October is too early for New Year’s resolutions, even if they are the same as last year’s: “Eat more fruit,” and “Renew my gym membership.” But October is the right time to plan for 2012 to insure your practice’s continued success.
- Stop me if you’ve heard this one: Test your electronic claims submission format this month to be sure that your software and clearinghouse can send the new HIPAA compliant 5010 format. Many private practices bonus their physicians in December, leaving little money in the practice. If your claims aren’t successfully transmitted in January, in the new electronic format, will there be money for payroll and rent in February and March? Establish a line of credit if you don’t already have one.
- If you aren’t using an e-Prescribing program: Find out if you can claim an exemption, and do so before November 1, 2011. Two exemptions already existed for practices that had limited high speed internet access or whose area pharmacies had limited internet access. These two exemptions were made on a claims basis, prior to June 30, 2011 to avoid a 1% reduction in 2012.
Four additional exemptions were given by Medicare, and are claimed by filling out an attestation on CMS’s website before November 1, 2011. Physicians are eligible if:
- They have registered in a Medicare or Medicaid electronic health record incentive program or have a certified EHR
- Were unable to prescribe electronically because of a local, state or federal law or regulation (mostly prescribe narcotics, for example)
- Had limited prescribing activity
- Had insufficient opportunities to report e-prescribing for eligible patient visits
You can read more about this on CMS’s website at http://blog.cms.gov/2011/08/31/greater-flexibility-in-e-prescribing-means-greater-success/
- Watch for coding changes later this year: If you haven’t ordered your 2012 CPT, HCPCS and ICD-9 books, do so now. Watch for articles that describe the changes for your specialty. If you order the CPT Professional Edition, changes to the editorial comments are in green, which can be helpful. Some groups order the specialty specific version of their book sold by commercial vendors, which also includes RVUs, covered diagnoses and indications, global days and NCCI edits. If your practice is large and you typically order more than one CPT book, order one of each to see which is most helpful for your practice.
- Review the CMS clarification on observation and consults:  In late August, CMS released to transmittals described as E/M Clarifications. (You can search for this in a search engine by putting in CMS Transmittal 2282 CR 7405 and CMS Transmittal 147, CR7405.) They did not break any new ground in these transmittals, but definitively answered some leftover questions.  CMS wants only the admitting observation physician to use subsequent observation visit codes 99224—99226.  All other physicians who see patients in observation status should use new and established patient office/outpatient visit codes, with the correct place of service. Most of our contractors paid claims this way, but CMS has made it official, and amended the Medicare Claims Processing Manual to state that. There is no similar CPT rule, making it a question what category of code to use (subsequent observation or office/outpatient visits).
CMS also re-stated its policy on paying for consultations, the policy change they made in January 2010. Some physicians questioned what to bill in 2010 and 2011 when the service would have been a low level inpatient consult, billed as a 99251 or a 99252.  There was not an official CMS crosswalk, but 99253 (level three consult) and 99221 (level one initial hospital service) had exactly the same documentation requirements. But what if a physician performed a lower level of consult? CMS instructs us not to use the unlisted code 99499 in these instances but reminds us that their policy is to allow the physician to bill a subsequent hospital visit, 99231-99232 in these instances.
- Be on the latest version of your software in 2012: It goes without saying that you’ll be on the latest version of your software at the end of 2011. If you’re not, you won’t be able to submit 5010 claims.  In order to submit ICD-10 codes in 2013, you will also need to be on the latest version of your software. Don’t wait until the last minute to make these upgrades. Stay up to date in the next two years. (Editor’s Note: Kareo customers are always using the latest version of the software, since it is web-based and updated automatically.)
As always, physician practices are dealing with the uncertainty of Medicare payments starting in January, and the threat of a large reduction. Â Our medical societies and professional organizations are working hard to avert this reduction, as they do every year.
Betsy Nicoletti, M.S., CPC, is the founder of Codapedia.com, a wiki for physician reimbursement. She is a nationally known speaker and consultant, and can be reached at www.mpconsulting.org. You can watch an informational video by Betsy Nicoletti on Better Collections Through Improved Medical Coding now. Or, view her archived webinar on What You Can Do to Prepare for Medicare Payment Reductions.
