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Tag Archives: Assessment
“code also” or ” buddy codes” required assessment?
morning, need help please!! as a new auditor I’m having difficulty with validating "code also" code that providers are choosing due to the coding convention guidelines. However the problem is when they chose these codes there is no assessment done. for example Hypertension I10 with nicotine dep, cigarette, uncomp F17.210. Social hx shows patient is a smoker. is this enough or do we have to have an assessment of these "buddy codes" as well.
any feedback is greatly appreciated. Thank you
any feedback is greatly appreciated. Thank you
Medical Practice – Electronic Medical Record Readiness Assessment
There is no doubt that Electronic Medical Records (EMR), implemented successfully and used properly, are valuable clinical tools in any medical practice. Their benefits of reducing costs, streamlining workflow, improving medical care and increasing practice productivity are undeniable. However, we hear stories upon stories of failed implementations and deinstallations of these systems across the US. According to a study conducted by HealthLeaders-InterStudy that “The state of Arizona and the Phoenix area have experienced a high adoption rate for electronic medical records, but this has been followed by a “deinstallation” of the technology”.
What should physicians and practices do to prevent and avoid such a failure? To thoroughly answer this question, we must start at the beginning of the process of changing from paper to electronic. It is very important for everyone involved to understand the implications and ramifications of this very important change. A practice profiling or readiness assessment and aptitude for embracing and adopting new technology is the first step to ensuring a successful EMR implementation long before the deployment of the system.
In this first article, of a series of future articles, we will focus on what is involved in performing EMR readiness assessment and briefly explain each task. These tasks lay the ground for the needed changes and the necessary training and support as the EMR implementation process proceeds.
Assessing your practice culture:
Understanding the office culture and it aptitude for change is considered a major factor of the successful implementation of an EMR. Cultural assessment includes:
o Staff willingness to accept change and to be able to change they way they do things.
o The change in workflow and processes and its impact on how staff interact with each others
o The level of resistance to change – real or perceived.
o The cause of resistance and possible remedies.
Assessing your practice technical capabilities:
o Identify current technical skill level. You might find some of your employees are less tech-savvy than others. It is very important to determine their skill level to help you design a training program to bring everyone up to the required skills level prior to deploying the EMR software.
o Identify the impact the EMR would have on your existing technical environment.
Assessing your operational changes:
o Front Office – receptionists, patient scheduling, checking-in, checking-out, processing insurance related information, etc.
o Nurses – interacting with patients, interacting with physicians, etc.
o Administrative and Back Office – coding, billing and accounting.
o Physicians – entering encounter information, dictations, medications, test results, etc.
Assessing your budget, cost, saving and ROI:
o Identify the impact and the cost of acquiring an EMR on your budget.
o Identify the impact on your patients volume and revenue.
o Assess the loss of practice productivity during and after transition to EMR
o Asses the impact on account receivables and the decrease in cash flow.
o Identify areas of saving and cost cutting as a result of deploying an EMR.
o Identify positive and negative impact on the practice bottom line
Marwan Madanat is in charge of Alphamed Solutions, Inc. operations and business development. Alphamed Solutions is a national healthcare company focusing on delivering innovative and quality medical services and technology solutions to physicians and medical practices nationwide. Our clients include practices in single to multiple specialties and of different sizes. Alphamed solutions and services include EMR/PM consulting, Revenue Cycle Management, medical billing and medical transcription. Our services empower practices of all sizes to maximize their clinical, financial and operational efficiencies and ultimately improve patient quality of care and physicians quality of life.
Related Medical Coding Articles
MH & SUD Assessment, how often can these be billed?
Can mental health and substance use disorder assessments be billed more often than once per year? Let’s say there was an assessment done 10 months ago by a provider but they feel that another assessment is appropriate now due to the potential change in the patient’s diagnosis and health status. Would it be appropriate for the provider to bill another assessment (H0001 or H0031) before 1 year? Or is there a more appropriate re-assessment code specific to Behavioral Health?
HITRUST security risk assessment
Product watch
HITRUST security risk assessment
by Chris Apgar, CISSP
There are no federally recognized HIPAA certification standards for covered entities (CE) and business associates (BA) and it’s unlikely one will be. However, that doesn’t stop larger CEs from requiring some form of certification to demonstrate compliance with HIPAA and proof that BAs have implemented sound information security programs. The Health Information Trust Alliance (HITRUST) (http://hitrustalliance.net) published its first common security framework (CSF) in March 2009 with the goal of focusing on information security as a core pillar of the broad adoption of health information systems and exchanges. Larger CEs, primarily large health plans, now require their BAs to become HITRUST certified.
HITRUST offers three levels of security risk assessments ranging from one that is self-administered to certification. The assessments are based on HITRUST’s CSF, an information security framework that addresses existing standards and regulations, including federal, third party, and government. HITRUST’s risk assessment tool was intended to deliver a comprehensive tool that can guide CEs and BAs in their information security and compliance planning activities. Unfortunately, in the opinion of the author and other healthcare practitioners, the HITRUST framework is overly burdensome and in some cases just plain wrong when it comes to assessing downstream vendor compliance.
The assessments are complex, burdensome, and, if certification is the goal, expensive. There is a cost to use the MyCSF tool and a certified HITRUST assessor must certify compliance with theMyCSF requirements.
After categorizing the entity to be assessed, scoping explores areas of security that are often addressed in a traditional risk assessment, a compliance audit, and other audits. This includes information system identification, system grouping. It also includes an evaluation or assessment of data elements, and determining system boundaries.
Facilitated or self-administered HITRUST assessments begin with scoping. Beyond determining where a CE’s or BA’s assets lie and what policies are in place, scoping takes into account the type of entity, the regulatory environment, the number of operational units, and so forth. Scoping determines the number of questions that need to be asked. For example, some questions about the security of those devices would not be pertinent to an entity such as a software-as-a-service vendor.
The rigor applied varies based on the level of the assessment. The self-assessment is just that: the CE or BA pays for the assessment and conducts scoping and the assessment itself. This option has the lowest level of rigor and potential accuracy, but is still a tall task to ask of a CE or BA given the amount of time necessary to accumulate the needed documentation and load it in the MyCSF tool.
The self-assessment has the lowest price tag. Conducting a self-assessment requires more than a little knowledge of information security and the internal workings of the IT shop. The report produced will be only as accurate and useful as the data. In other words: Garbage in, garbage out.
The next two levels require an external third party to conduct the HITRUST assessment. The cost of the assessment will vary depending on the size and complexity of the entity but, even with smaller entities, the cost is hefty. The validated assessment is conducted by a third party and validated by HITRUST. The last level of assessment leads to HITRUST certification that is good for two years with a mini-assessment conducted in the off year.
Version 7 of the MyCSF tool is clunky and time-consuming to use. If you begin loading documents, it takes more than a few seconds to load each document, and if you don’t save your uploads frequently enough you will lose your work. HITRUST states on its MyCSF webpage that the tool is user friendly. It is far from that.
Certification may not be immediately granted following the assessment. HITRUST does not ensure entities assessed will remain compliant between assessments. Compliance, along with information security, are not one-time events. There is no guarantee entities will not be audited or will pass an OCR audit. HITRUST assesses compliance on the information security side, but does not assess compliance with the HIPAA Privacy Rule or state privacy and breach laws.
All third-party vendors that perform validated assessments and certification assessments must be re-certified periodically by HITRUST. HITRUST also manages the CSF and the MyCSF tool. This is supposed to support consistency of approach, structure, standardization, and currency. It doesn’t always hit the mark, though, because it includes requirements that are simply overkill and, in some cases, are actually wrong.
The direct costs for HITRUST certification include both fees to HITRUST and to the HITRUST approved assessor. The direct cost is about $ 40,000?$ 60,000 but costs can be much higher for larger organizations, per Catalyze, a HITRUST certified cloud infrastructure vendor (http://content.catalyze.io/what-is-the-cost-of-hitrust-csf-certification).
Indirect costs are harder to quantify. Catalyze estimated the total time spent for all employees to compile and load the documentation into MyCSF at 200 hours. The time spent between each audit to address issues and solidify compliance and information security programs must also be considered.
Per Catalyze, conservatively estimating the cost of an hour of work to be $ 100/hour, a rough calculation can be tallied. With the cost of salaries, benefits, and lost opportunities from work not performed, a partial loss must be considered. Based on those numbers, the total cost of the HITRUST assessment is roughly $ 60,000?$ 80,000.
If the assessment is conducted correctly, HITRUST tools can be used to improve information security and adherence to compliance requirements. However, it is not a simple exercise and is fraught with high costs, headaches associated with using the MyCSF tool, and may wastes time and resources. There are other options for third-party assessments to demonstrate HIPAA compliance and a sound information security program, often at significantly less cost.
Any claims that OCR will recognize the HITRUST tool in and of itself as demonstrating compliance with HIPAA are false. The Office of the National Coordinator for Health Information Technology and OCR, among others, have published their own guidance about what should be included in a HIPAA risk analysis or risk assessment.
Editor’s note: Apgar is president of Apgar & Associates, LLC, in Portland, Oregon. He is also a BOH editorial advisory board member. Opinions expressed are that of the author and do not represent HCPro or ACDIS. This information does not constitute legal advice. Consult legal counsel for answers to specific privacy and security questions. Email your HIPAA questions to Associate Editor Nicole Votta at [email protected].
ABIM announces changes to MOC assessment
ABIM announces changes to MOC assessment
In response to criticism that its Maintenance of Certification (MOC) exam is too time-consuming, the American Board of Internal Medicine (ABIM) recently announced plans to offer a new option that will allow physicians to take a shorter assessment exam beginning in 2018.
The specific details of the new assessment option have yet to be finalized; however, ABIM says the shorter assessments will be taken more frequently than the current eight-hour assessment every 10 years, but no more than annually. Additionally, physicians will be allowed to take the assessment on their own secure personal or office computer and will receive feedback to address their knowledge gaps. Physicians who perform well enough on the shorter assessments will also not be required to take the 10-year exam to remain board certified.
"By offering shorter assessments that they could take at home or at the office, we hope to lower the stress and burden that many physicians have told us the current 10-year exam generates," says ABIM President and CEO Richard J. Baron, MD.
This change addresses one of the key recommendations made by ABIM’s Assessment 2020 Task Force, which issued its final report in September. Among its recommendations was replacing the 10-year exam with more frequent assessments, taken at home or in the office.
The Assessment 2020 report explained, "The results of the smaller, more frequent, lower-stakes assessments would provide insight into performance and accumulate over time and culminate in a high-stakes pass/fail decision … This approach would emphasize learning as an integral part of the program, but would also provide meaningful criteria to the public as to whether a physician is remaining current."
ABIM plans to initially make the shorter assessment option available only to physicians maintaining certification in internal medicine and possibly a few subspecialties. Feedback from early adopters will be used to help make the new assessment option available to more subspecialties in the future.
Physicians who do take the short assessments but don’t meet a passing standard over a period of time, which ABIM has yet to determine, will be required to take the traditional longer assessment.
Survey results
The move to shorter, more frequent assessments was supported by the results of ABIM’s survey of more than 9,200 board-certified physicians about potential changes to the MOC assessment, the results of which were released in April.
The survey found:
- 56% of respondents had a positive reaction to the idea of a shorter knowledge assessment taken more frequently, compared to roughly 30% who responded negatively.
- More than 86% reacted positively to the idea of taking the exam at their home, office, or elsewhere using a secure computer connection instead of going to a testing center. Only about 7% had an unfavorable view.
- For alternate testing locations, the majority of respondents preferred their home or office (87%), followed by a local medical center or hospital (34%). Only about 21% found going to a dedicated secure test center favorable.
- Nearly 80% said they would take a series of shorter assessments over the course of a few years that would allow them to skip the traditional MOC exam if they performed well enough, even if the current eight-hour assessment taken once every 10 years still existed.
Diving further into assessment length and frequency preferences, the survey found that the majority of respondents preferred assessments requiring less than an hour of time and taken every year (55%), followed by two- to four-hour assessments taken every few years (45%). And, despite the overwhelming preference for the shorter assessment, nearly 21% of respondents still liked the 10-year assessment, Baron says, which is why the ABIM is keeping it as an option. "Our announcement reflects these divergent views and gives physicians the chance to choose the assessment that best meets their needs."
The survey also found that 76% of respondents had a favorable view of accessing online reference material during an assessment. Nearly two-thirds favored having access to online reference material they used in practice. Respondents had less favorable views of limiting online reference access to certain sections of the assessment (44.4%) and limiting the amount of time to complete the assessment using references (47.6%).
In its announcement for the new assessment option, ABIM said it will continue to study the feasibility of offering open-book assessments.
Pricing for the more frequent assessments has not yet been determined. ABIM will be redesigning its fee structure as it redesigns the assessment model and looking to provide payment options for each program track.
Reaction to the announcement
Baron says it’s too early to gauge the full extent of the reaction to the new assessment option, "but for the past year, we have been hearing from doctors that they are very interested in having assessment options. And the reaction to the announcement has been generally positive so far."
Some members of the physician community see the new option as a necessary correction to a program that’s viewed by many as too burdensome.
"There needs to be a balance between ‘opposite poles’ or things will swing too far one way or the other. The initial intent for MOC was a good one but went way too far and became an onerous proposition rather than an ongoing badge of honor. This move by the ABIM to move to a centrist position is a good one." says William K. Cors, MD, MMM, FACPE, chief medical officer of Pocono Health System in East Stroudsburg, Pennsylvania. "It restores some balance to the equation of maintaining an ongoing bar of certification on the one hand and not representing a near-impossible life challenge to the physician on the other hand. Sometimes reason prevails and both poles of a proposition are in better alignment."
Steven Weinberger, MD, MACP, FRCP, American College of Physicians (ACP) executive vice president and CEO, also expressed support for reforming the MOC assessment.
"ACP is encouraged to hear that ABIM is considering alternatives to the 10-year secure examination for maintenance of certification, and that they are beginning to respond to the concerns we’ve raised on behalf of our members. We look forward to hearing more about the new approach, such as the frequency of the assessments, cost, and more about the feedback mechanism. The specifics of how the new approach is designed and implemented will be critical to its success in decreasing the burden and increasing the relevance of the current program," Weinberger says.
In a statement released by the American College of Cardiology (ACC) shortly after the ABIM announcement, ACC President Richard A. Chazal, MD, FACC, praised ABIM’s effort while remaining cautious.
"MOC continues to rank among the top concerns of our internal medicine members, with the 10-year examination being the largest obstacle … We applaud the ABIM’s move in the direction of more flexibility in MOC requirements; however, we will need more details to see how it aligns with ACC’s proposal," Chazal said.
However, regardless of ABIM’s new assessment option, MOC itself still has its detractors. "We object to MOC on principle," says Jane M. Orient, MD, executive director of the Association of American Physicians and Surgeons. "Doctors are professionals. They are supposed to know how to learn (or what good are the training programs?), and no one knows better than they do [of] what they need to know to best serve their patients."
Orient believes there is no evidence that patient care is improved by time-limited board certifications and likens it to the idea of time-limited MD degrees or requiring attorneys to pass the bar every 10 years.
What’s next?
Baron says over the next few months, ABIM will ask for feedback from physicians, societies, and other stakeholders to help it refine the new assessment model. Specific details will be provided to the community no later than December 31, 2016. Before the model’s implementation, ABIM will also hold a public comment period about the proposed changes.
"Understandably, we have received a few questions about what the new assessment option will exactly look like, and while we do not have all the details yet, we have tried to address some of the [frequently asked questions] online," Baron says.
In the meantime, physicians with certifications set to expire prior to the adoption of the new assessment option in January 2018 will still need to take the current exam.
Whether the new assessment option will make ABIM’s MOC program more attractive to physicians remains to be seen, but Baron says he is optimistic.
"[I]t is our hope that by working with physicians to create a new assessment option, more physicians will elect to participate in the MOC program," he says. "Over the past year, we have heard from many physicians who have said that they want a relevant and meaningful credential that signals to the public and to their peers that they are staying current with medical knowledge and practice. ABIM’s MOC credential offers this to them, and with the proposed changes, we hope more physicians will proudly choose to participate in ABIM’s MOC program."
Medication Management and Assessment
If a provider sees a patient for wheezing and breathing problems and before the end of the visit ends up filling the patients prescriptions for chronic problems like hypertension, gout, cholesterol and osteoporosis but only codes for the wheezing in the assessment and the plan only describes the treatment breathing problem.
He did write that he refilled the prescriptions just not under the assessment part of the note, should the extra 4 diagnoses be coded?
Should the coder add the extra 4 diagnosis to the claim, have the provider write an addendum and add the codes to the claim or just leave the wheezing diagnosis as is.
Or is there another option?
Assessment and E&M code dilemma
I have a provider who puts sometimes 10 or more diagnoses in her assessment and always wants to bill a 99214 or 99215. In the chief complaint the patient was there for a med refill for HTN or DMII and she will re-diagnose things from a list of chronic problems but not mention them in her HPI or do a physical exam. How should I approach this? I’ve been told I’m being too picky or demanding. What can I do to remedy this problem?