|
Noridian E/M Office Services; Top Provider Q&A Part 1
A collaborative of inquiries from the Medicare Administrative Contractors (MACs) in conjunction with the Noridian Provider Outreach and Education department over top provider questions was released on various local contractor websites last year. The intent was to ensure consistent communication and education so that providers have updated or clarifying information about E/M services for appropriate documentation and claims submission. In Part 1 of this article, we will cover some of the highlights involving E/M documentation, number of problems addressed, and data complexity clarifications.
Q: Under the 1995/97 CMS E/M guidelines, providers were held to specific criteria of history, exam, and medical decision making for the level of services provided. Yet, under the 2021 American Medical Association (AMA) E/M guidelines the level of service criteria shifted strictly to medical decision making or time. Will the medical record still require history and an exam?
A: Documentation must show the medical necessity of the service. This is the diagnosis or treatment of an illness or injury or treatment of a malformed body member. The guidelines indicate you perform the history and exam as clinically appropriate. Your documentation must support the medical necessity of the service and the level of service chosen. While the nature and extent of history and exam is determined by the provider and is not an element in code level selection, both should tell the patient's story, be medically relevant, and correlate with any presenting complaints.
Q: The first component of medical decision making (MDM) is the number and complexity of problems addressed at the encounter, which involves a disease, condition, illness, injury, symptom, sign, finding, complaint, or other matter that is evaluated and/or treated at the encounter by the provider reporting the service. If the patient has more than one problem, can I increase the number of problems addressed to a higher level?
A. No. Some of the bullets under the number of problems addressed indicate '1 or more'. This would mean that the additional problems in that bullet would still count for one bullet. some of the bullets indicate '1'. Choose your level based on the problem(s) addressed and the highest level or problem(s) indicated. Look to the other two elements, data and risk, to determine if a higher level of services is appropriate. In addition, when multiple problems are listed in the same range of medical complexity, this does not bump the problems addressed to a higher level. For example, if the patient has an acute, uncomplicated illness and a stable chronic condition, the problems addressed level is low and does not bump to moderate.
The second component of MDM, the amount and complexity of data to be reviewed and analyzed contains three different categories that are weighted differently when assigning credit and have a lot of AMA rules or clarifications. Here are a couple of additional clarifying Q&As:
Q: The patient brings a log of their food intake, blood pressures, blood sugars, etc. Can I count this as "external notes"?
A. No. Reviewing notes from another unique source data category 1) would be notes from another health care professional or organization. When choosing your level of service based on time, you can count the time spent reviewing the log.
Q: I reviewed the uploaded results of tests ordered by an external entity onto the patient's medical record. Can I count the review of this unique test?
A: Since the practitioner or a member of your group with the same specialty did not order the service, you could count this as a review of a test. If the test was part of an external note, you would only count the review of the external note. Documentation must show you reviewed the results and used those results in the medical decision-making for the patient.
Q: The medical record contains test results. Does this mean I can count the review of the tests?
A: Document your review/analysis of the test results. Your documentation must show your review and use for your medical decision for that patient encounter. If you submit a separate charge for the professional component of the test or use the independent interpretation as a data element, do not count the review.
Next month in Part 2, we will cover some highlights from the Q&A involving time, risk and miscellaneous questions.
|