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Annette Vesey, CPC-A
Follow this step-by-step guide to coding and documentation compliance. It’s always better for a facility to find compliance issues before a government agency or payer does (who may respond by levying penalties and fines). Pre- or post-bill audits help facilities uncover minor concerns before they become major compliance issues, thereby promoting revenue integrity. Here’s how […]
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Tom Cheezum, O.D., CPC, COPC
My employer has had an audit of charts and the insurance companies hired auditors have an issue with our billing by time documentation.
Our providers always follow the CMS guidelines and then refer to the assessment and plan or other documentation in the note for the content of counseling. Its pretty obvious what the counseling is about due to treatment options, diagnosis or complications. We are a pediatric practice so parents and caregivers come in and require lots of time for answering questions. We spend a lot of time addressing what the parent/caregiver has seen on the internet too. This seems to be a common way to document the counseling topics. However the large carrier that audited us said that’s not enough but would not give us an example of acceptable documentation for the content of counseling.
My question is has any other practice had a billing by time recoupment from a carrier? If so were you given any examples of acceptable documentation beyond the CMS documentation guidelines?
Thank you,
Louise
Alpana
Answer six questions to provide a concise audit that is purposeful, corrective, and educational. You’ve reviewed the records and analyzed the results. Now, it’s time to prepare for what may be the most challenging aspect of the audit process: presenting the results in a way that makes sense and generates the change needed to ensure […]
AAPC Knowledge Center
The first denial came back stating:
"The 5 day assessment, ARD 8/3/17 pays for 8/1-8/3/17 and the 14 day/COT assessment ARD 8/10/2017 pays for 8/4-8/12-17. Billed RVB x 3 days and RUB x 9 days, validated RHB x 3days and RUB x 9days. The CMS RAI manual requires clinical documentation of daily therapy minutes provided. The ST minutes are incorrectly coded on the 5 day assessment compared to documentation received. Evaluation minutes are not to be included on the MDS."
On 8/1 this is what was done- 92507 (47 minutes) 92523 (55 minutes) and 96125 -59 (60 minutes). 8/2 92507 (36 minutes) and 8/3 92507 (31 minutes)
We had a total of 174 minutes of ST on the MDS. My interpretation of what they said was that they thought we were including the 55 minutes for the 92523 – Evaluation of Speech Sound Production. We did not, it was the 96125 with -59 Standardized Cognitive testing which includes face-to-face time administration and interpretation and report.
I sent that in over 2 months ago and we got yet another denial/upholding of the Level 1 stating:
This is what they state in a letter we received on 7/20/18.
Per CMS guidelines, CPT code 96125 is a billable code if face-to-face tested is completed and the interpretation is not completed by a technician or coputer. The treatment code completed for CPT code 96125 does not indicate how the testing and interpretation of testing were completed. Unable to determine if all time billed for CPT code 96125 was billable minutes. The eval is digitally signed by the ST, that’ show it reads and it’s our Speech Therapist. Are they reading that as Tech?!
In a letter we received 7/18 they state:
Per CMS guidelines, CPT code 96125 is a timed code and evaluation time cannot be billed on the MDS, only time for interpretation of the evaluation and preparation of the report are billable. Documentation provided does not distinguish between evaluation minutes and interpretation minutes.
So they have 2 letters stating 2 different reasons for denial. I’m not even the biller here, I’m the coder, I do diagnosis coding for my facility. And I’m the only one so it’s frustrating at this point. This is the first time I’ve worked in LTC/SNF so I need all the help I can get with this one.
Thank you for taking your time to read this!