and Rehabilitation, 97110, 98940 (Q&A)

Question: Is it appropriate to report codes 97110-97124, if the procedure were performed at the same region as Chiropractic Manipulative Treatment (CMT)?

Answer: Yes. The physical medicine and rehabilitation procedure codes, 97110-97124, represent distinctly separate and unrelated procedures, which are not considered inclusive of CMT as described by codes 98940-98943. Therefore, when the procedure is distinct from the manipulation, it would be appropriate to report codes 97110-97124 in addition to CMT, when performed at the same anatomic site (i.e., separate body regions are not required).

Page 25: Presented by: David Klein, CPC, CPMA, CHC...On October 1, 2019 the 2020 ICD-10 codes went into effect. This year there were 273 new codes, 30 revised codes and 21 deleted codes, bringing

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CPT Assistant, August 2005 page 11

Medicare Coding Update: Units of Service Reporting of Outpatient

Rehabilitation CPT Codes

“…From a CPT coding perspective, some of the physical medicine services are timed codes based on a 15-minute unit. Multiple units can be billed on a date of service for one or more procedures based on the aggregate amount of time spent by a qualified healthcare professional in direct contact with the patient. As with any 15-minute timed code, it is important to recognize that a substantial portion of 15 minutes must be spent in performing the pre-, intra-, and post service work in order to report the timed code. If only a few minutes are spent performing the physical medicine service, either the code should not be billed or modifier 52 should be appended to the code (See December 2003 CPT Assistant, "Coding Communication: Physical Medicine and Rehabilitation Services, Part I")”

Page 27: Presented by: David Klein, CPC, CPMA, CHC...On October 1, 2019 the 2020 ICD-10 codes went into effect. This year there were 273 new codes, 30 revised codes and 21 deleted codes, bringing

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AMA CPT Assistant, March 2014 page 15

Frequently Asked Questions: Medicine: Physical Medicine and Rehabilitation

Question:

When reporting the Physical Medicine and Rehabilitation time-based codes (97110-97548), is it appropriate to report these services with modifier 52, Reduced Services, if less than 15 minutes was spent treating the patient, or when the treatment lasts less than eight minutes? When taking into consideration the following statement published in the August 2005 issue of CPT® Assistant, "For the purpose of determining the total time of a service, incremental intervals of treatment at the same visit may be accumulated," how would the following scenario be reported: At 8 am, the therapist provides seven minutes of treatment described by code 97110; at 8:15 am, the therapist provides 23 minutes of treatment described by code 97112; and at 8:45 am, another eight minutes of treatment described by code 97110 was provided?

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AMA Answer:

“When codes do not contain specific language in the guidelines, code descriptors, or parenthetical statements other than an increment of time, the guidelines for time in the introduction section of the CPT code set provide the following instructions: "A unit of time is attained when the mid-point is passed. For example, an hour is attained when 31 minutes have elapsed (more than midway between zero and sixty minutes). A second hour is attained when a total of 91 minutes have elapsed. When codes are ranked in sequential typical times and the actual time is between two typical times, the code with the typical time closest to the actual time is used (CPT 2014; page xv)." Therefore, in response to the first question and based on the time guidelines provided in the CPT code set, it is not appropriate to append modifier 52, Reduced Services, to codes 97110-97546. To further clarify, in order to report code 97110, Therapeutic procedure, 1 or more areas, each 15 minutes; therapeutic exercises to develop strength and endurance, range of motion and flexibility, a minimum of eight minutes of therapeutic exercises need to be performed. Services of less than eight minutes would not be reported…”

Page 29: Presented by: David Klein, CPC, CPMA, CHC...On October 1, 2019 the 2020 ICD-10 codes went into effect. This year there were 273 new codes, 30 revised codes and 21 deleted codes, bringing

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Extraspinal CMT: 98943

December 2013 page 15Medicine: Chiropractic Manipulative Treatment

Question: Is modifier 51, Multiple Procedures, applicable to chiropractic manipulative treatment (CMT) codes (98940-98943)? The National Correct Coding Initiative (NCCI) edits indicate that modifier 51 does not apply to these procedures as they are considered separate and distinct; however, these codes do not appear in the list of CPT codes exempt from modifier 51 in CPT® 2013.

Answer: Modifier 51 should not be appended to the CMT codes. These are separate and distinct procedures and the use of modifier 51 does not apply. ♦

Page 30: Presented by: David Klein, CPC, CPMA, CHC...On October 1, 2019 the 2020 ICD-10 codes went into effect. This year there were 273 new codes, 30 revised codes and 21 deleted codes, bringing

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How do I code for Cupping?

November 2016 page 9c

Question: Is code 97799, Unlisted physical medicine/rehabilitation service or procedure, the appropriate code to use to report a cupping procedure (suction cups) performed by an acupuncturist?

Answer: No, cupping is considered a modality (ie, any physical agent applied to produce therapeutic changes to biologic tissue) and should be reported with code 97039, Unlisted modality (specify type and time if constant attendance). When reporting an unlisted procedure code, it is necessary to submit supporting documentation (e.g., procedure report) along with the claim to provide an adequate description of the nature, extent, and need for the procedure; and the time, effort, and equipment necessary to provide the service.

Page 31: Presented by: David Klein, CPC, CPMA, CHC...On October 1, 2019 the 2020 ICD-10 codes went into effect. This year there were 273 new codes, 30 revised codes and 21 deleted codes, bringing

2013 Definition:

L0631 - “Lumbar-sacral orthosis, sagittal control, with rigid anterior and posterior panels, posterior panels, posterior extends from sacrococcygeal junction to a T-9 vertebra, produces intracavitary pressure to reduce load on the intervertebral discs, includes straps, closures, may include padding, shoulder straps, pendulous abdomen straps, pendulous abdomen design, prefabricated, includes fitting and adjustment.”

2014 Definition:

L0631 - Lumbar-sacral orthosis, sagittal control, with rigid anterior and posterior panels, posterior extends from sacrococcygeal junction to T-9 vertebra, produces intracavitary pressure to reduce load on the intervertebral discs, includes straps, closures, may include padding, shoulder straps, pendulous abdomen design, prefabricated item that has been trimmed, bent, molded, assembled, or otherwise customized to fit a specific patient by an individual with expertise

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Page 32: Presented by: David Klein, CPC, CPMA, CHC...On October 1, 2019 the 2020 ICD-10 codes went into effect. This year there were 273 new codes, 30 revised codes and 21 deleted codes, bringing

On October 1, 2019 the 2020 ICD-10 codes went into effect. This year there were 273 new codes, 30 revised codes and 21 deleted codes, bringing the total number of codes up to 72,184. Fortunately, these changes are unlikely to have much impact on the average Physical Medicine Practice however, here are a couple of them to be aware of:

Page 33: Presented by: David Klein, CPC, CPMA, CHC...On October 1, 2019 the 2020 ICD-10 codes went into effect. This year there were 273 new codes, 30 revised codes and 21 deleted codes, bringing

Guideline Section 1.19.c: ◦ For physeal fractures, assign only the code

identifying the type of physeal fracture. Do not assign a separate code to identify the specific bone that is fractured.

Code revision: ◦ Z45.42: “Neuropacemaker” is changed to

“neurostimulator” and brain, peripheral nerve, and spinal cord are removed.

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Page 34: Presented by: David Klein, CPC, CPMA, CHC...On October 1, 2019 the 2020 ICD-10 codes went into effect. This year there were 273 new codes, 30 revised codes and 21 deleted codes, bringing

We have noticed an increase in payers using some established ICD-10 guidelines to deny claims.

When a code includes an Excludes1 note, that means that the code that follows cannot be used with it. For example, M54.6 Pain the thoracic spine includes an Excludes1 note for M51- disc disorders. These codes should not appear on the same claim, even though some of the M51 codes are for the lumbar spine.

Page 35: Presented by: David Klein, CPC, CPMA, CHC...On October 1, 2019 the 2020 ICD-10 codes went into effect. This year there were 273 new codes, 30 revised codes and 21 deleted codes, bringing

Pain diagnoses: Diagnosis codes such as M54.2 Cervicalgia, or M54.5 Low back pain are considered short term and more of a symptom than a definitive diagnosis.

Providers should identify the cause of the pain and report a more definitive diagnosis instead. Reporting a symptom diagnoses does not do much to establish medical necessity.

Page 36: Presented by: David Klein, CPC, CPMA, CHC...On October 1, 2019 the 2020 ICD-10 codes went into effect. This year there were 273 new codes, 30 revised codes and 21 deleted codes, bringing

“Code signs and symptoms when a related definitive diagnosis has not been established (confirmed) by the provider” (section I.B.6)

Example: R45.2 Unhappiness

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Page 37: Presented by: David Klein, CPC, CPMA, CHC...On October 1, 2019 the 2020 ICD-10 codes went into effect. This year there were 273 new codes, 30 revised codes and 21 deleted codes, bringing

“Signs and symptoms that are associated routinely with a disease process should not be assigned as additional codes” (section I.B.7)

Example: R68.84 Jaw pain would not be coded with M26.62 temporomandibular joint arthralgia

“Additional signs and symptoms that may not be associated routinely with a disease process should be coded when present.” (sectionI.B.8)

Example: R11.0 Nausea and S13.4xxA Sprain of ligaments of the cervical spine

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Page 38: Presented by: David Klein, CPC, CPMA, CHC...On October 1, 2019 the 2020 ICD-10 codes went into effect. This year there were 273 new codes, 30 revised codes and 21 deleted codes, bringing

“Do not code diagnoses documented as ‘probable’, ‘suspected’, ‘questionable’, ‘rule out’, or ‘working diagnosis’ or other similar terms indicating uncertainty.” (section IV.I)

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Page 39: Presented by: David Klein, CPC, CPMA, CHC...On October 1, 2019 the 2020 ICD-10 codes went into effect. This year there were 273 new codes, 30 revised codes and 21 deleted codes, bringing

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Page 40: Presented by: David Klein, CPC, CPMA, CHC...On October 1, 2019 the 2020 ICD-10 codes went into effect. This year there were 273 new codes, 30 revised codes and 21 deleted codes, bringing

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Medicare

Medicare is the Gold Standard – Based on The Code of Federal Regulations (CFR)

• National Coverage Determinations

• Local Coverage Determinations

• Medicare Carrier Manuals

• Med Learn Matters

• National Correct Coding Initiative (NCCI)

• Office of Inspector General (OIG)

Page 41: Presented by: David Klein, CPC, CPMA, CHC...On October 1, 2019 the 2020 ICD-10 codes went into effect. This year there were 273 new codes, 30 revised codes and 21 deleted codes, bringing

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How to Use Medicare Effectively

http://www.cms.gov/medicare-coverage-database/overview-and-quick-

search.aspx?CoverageSelection=Local&ArticleType=All&PolicyType=F

inal&s=Pennsylvania&CptHcpcsCode=97110&bc=gAAAAAAAAAAAAA

%3d%3d&=&

Lookup an LCD:

Page 42: Presented by: David Klein, CPC, CPMA, CHC...On October 1, 2019 the 2020 ICD-10 codes went into effect. This year there were 273 new codes, 30 revised codes and 21 deleted codes, bringing

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Medicare Coverage Database

Page 43: Presented by: David Klein, CPC, CPMA, CHC...On October 1, 2019 the 2020 ICD-10 codes went into effect. This year there were 273 new codes, 30 revised codes and 21 deleted codes, bringing

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Select The State

Page 44: Presented by: David Klein, CPC, CPMA, CHC...On October 1, 2019 the 2020 ICD-10 codes went into effect. This year there were 273 new codes, 30 revised codes and 21 deleted codes, bringing

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Choose the CPT Code or Keyword

Page 45: Presented by: David Klein, CPC, CPMA, CHC...On October 1, 2019 the 2020 ICD-10 codes went into effect. This year there were 273 new codes, 30 revised codes and 21 deleted codes, bringing

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Choose the Correct LCD

Page 46: Presented by: David Klein, CPC, CPMA, CHC...On October 1, 2019 the 2020 ICD-10 codes went into effect. This year there were 273 new codes, 30 revised codes and 21 deleted codes, bringing

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View the LCD

Page 47: Presented by: David Klein, CPC, CPMA, CHC...On October 1, 2019 the 2020 ICD-10 codes went into effect. This year there were 273 new codes, 30 revised codes and 21 deleted codes, bringing

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Don’t Just Limit it to Chiropractic

Page 48: Presented by: David Klein, CPC, CPMA, CHC...On October 1, 2019 the 2020 ICD-10 codes went into effect. This year there were 273 new codes, 30 revised codes and 21 deleted codes, bringing

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CPT code 97035 (ultrasound therapy)

Therapeutic ultrasound is a deep heating modality that produces a sound wave of 0.8 to 3.0 MHz. In the human body ultrasound has several pronounced effects on biologic tissues. It is attenuated by certain tissues and reflected by bone. Thus, tissues lying immediately next to bone may receive as much as 30% greater dosage of ultrasound than tissue not adjacent to bone. Because of the increased extensibility ultrasound produces in tissues of high collagen content, combined with the close proximity of joint capsules, tendons, and ligaments to cortical bone where tissue may receive a more intense irradiation, ultrasound is an ideal modality for increasing mobility in those tissues.

It is considered reasonable and necessary that ultrasound may be pulsed or continuous width; and for it to be used in conjunction with therapeutic procedures, not as an isolated treatment.

Specific indications for the use of ultrasound application include but are not limited to:•limited joint motion that requires an increase in extensibility•symptomatic soft tissue calcification•neuromasPhonophoresis (the use of ultrasound to enhance the delivery of topically applied drugs) will be reimbursed as ultrasound therapy. Separate payment will not be made for the contact medium or drugs.

If no objective or subjective improvement is noted after 6 treatments, a change in treatment plan (alternative strategies) should be implemented or documentation should support the need for continued use of ultrasound. Documentation must clearly support the need for ultrasound more than 12 visits.

Page 49: Presented by: David Klein, CPC, CPMA, CHC...On October 1, 2019 the 2020 ICD-10 codes went into effect. This year there were 273 new codes, 30 revised codes and 21 deleted codes, bringing

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Other LCD’s Can Prove Helpful

Page 50: Presented by: David Klein, CPC, CPMA, CHC...On October 1, 2019 the 2020 ICD-10 codes went into effect. This year there were 273 new codes, 30 revised codes and 21 deleted codes, bringing

• Twelve (12) chiropractic manipulation treatments for Group A diagnoses.• Eighteen (18) chiropractic manipulation treatments for Group B diagnoses.• Twenty-four (24) chiropractic manipulation treatments for Group C diagnoses.• Thirty (30) chiropractic manipulation treatments for Group D diagnoses.

M54.5 Low back painM54.6 Pain in thoracic spineM54.89 Other dorsalgiaM54.9 Dorsalgia, unspecifiedM62.40 Contracture of muscle, unspecified site

M47.23 Other spondylosis with radiculopathy, cervicothoracic regionM47.24 Other spondylosis with radiculopathy, thoracic regionM47.25 Other spondylosis with radiculopathy, thoracolumbar regionM47.811 Spondylosis without myelopathy or radiculopathy, occipito-atlanto-axial region

Example Group A Diagnoses:

Example Group B Diagnoses:

Consider Novitas Solutions, Inc. LCD

Page 51: Presented by: David Klein, CPC, CPMA, CHC...On October 1, 2019 the 2020 ICD-10 codes went into effect. This year there were 273 new codes, 30 revised codes and 21 deleted codes, bringing

M48.01 Spinal stenosis, occipito-atlanto-axial regionM48.02 Spinal stenosis, cervical regionM48.03 Spinal stenosis, cervicothoracic regionM50.10 Cervical disc disorder with radiculopathy, unspecified cervical regionM50.11 Cervical disc disorder with radiculopathy, high cervical region

M54.14 Radiculopathy, thoracic regionM54.15 Radiculopathy, thoracolumbar regionM54.16 Radiculopathy, lumbar regionM54.17 Radiculopathy, lumbosacral regionM54.30 Sciatica, unspecified sideM54.31 Sciatica, right sideM54.32 Sciatica, left sideM54.40 Lumbago with sciatica, unspecified side

Example: Group C Diagnoses

Example: Group D Diagnoses

Page 52: Presented by: David Klein, CPC, CPMA, CHC...On October 1, 2019 the 2020 ICD-10 codes went into effect. This year there were 273 new codes, 30 revised codes and 21 deleted codes, bringing

For custom fabricated orthoses, there must be detailed documentation in the treating physician’s records to support the medical necessity of custom fabricated rather than a prefabricated orthosis.

◦ Custom fitted - Prefabricated item that requires substantial modification e.g., has been trimmed, bent, molded, assembled, or otherwise customized to fit a specific patient by certified orthotist or an individual with equivalent expertise.

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Page 53: Presented by: David Klein, CPC, CPMA, CHC...On October 1, 2019 the 2020 ICD-10 codes went into effect. This year there were 273 new codes, 30 revised codes and 21 deleted codes, bringing

Substantial modification is defined as changes made to achieve an individualized fit of the item that requires the expertise of a certified orthotist or an individual who has equivalent specialized training in the provision of orthotics such as a physician, treating practitioner, an occupational therapist, or physical therapist in compliance with all applicable Federal and State licensure and regulatory requirements. A certified orthotist is defined as an individual who is certified by the American Board for Certification in Orthotics and Prosthetics, Inc., or by the Board for Orthotist/Prosthetist Certification.

◦ Only a certified Orthotist (ABC or BOC)

◦ Equivalent Specialized Training: Physician, Treating Practitioner, Occupational Therapist, Physical Therapist –(those within the Medical Practices Act who have training in the provisions of orthotics)

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Page 54: Presented by: David Klein, CPC, CPMA, CHC...On October 1, 2019 the 2020 ICD-10 codes went into effect. This year there were 273 new codes, 30 revised codes and 21 deleted codes, bringing

The new modifiers are:

• XE Separate Encounter, a service that is distinct because it occurred during a separate encounter

• XS Separate Structure, a service that is distinct because it was performed on a separate organ/structure

• XP Separate Practitioner, a service that is distinct because it was performed by a different practitioner

• XU Unusual Non-Overlapping Service, the use of a service that is distinct because it does not overlap usual components of the main service

It is unclear at this time if other/all payers will adopt the new

modifiers and as such this change will only affect Medicare.

Medicare Changes to Modifier 59

Page 55: Presented by: David Klein, CPC, CPMA, CHC...On October 1, 2019 the 2020 ICD-10 codes went into effect. This year there were 273 new codes, 30 revised codes and 21 deleted codes, bringing

LCD’s Can Include:

Code specific instruction

Definitions

Documentation Guidelines

Special Instructions

Medical Necessity Guidelines

Special Warnings

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Page 56: Presented by: David Klein, CPC, CPMA, CHC...On October 1, 2019 the 2020 ICD-10 codes went into effect. This year there were 273 new codes, 30 revised codes and 21 deleted codes, bringing

In 2002 The US Department of Health and Human Services (HHS) answered this question in a Q&A:

Question:

Are appointment reminders allowed under the HIPAA Privacy Rule without authorizations?

Answer:

“Yes, appointment reminders are considered part of treatment of an individual and, therefore, can be made without an authorization.”

Source: HHS_AppointmentReminder_QA

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Page 57: Presented by: David Klein, CPC, CPMA, CHC...On October 1, 2019 the 2020 ICD-10 codes went into effect. This year there were 273 new codes, 30 revised codes and 21 deleted codes, bringing

The 2013 Omnibus final rule states the following regarding your Notice of Privacy Practices (NPP):

“In particular, §164.520(b)(1)(iii) requires a separate statement in the notice if the covered entity intends to contact the individual to provide appointment reminders or information about treatment alternatives or other health related benefits or services.”

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Page 58: Presented by: David Klein, CPC, CPMA, CHC...On October 1, 2019 the 2020 ICD-10 codes went into effect. This year there were 273 new codes, 30 revised codes and 21 deleted codes, bringing

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Know What your Provider Agreements Say

⚫ Delegation of Services to Unlicensed Personnel

⚫ Clinical Policy Bulletins

⚫ Appeal Processes

⚫ Fee Schedules

⚫ Active vs. Passive Care

Page 59: Presented by: David Klein, CPC, CPMA, CHC...On October 1, 2019 the 2020 ICD-10 codes went into effect. This year there were 273 new codes, 30 revised codes and 21 deleted codes, bringing

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Example – CPT 97012

97012 - traction, mechanical

CPT Assistant further defines mechanical traction: “The force used to create a degree of tension of soft tissues and/or to allow for separation between joint surfaces. The degree of traction is controlled through the amount of force (pounds) allowed, duration (time), and angle of pull (degrees) using mechanical means. Terms often used in describing pelvic/cervical traction are intermittent or static (describing the length of time traction is applied), or autotraction (use of the body's own weight to create the force).”

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1.Policy

Aetna considers autotraction devices experimental and investigational because there is insufficient evidence to support their clinical value in treating low back pain (LBP) or for other indications.

2. Note: Brand names of autotraction devices include the Anatomotor, the Arthrotonic stabilizer, the Quantum 400 inter-segmental traction table, and the Spinalator, Spinalign massage inter-segmental traction table.

Aetna Clinical Policy Bulletin:Lumbar Traction Devices

Number: 0569

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Horizon Policy

CMT E&M Services: According to CPT guidelines, CMT codes include a pre-manipulation patient assessment. An E&M service may be reported in addition to CMT if the member’s condition requires a significant, separately identifiable E&M service that is above and beyond the usual pre-service and post service work associated with the CMT. In such instances the provider should append modifier 25 to the E&M code and ensure that the appropriate documentation is included in the patient’s medical record in accordance with CMS guidelines. It is appropriate to separately and additionally report an E&M service only in the following conditions:

1. Initial evaluation of a new member or condition; or a reevaluation of an established patient’s progress under a current treatment plan every thirty (30) days;

2. Acute exacerbation of symptoms or a significant change in the member's condition; or

3. A distinct and different indication which is separately identifiable and unrelated to the manipulation.

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Discounts

Page 64: Presented by: David Klein, CPC, CPMA, CHC...On October 1, 2019 the 2020 ICD-10 codes went into effect. This year there were 273 new codes, 30 revised codes and 21 deleted codes, bringing

What kind of Discounts Can I offer?

Discounts often include:

◦ Waivers of deductibles and copays

◦ Free care

Historical concerns – dual-fee schedule and provider contracts

More Recently…Anti-inducement laws

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Page 66: Presented by: David Klein, CPC, CPMA, CHC...On October 1, 2019 the 2020 ICD-10 codes went into effect. This year there were 273 new codes, 30 revised codes and 21 deleted codes, bringing

Audits

Payers sending out letters

◦ Applies to

Out-of-network practices

Non-covered care focused practices

Rule of Thumb – If you treat insured patients, then discounts is an issue

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Problem – other businesses don’t involve claims being filed with insurance

Federal government does recognize certain kinds of discounts

General rules

◦ Policy must be in writing

◦ Consistently applied #1 requirement

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1.Hardship

2.Prompt Pay

3.Discount Medical Plans

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Page 69: Presented by: David Klein, CPC, CPMA, CHC...On October 1, 2019 the 2020 ICD-10 codes went into effect. This year there were 273 new codes, 30 revised codes and 21 deleted codes, bringing

OIG Advisory – February 8, 2008

http://www.oig.hhs.gov/fraud/docs/advisoryopinions/2008/AdvOpn08-03A.pdf

Background – hospital posed a question to the OIG regarding prompt pay discounts.

Tip:

✓Get a copy of the

OIG Advisory

Opinion 08-03A

off of the Internet

and save it to

your local

computer.

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It’s a discount that:

"is designed to reduce the Health System's accounts receivables and costs of debt collection, and to boost its cash flow."

"bear[s] a reasonable relationship to the amount of collection costs that would be avoided."

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% of Bill Discounted on Payments Made Prior to Discharge

Balances $0 -- $999 = 10%

Balances = $1,000 = 15%

% of Bill Discounted on Payments Made Post-Discharge But

Within 30 days of Discount Offer

Balances $0 -- $999 = 5%

Balances = $1,000 = 10%

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Discount would be offered by the hospital without regard to the "reason for the patient's admission" or "length of stay."

Hospital certified that it "would not advertise the discount opportunity."

Patients and their representatives would only be informed of the Prompt Pay Discount's availability "during the course of the actual billing process."

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◦ Limited Pre-Payment Discount – e.g., Cap it at a

dollar amount

◦ Time-of-Service Discount

◦ Auto-Draft Discount – Full Past Pay

◦ Auto-Draft Discount – Equal Payments

◦ Payment Assurance Discount – patient provides a

credit card as assurance of payment.

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Prompt Pay Discounts

Talk With Your Attorney

“Fr”

Services?

Not Advertised

In Writing &

Consistently Applied

ReasonableNot

Based on

Length of

Care

“Non-Covered

Services” Only?

Notify

Payer?

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HRSA - Health Resources and Services Administration.

HRSA is the "primary Federal agency for improving access to health care services for people who are uninsured, isolated or medically vulnerable."

HRSA has developed a Hardship Application based on federal poverty guidelines

HRSA Sliding Fee Scale

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Certain health centers, in order to receive assistance from federal government must:

Using a discounted/sliding fee schedule to help patients in financial need

Posting a sign that no one who is unable to pay will be denied access to services

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General guidelines:

◦ Patient’s Income and Expenses

◦ Family Size

◦Amount of Medical Bills

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“Providers may establish any number of

incremental percentages (discount pay

class) as they find appropriate between

100-200% of poverty….”

Pg. 3

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“Patients above 200% of poverty may be charged the full fee for the service(s), or; providers may continue to charge incremental percentages for services when patient income is above 200% of poverty, until 100% of the full fee is reached.”

Pg. 3

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“The reasonableness of … the percent of a full

fee that is assessed, may be subject to

review/challenge by federal reviewers during

routine reviews by duly authorized federal

staff, or their state counterparts.”

Pg. 3

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“The simplest approach is to accept the

patient’s word at the time the request is

made. On future visits, it may be

appropriate to require some form of

verification.”

Pg. 4

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“Many … providers count only the mother,

father, and dependent children under 18 as

the family. Other adults in the household,

even though related, are considered

separately.”

Pg. 4

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Discount Medical Plans

Acts just like an insurance plan except thePatients pay you directly

You get credentialed

Set your “network” fee schedule

Post that you are a network provider

Make sure to go with a licensed and bonded discount Medical Plan – e.g. ChiroHealth USA

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Patient must sign up with the plan

Fees are generally reasonable - $59 per year

They can now enjoy the “in-network” fee schedule

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More Info?

Stop By Our Booth.

Phone: 888-306-1256

Email: [email protected]

www.paydc.com

Thank You!