Many of you may have heard that The Centers for Medicare and Medicaid Services and Office of the National Coordinator for Health Information Technology held a “listening session” in Washington on May 3, 2013. The meeting was with stakeholders to discuss EHRs and billing. Hmmm…I bet many of you weren’t invited.
You may also have heard that The American Health Information Management Association is urging more research on the causes of higher levels of coding and reimbursement through the use of electronic health record. Sue Bowman, Senior Director of coding policy and compliance, has reiterated their view, “The extent to which EHRs have led to improper reimbursement is unclear. EHRs produce more complete and accurate documentation and this could be leading medical providers to seek reimbursement for services they have always been providing, but weren’t properly documenting before. Higher levels of reimbursement do not necessarily equate to fraud.” [Good for AHIMA to share this very important tidbit the government bean counters must have overlooked when they estimated disbursements from their mandated EHRs!]
I’ve written several articles on coding the past year, emphasizing the issues that will and are resulting from too complicated a coding system. Here's one you might like to check out. IDC-10 Codes, There's Got to Be a BETTER Way!
This latest round about coding is a perfect example of the documentation mess we're in, except in the reverse. Now physicians are getting accused of seeking higher reimbursements because their EHRs are allowing them to more accurately document all the services they are providing - which are legally billable, by the way! Look at this from the physician’s side: They have expensive EHRs they've been mandated to implement. Now they have a capability to document and bill for all their services that they probably missed billing in the past due to “user/billing errors.” Doesn't it make sense that they would bill for all the services they provided - thus helping them pay for their EHRs, employee training, lost productivity, etc? Wow, if you’re healthcare provider in today’s healthcare world, you’re placed in a position of being “damned if you do and damned if you don’t.”
This reminds of our of complicated tax system. For those of us lucky enough to hire a good CPA, we can deduct everything coming to us, but those who can’t afford such professional services, you’re left to filing your taxes with only “street” knowledge that you’ve gathered over the years. And oh yeah, what you’ve learned may or may not be applicable to the newest tax rules, so you’re increasing your chances of being audited by the IRS.
Now back to Ms. Bowman... She’s recommending the development of a code of ethics for EHR vendors and users to design and use the system appropriately, guidelines to ensure features in an EHR are correctly used, development by CMS of a national set of coding guidelines for hospital reporting of emergency department and clinic visits, and education and training on coding with EHRs.
Forgive me, but on the vendor’s side, shouldn’t this be part of the licensing process for EHR software? There will always be some unscrupulous people in all professions, but is it necessary to make more laws to make sure docs are coding correctly? Remember, the new codes have increased from 13,000 to 55,000! Getting all the coding done correctly will be like finding a specific shell on the beach. There's a good chance you'll find the wrong shell? Coding accuracy will be a myth!
I would welcome dialog on the issue. It’s a big one for me and I’m hoping it gets you riled up a bit to!