Are You Ready for CMS’s multi-faceted Reimbursement Reduction Movement? (Part 1)

Healthcare Finance News posted this back in May. I love the first line of this article:

“Take heed, hospital administrators – Uncle Sam is watching.”

Oh how true. Most everyone involved in healthcare knows that “Uncle Sam is watching.”

And we also know that good ole CMS is getting pickier and pickier about what they are going to pay for these days.

“While no healthcare sector is being spared from the reimbursement knife, the Value-Based Purchasing initiative is aimed squarely at hospitals.” {Value-based purchasing (VBP), which links payment more directly to the quality of care provided, is a strategy that can help to transform the current payment system by rewarding providers for delivering high quality, efficient clinical care. Click here for more details.} “It is part of a larger reimbursement reduction movement that also includes the Recovery Audit Contractor (RAC) program, Medicare-Severity DRGs (MS-DRGs) and pay-for-performance (P4P).”

“The intent is to use the combination of transparency and fiscal reward to drive clinical quality, patient-centric services and operational efficiency.”

“This program, which I call the ‘Hospital Acquired Payment Adjustment Provision,’ is an overall movement to control costs at the Medicare and Medicaid levels,” said Walt Zywiak, principal researcher for CSC. “CMS has decided it will not make payments for hospital-acquired conditions. Overall, how it works is that if a hospital submits a Medicare claim for any of 10 CMS-identified conditions that were not present upon the patient’s admission, payments for those claims will be reduced.”

The 10 categories of conditions that CMS selected for the Hospital Acquired Conditions (HAC) payment provision are:

1. Foreign Object Retained After Surgery
2. Air Embolism
3. Blood Incompatibility
4. Stage III and IV Pressure Ulcers
5. Falls and Trauma
   • Fractures
   • Dislocations
   • Intracranial Injuries
   • Crushing Injuries
   • Burns
   • Electric Shock
6. Manifestations of Poor Glycemic Control
   • Diabetic Ketoacidosis
   • Nonketotic Hyperosmolar Coma
   • Hypoglycemic Coma
   • Secondary Diabetes with Ketoacidosis
   • Secondary Diabetes with Hyperosmolarity
7. Catheter-Associated Urinary Tract Infection          (UTI)
8. Vascular Catheter-Associated Infection
9. Surgical Site Infection Following:
   • Coronary Artery Bypass Graft (CABG) – Mediastinitis
   • Bariatric Surgery
     • Laparoscopic Gastric Bypass
     • Gastroenterostomy
     • Laparoscopic Gastric Restrictive Surgery
   • Orthopedic Procedures
     • Spine
     • Neck
     • Shoulder
     • Elbow
10. Deep Vein Thrombosis (DVT)/Pulmonary Embolism (PE)

• Total Knee Replacement
• Hip Replacement

Source: http://www.cms.hhs.gov/HospitalAcqCond/06_Hospital-Acquired_Conditions.asp

So, we see that CMS is putting hospitals to the test when it comes to transparency in documentation and quality of care. As an administrator, how do you ensure that your physicians are accurately documenting care administered to patients, according to the rules of CMS? Are you relying on them to include this in their dictated reports? If so, how do you remind them {uh, change their behavior} to include documentation of POA conditions? Post-it notes? Posters on the wall? Notes in the Physician Lounge? {All of which make little-to-no impression on the physician.}

OR, have you invested in a compliance-driven documentation program, like ComplyMD, that will help your physicians deliver robust documentation to your facility? Chances are, you have not. Chances are, your EMR will not do this either.

Better documentation is becoming increasingly important. Remember, Uncle Sam is in fact watching. You better get equipped to handle all of his demands.

Round 1’s Definition of “Meaningful Use” for EHRs

As we discussed the governmental push {Stimulus} towards EHR, the definition of “meaningful use” came to surface; rather the lack of definition arose. EHR companies and healthcare facilities alike have been waiting to hear from the HIT Policy Committee on “What exactly defines ‘meaningful use’ of an EHR?”. On June 16, the committee released its initial recommendations for the definition.

Health Data Management reported this “First Look at ‘Meaningful Use’” article, which lists 15 of the 22 objectives for EHRs in 2011. Here’s the list:

* Use CPOE for all order types including medications
* Implement drug-drug, drug-allergy and drug-formulary checks
* Maintain an up-to-date problem list
* Generate and transmit permissible prescriptions electronically
* Maintain an active medication allergy list
* Send reminders to patients per their preference for preventive and follow-up care
* Document a progress note for each encounter
* Provide patients with an electronic copy or electronic access to clinical information such as lab results, problem list, medication lists and allergies
* Provide clinical summaries for patients for each encounter
* Exchange key clinical information among providers of care
* Perform medication reconciliation at relevant encounters
* Submit electronic data to immunization registries where required and accepted
* Provide electronic submissions of reportable lab results to public health agencies
* Provide electronic surveillance data to public health agencies according to applicable law and practice
* Comply with federal and state privacy/security laws and the fair data sharing practices in HHS’ Nationwide Privacy and Security Framework, released in December 2008.

Once this first round of definition and standards were released, we read in Modern Healthcare where

“the group invited feedback on whether the balance it sought to strike was ‘overly aggressive based on the current state of technology and the demands on new provider workflows, or not challenging enough to result in significant transformation.’”

Some believe the group did a nice job of establishing a decent framework for the standards. Some believe the objectives have set the bar a little too high, which could slow the adoption of EHR. The jury is still out.

“For better or worse, it is now the starting point for what surely will be months of debate on ‘meaningful use’ before the federal rulemaking is completed. That is expected to happen sometime early next year. Even then, the meaning of ‘meaningful use’ will remain fluid throughout the life of the EHR subsidy program, which is now slated to run through 2015.”

Here’s a helpful matrix that the group developed that outlines the Goals, Objectives and Measures of “Meaningful Use”.

There is one thing you need to be sure of: Make certain that your EHR not only meets the governmental standards and objectives, but also shows measurable results in your facility with positive feedback from active users. Make sure that your facility sees improved patient care, increased safety, reduced medical errors, and a healthier bottom line. To do this, you must be sure that your EHR covers all your bases.

In my time, I’ve seen a gap in the ability of EHRs to capture surgical documentation at the point of service. This is exactly where ComplyMD comes into play and fits seamlessly with most any EHR on the market. You’ve got to engage physicians. You’ve got to capture their attention at the point of service, when their knowledge of the patient encounter is most fresh. You’ve got to ensure they give accurate, comprehensive documentation. You’ve got to have ComplyMD’s Surgeon Notes™ solution.

Physician Documentation and Coding: Are Doctors Prepared?

This abstract from the American Journal of Surgery entitled “Surgical residents’ knowledge of documentation and coding for professional services: an opportunity for a focused educational offering” hints at the fact that most physicians are not properly prepared for coding and documentation in the real world of medicine.

We all understand that patient care is the most important aspect of practicing medicine. In Med School, physicians are trained to take care of patients. Many even specialize in a certain area of medicine and take care of certain kinds of sick people.But what about documentation and coding? Why aren’t physicians trained on how to best document what they did on patients? Isn’t good documentation important to continuity of patient care? Isn’t this how they are to defend themselves in a (heaven forbid) medical malpractice case? Isn’t this how they get paid? If physicians don’t know how to document, they’re losing….and its more than just dollars and cents. They’re honestly robbing themselves of being a “Best Pracitces” physician within the healthcare industry. So….WHY is this not taught to physicians in their formal education?

“The purpose of this study was to survey surgical residents and attending for their knowledge of documentation and coding and their opinions about its importance in their training and practice.”

The convenience sample: 60 surgical residents and 46 attendings from 5 surgical residency training programs

“Similar portions of residents and attendings, 82% and 89%, respectively, stated they had not received adequate training in DCPS (documentation and coding for physician services). The vast majority of residents (85%) felt they were novices at coding and billing, whereas 61% of attending stated that they were somewhat knowledgeable.”

So 82-89% of residents and attending do not feel adequately trained in DCPS. So how will they learn? Think about it…CMS, Joint Commission and all the other players have so many rules and regulations that doctors must play by; but the docs are never taught the rules in the first place. It seems that docs have to (a) learn the hard way by making costly mistakes (b) take initiative towards independent training or (c) continue to be losers in the area of documentation and coding.

How Far Does Your Facility Go for Documentation Assurance?

In Hospital Case Management’s recent article “Does Your Documentation Assurance Program Stop Short?” (March 1,2009), the following quote caught our eye:

“If your documentation assurance program focuses on reimbursement alone, you’re not going far enough. With pay-for-performance initiatives on the rise and increasing mandates for public reporting of hospital data, it’s critical that the medical record accurately reflect the severity of illness and the services provided to your patients.”

If we really think about it, the quote above is totally true. Many facilities have implemented Documentation Assurance Programs, such as Clinical Documentation Improvement initiatives. And these programs oftentimes measure ‘success’ in terms of dollars and cents, rather than by quality documentation of severity of illness, continuity of care, level of acuity and risk of mortality.

“Many times, documentation specialists do a great job of picking up the complications/comorbidities (CCs) and major complications/cormorbidities (MCCs) but stop right there and miss the opportunity to add additional documentation, which will affect the drivers of acuity level and risk of mortality.”

Documentation Specialists are trained professionals who are taught to look for those CCs and MCCs. In an attempt to build the best DRG, they must capture these important conditions. But, they shouldn’t just stop when they’ve gotten to a certain DRG level. A good Documentation Specialist will not be focused on getting the patient into the highest paying DRG, but will be focused on painting the most comprehensive picture of the health of each patient.

This is exactly where ComplyMD comes in. In attempt to paint the most vivid picture of (1) the health of the patient and (2) the procedure(s) performed on the patient, we aid physicians and staff in capturing the most documentation about each patient encounter.

Lemak Sports Medicine Adopts ComplyMD Surgeon Notes

When world class athletes are sidelined, they find Dr. Lawrence Lemak for his orthopaedic expertise. When a world class doctor seeks to improve his documentation, he finds ComplyMD. The solution to healthcare’s archaic documentation process is ComplyMD Surgeon Notes. 

 

“I haven’t seen a noteworthy change in any type of documentation solution since the dinosaur system I saw in 1970″, said Lemak. “We’ve chosen to implement ComplyMD at Lemak Sports Medicine because it’s a type of documentation process we’ve never before seen – and we like it. ComplyMD will revolutionize the way we document our procedures.”

 

Lemak Sports Medicine, located at Brookwood Hospital, consists of three practicing physicians and three fellows. ComplyMD Surgeon Notes is a great fit for Lemak because of their high volume of orthopaedic cases. Scheduled for an early summer implementation, ComplyMD will shift the cumbersome, antiquated process of documentation from redundant dictation/transcription to a smart, physician-friendly tool. ComplyMD enables the vivid documentation of patient health and accompanying procedures, immediately generating complete and accurate data that is instantly available to both his office staff and the hospital/facility staff. The value of ComplyMD’s artificial intelligence intrigued Dr. Lemak. The system adapts to his team’s documentation behavior, allowing them to focus more on patient care and still generate a compliant and complete operative report.

 

“Dr. Lemak is known for excellence in healthcare. We’re delighted he selected ComplyMD Surgeon Notes to be a part of his successful practice,” said Curtis Palmer, CEO of ComplyMD. “His extensive experience will allow us to further develop ComplyMD’s radical process shift in healthcare documentation.”

* * * * *

ComplyMD allows physicians to vividly document the health of their patients and the procedures administered during their encounters, immeidately generating complete and accurate data for physicians. ComplyMD shifts the documentation process to enhance rich data creation, improve efficiency and maximize productivity in healthcare facilities.

Lemak Sports Medicine: World renowned orthopaedic surgeon, Dr. Lawrence J. Lemak, has played an integral role in sports medicine and arthroscopy research. He specializes in sports medicine, arthroscopy and reconstruction of the knee, shoulder, hip and elbow. As a leader in the field of arthroscopy, Dr. Lemak has published articles in numerous medical journals and has given presentations in the United States, England, Europe, Japan and South America. Many professional sports organizations call upon Dr. Lemak’s expertise as he serves as Medical Director for Major League Soccer, NFL Europe, Professional Golf Association and the Ladies Professional Golf Association. He is also Team Physician for many colleges and universities throughout Central Alabama and the Southeast. He is the National Medical Director for PhysioTherapy Associates, a leader in outpatient physical therapy with over 600 locations throughout the country. Dr. Lemak serves as the Associate Dean of Entrepreneurial Medicine at the University of South Florida, and is a Trustee of Alabama State University.

The Results Are In….One Office Coder Tells Her Story on the Benefits of ComplyMD

Physicians who currently use ComplyMD, have seen great results in their documentation. They are more aware of the benefits of capturing accurate, real-time documentation: benefits to the patient, benefits to themselves, benefits to the hospital/ASC, and benefits to their office staff. Here, I’d like to focus on some great feedback we received from one practice’s office coder.

And I quote…

-Chart accuracy has improved by 75%.

-Specifically, our physicians are now documenting their (1) lesion removals and (2) incision and drainage of abscesses more accurately, resulting in more accurate coding and reimbursement for our office.

-The free-text availability in ComplyMD has proven helpful in coding procedures and diagnoses. Our physicians are able to better communicate to us exactly what they did, along with the exact condition of the patient.

-Our billing department has become a more efficient, productive place with the utilization of ComplyMD.

-Our work load has decreased by about 40%.

-Increased ComplyMD usage has decreased the frequency of phone calls to the hospitals’ HIM departments by 80%.

-ComplyMD promotes a more efficient, more accurate method of documentation and coding among healthcare professionals.

Real people. Real results. Why not document with ComplyMD?