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The Standards for Healthcare Records
The healthcare world is not a provider on an island where there are no
concerns for the information in the records beyond the borders of the
island. There are numerous amounts of information that must be
documented correctly and within some very strict and exacting guidelines.
The number of entities that set the regulations for the information found in
the charts seems to grow each year. The medical data found in the charts is
no longer just for the care of the patient; it is now used to measure the
quality of patient care and to determine how compliant the provider is in
regard to governmental regulations. To better understand the how and why
of this arrangement, let us take a step back and build a pyramid to
determine how this is possible.
The primary purpose of the healthcare record, as discussed earlier, is the
documentation of the medical care provided to a patient. This information is
changed into codes that represent both the services received by the patient
and the diagnoses of the issues that brought the patient to the provider’s
office. The medical chart is coded by a staff member or the medical staff.
These codes are then transferred to the patient’s insurance carrier for
payment of the services. The payer processes the claim submission and then
sends payment back to the healthcare provider. This is when the borders of
the island begin to fade.
There are several agencies that influence the formatting of the
documentation found in the medical chart. The guidelines for coding the
procedures that represent the services received by the patient are written
by the American Medical Association (AMA) and adopted by the Centers for
Medicare & Medicaid Services (CMS). Since the CMS is a federal agency
funded by tax payer money, there are several regulations that must be
followed to assure compliance. The first regulation states that Medicare will
not pay for services that are not reasonable and necessary for the diagnosis
or treatment of illness or injury (Centers for Medicare & Medicaid, 2014). It
is of utmost importance for the CMS to be able to verify the information
found in the medical charts as accurate and supportive of the services for
which the medical provider has received payment. This same principle
applies to all areas of the government when it comes to using taxpayer
money to pay an entity for services rendered. So there we have a pyramid
to show how the provider is not on an island alone; what services the
provider performs must be supported by documentation.
Many insurance carriers have adopted the same guidelines used by
Medicare and Medicaid as their own standards. Other entities have entered
into the picture to set standards for the medical charts. One of these
entities, the Joint Commission, is an organization that provides standards
that affect patient safety. Healthcare entities will voluntarily request the
Joint Commission to inspect the healthcare facility in order to attain what is
known as an accredited status. This status shows the community the
facility’s desire to provide the best service available. The accredited status
also allows the facility some additional benefits related to participation
agreements in many insurance programs.
There are a number of organizations that look at the facility to verify patient
safety and make sure the services that are reported are actually the ones
being performed at the facility. The medical record documentation is one of
the most important areas that these organizations will want to review when
looking at a healthcare facility. The documentation found in the medical
chart is a legal document. It represents to standards by which the facility
operates. The importance of the medical document cannot be overstated.
Data Mapping and Bell Curves
The purpose of a bell curve is to limit your organization's vulnerability to an
insurance audit. A good way of doing this is through comparing benchmarks
at the national and local levels. The bell curve should take the shape of a
bell and should not show any outliers that could make you a target for
audits. Bell curves are used by insurance companies, both governmental and
private carriers, to do a quick evaluation of a provider’s billing levels. There
are many things that can be discovered about a provider’s billing levels from
these bell curves.
For example, if a provider bills all 99204, then it would make insurance
carriers question the validity of the services provided. The Program for
Evaluating Payment Patterns Electronic Report (PEPPER) monitors the data
that leads to improper payments. It is vital that organizations monitor
coding accuracy, as well as trends in regard to code use, through auditing
and compliance programs. Take a look at the Module Four Comparison
Chart Spreadsheet for a visual of a bell curve.
Compliance audits are performed to examine the proficiency of the provider
and the coding staff on regulations regarding coding and billing. Every claim
in the practice is not audited; instead, a random sample is selected. If the
random sample indicates a need for further review, then more charts will be
selected. If the initial claims do not indicate any issues, then no further
actions are necessary for the auditor. One of the initial indications of an
issue can be found by simply reviewing the range of evaluation and
management (E&M) codes billed. There should be a spread of codes
indicating that all codes are being used. Being outside the range of codes
over the normal spread could indicate an issue that needs to be addressed.
The normal range for established patients would be a few codes in 99211
and 99215, with the majority of visits in the 99212–99214 range. It would
be the same for new patients—a few in 99201 and 99205, and the majority
in 99202–99204.
References
Centers for Medicare & Medicaid. (2014, February 25). Medicare learning
network. Retrieved from www.cms.gov
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