DEPARTMENT OF INTERNAL MEDICINE
Billing Policy and Procedure
Physician Responsibility: (This document is available
in pdf format here)
- To fully document patient encounters for the services provided by
the physician (s) during the encounter.
- To document patient encounters
(Initial
history and physical, subsequent inpatient visits, short stay,
observation, emergency room, ambulatory surgery, outpatient, discharges
etc.)
within 24-48 hours of the encounter.
- Documentation of encounters
may be
dictated, legibly handwritten (pending full implementation of the electronic
medical
record), or entered through Power-Note.
- Physicians will determine
what level of E&M service to bill for a particular patient according
to the services provided and supporting documentation.
- To respond
to e-mail
or phone requests from the billing staff within 48 hours of receipt.
-
Annual review of the Internal Medicine and University Health Care
compliance policies.
http://www.muhealth.org/~compliance/corporate/index.shtml
- The Department of Internal Medicine
will continue to use the 1995 Center for Medicare and Medicaid Services
(CMS)
Documentation Guidelines and CMS Physicians at Teaching Hospitals
(PATH) Guidelines until such a time as those are amended and/or changed.
(SEE
INTERNAL MEDICINE WEB SITE BILLING OFFICE or Appendix.)
Billing Staff Responsibility
- Reimbursement Assistants (RA) will review inpatient written
documentation
and access the Electronic Medical Record to ensure that all documentation
present is used for billing purposes.
- RAs are to discuss with the
Reimbursement Specialist (RS) any and all services not meeting the 1995
Documentation
Guidelines, PATH Guidelines or University Policy and Procedures, resulting
in a non-billable or reduced/upcoded level of service. With the RS approval,
the RA is to notify physician and the division director via e-mail or
phone call. Follow up will be by variance reports.
- RA will contact the physician to correct issues such as missing time, date or signature prior to charges
being entered. If the physician does not respond to the e-mail or phone
call within 48 hours, the appropriate division administrator will be
contacted to determine if the physician is available to respond. If the
physician
is available and no response is received within 5 working days, the RA
will abstract and bill appropriately from the supporting documentation
available.
- Weekly review of the Internal Medicine and University Health
Care compliance policies.
http://www.muhealth.org/~compliance/corporate/index.shtml
- Staff will use the current year Current Procedural Terminology
(CPT) manual, International Classification of Diseases, 9th Revision, Clinical
Modification (ICD-
9-CM) manual, Medicare's National Level II coding (HCPCS) manual, and apply
the 1995 CMS Documentation Guidelines and CMS Teaching Physician
Guidelines when auditing physician documentation for levels of billable services.
- Perform audits on all billed charges and provide feedback to the physician
regarding any discrepancies found. The Office of Compliance may be contacted
for assistance when needed.
Billing and Compliance Education:
- RAs will review inpatient documentation for appropriate level of service(s)
according to 1995 CMS Documentation Guidelines and CMS Teaching Physician
Guidelines until such a time as CMS amends and/or changes these guidelines.
The RAs will use a current CPT, ICD-9-CM, and HCPSC manual to evaluate the
level of service.
- RAs will note any discrepancies between documentation of services and levels of
service marked or selected by physician on individual physician variance reports
including under coding, over coding, missing procedures, incorrect or no date of
service, etc.
- If the documentation is not legible, the physician will be contacted via e-mail or
phone and be allowed the opportunity to dictate or type the notes prior to billing
the charge. Failure to do so will result in the charge not being billed and the
information being reported back to the physician with a copy of the
documentation via variance report.
- RSs will offer individual educational information to physicians regarding
compliance problems. Office of Compliance may be contacted for assistance
when needed.
- If there are questions regarding adherence to 1995 CMS Documentation
Guidelines and/or CMS Teaching Physician Guidelines when auditing physician
documentation for levels of billable services, those questions will be referred to
the Office of Compliance for clarification and guidance.
- After reviewing variance report discrepancies with the Billing
Office, physicians
who disagree with the Billing Office's audit finding(s) may request that the
Billing Office contact the Office of Compliance for an independent review of
the
discrepancies.
- In extreme cases if the Billing Office continues to encounter problems with an
individual physician, who has been instructed on the 1995 CMS Documentation
Guidelines and CMS Teaching Physician Guidelines and continues to insist the
Billing Office is incorrect, the physicians behavior will be reported to the
Chairman of the Department, and/or Compliance Resource and Reporting Line at
(573) 884-1729 per Code of Conduct Guidelines.
http://www.muhealth.org/~compliance/handbook/index.html
- Appendix
A. University Compliance Plan
B. Internal Medicine Compliance Plan
C. 1995 CMS Documentation Guidelines
D. Physicians at Teaching Hospitals (PATH) Guidelines
E. RA Audit Sheet
F. Sample Variance Report
Oversight for Policies
A. Administrative Manager to monitor Reimbursement Assistants and
Reimbursement Specialists Responsibility as outlined above
B. Department Chairperson, Vice Chairperson and/or Department Compliance
Liaison to detect problems or items as outlined above in the Physician
Responsibilities
C. The Office of Compliance has oversight responsibility. The Compliance
Director is strongly committed to ensure compliance with all applicable laws,
regulations and policies with which we conduct business at the University of
Missouri Health Sciences Center.
