Healthcare Revenue Cycle Compliance
Billing/RCM

Best Practices in Patient Eligibility and Benefits Verification

Written by: Melvin Miller, Chief Operating Officer




With rising consumerism, patients have increasing responsibility for payments. The growth of high deductible health plans (HDHPs) is a clear indicator of this trend. It is, therefore, important to clearly understand the patient's responsibility for payments upfront and determine coverage.  


This article highlights the importance of patient eligibility and benefits verification.


What is patient eligibility and benefits verification?


A healthcare practice must verify a patient's coverage for medical services and determine their responsibility for payments. Through the patient eligibility and benefits verification process, physician practices can confirm the coverage offered by the health plan and copayments, deductibles, and co-insurance with the health plan. 


Verification of eligibility promotes the collection of the coverage status and reduces the likelihood of claims getting denied. It enables healthcare providers to collect payments from patients proactively and prevents delays in cash realization.


Information to be provided for patient eligibility and benefits verification


One of the fundamental components of the front-office tasks is to collect the patient details upfront and enable the verification of benefits by insurance verifiers.


Healthcare providers must train staff members on the insurance verification processes. Efficient processing reduces the likelihood of denials and accelerates the cash flow cycle.


Electronic and manual eligibility verification processes


Most payers have made available interfaces to check eligibility online. By verifying eligibility electronically before the scheduled patient appointment, you will be able to:

  • Get accurate information about the patient's insurance status and understand the benefits of the health plan.
  • Determine if you must collect a co-pay at the time of service.
  • Update insurance details.
  • Get patients to update primary care physician details.

Sometimes, it may be necessary to call the payer with questions related to prior authorization requirements or clarify some eligibility and benefits elements.


Timeliness of eligibility checks


Healthcare providers must check eligibility at least 48 hours before the visit. Should this not be possible, it can be done in real-time during check-in before the treatment. Timely eligibility checks help you reduce claim rejections and denials. Most electronic health records and revenue cycle management systems have electronic eligibility checking functionality. By verifying the patient's coverage before care delivery, your practice will be able to reduce denials and improve revenue realization.


Importance of process documentation


The needs of your practice are unique. A substance use support clinic has very different eligibility verification requirements from a hospital or radiology clinic. Hence, each institution must create specific eligibility and benefits verification workflows. All your team members need to collaborate effectively and ensure efficient completion of all steps.


Checklist for eligibility verification


The following are some of the best practices for the patient eligibility and benefits verification process.

  • Check if the plan is active.
  • Always quiz the patient about any impending or recent insurance changes.
  • Check if the patient has multiple insurances – primary, secondary and tertiary. Ensure that the patient has updated the Coordination of Benefits (COB) with each payer.
  • As a significant percentage of the population in the United States is aging, verify the Medicare coverage for patients who are above 65 years of age.
  • Understand if you need prior authorization or a referral for the specific medical service. If referrals or authorizations are needed, please obtain them and update the revenue cycle system.
  • Confirm if the patient's policy covers the procedure.
  • Some plans may stipulate the number of visits and time frame in which medical services can be delivered and have a ceiling on the benefit limits. The front office must obtain these details.
  • Specific services such as behavioral and mental health, substance abuse, and addiction may require a call to the insurance company. You may not be aware of these requirements and must refer to payer-specific guidelines.
  • Collect the payments for deductibles, copayments, and co-insurance based on the policy details. Pursuing patient collections can be tedious, and you must collect as much upfront as stipulated.
  • Collect additional information.

Social determinants of health are becoming an essential element of care delivery and promote healthcare equity and access. Characteristics such as race, gender, ethnicity, date of birth, preferred language, etc., are essential for Meaningful Use reporting. These characteristics are also crucial for health equity studies.


Outsourcing eligibility and benefits verification processes

 

An outsourced service provider can help you carry out eligibility and benefits verification processes. Their training processes help you get expert workers at reduced costs and reduce the workload on your revenue cycle team. Some of the benefits of outsourcing are:

  • Freeing up your staff's time to focus on other patient experience improvement and revenue cycle functions.
  • Speeding up time to care delivery.
  • Reducing denials and accelerated cash flow.
  • Reducing costs through labor rate arbitrage.
  • Well maintained policies and procedures.
  • Shifting the focus to denial prevention by reducing the number of eligibility and benefits related denials.

Eligibility and benefits verification company competencies


Efficient eligibility and benefits verification processes are essential for your organization's financial well-being. The process also accounts for the highest component of claim denials. You need to learn from each denial and constantly improve. Retain a company which can provide seasoned revenue cycle workers who can support your front-office staff with eligibility and benefits verification processes as well as comprehensive revenue cycle solutions to reduce costs and improve efficiency.


Additional Resources:

  • Medical Billing Wholesalers - https://www.medicalbillingwholesalers.com
    _________________________________________________________
    Melvin Miller is an experienced Chief Operating Officer with a demonstrated history of working in the healthcare industry for over 15 years, Satish, a.k.a. Melvin, has experience in team building, business development, Healthcare Information Technology (HIT), revenue cycle process training, US. Health Insurance Portability and Accountability Act (HIPAA), and Healthcare Management.
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Healthcare Revenue Cycle Compliance
Billing/RCM

Provider Credentialing Verifies Expertise

Written by Angela Chorny, MA, President and CEO of Emerge and See, LLC




Payor Enrollment – An Understated and Overlooked Process


Oh, the all-important question of credentialing! Why do we need to be credentialed and what is it?

Credentialing is the anchor between billing and being PAID. It is one of the most important aspects to healthcare, AND, in many cases, it is REQUIRED!


So, what is credentialing? Credentialing is the process of verifying that a provider’s expertise and qualifications to render care to patients are real and valid, this process is also called Primary Source Verification, or PSV… simply stated.


Many facilities and groups who are accredited by an entity, such as JCAHO, AAAHC, AAAASF (just to name a few), are REQUIRED to complete this process for every provider who is rendering services within the group or facility, especially active, licensed, independent practitioners, or LIPs. The accreditation agency will provide their own list of requirements, but a group or facility may include additional requirements of their own in order to privilege a provider.


The buck doesn’t stop there, though, that’s only about half of the credentialing process. Payor enrollment is an understated and overlooked process. This is where the provider is enrolled into the health plans that they would like to accept from their patients. If the provider is not enrolled in the plan, you will not be able to bill for services rendered, ESPECIALLY with Medicare and Medicaid.


In addition, once the provider is enrolled with the payor/insurance health plan, they are added to the roster of available care in their area… built in marketing! When a patient calls and requests a list of providers that accept their health plan in the area requested, the enrolled provider and/or practice will be on that list provided to the potential new client.


So Why Is Credentialing So Important?


  1. Protecting Patients and Ethics.

    Credentialing is undertaken to determine whether a practice or healthcare professional is fully qualified to treat patients. Patient care has always been the core purpose of medical credentialing. The process itself is rather tedious and involves verifying a practitioner’s credentials against various relevant data points.

    For instance, a provider is continuously monitored against major publications like the Death Master File, Sex Offender Registries, National Abuse Registry, OFAC, and many other sources. A provider can be denied credentialing if their name shows up in any of the above data points.

    Credentialing also monitors sanctions on a provider’s license via the Office of Inspector General (OIG) as well as any possible lawsuits and their outcomes via the National Provider Data Bank, or NPDB. These tools have been put in place and are required to be utilized to help the practice make a determination as to whether the provider should be privileged or employed by the entity. Credentialing can also be denied based on a provider’s license having expired or having defaulted on their student loans.

    Credentialing instills confidence among patients and provides added comfort that the organization wants to provide professional and ethical services to a patient. For example, it would be nice to know that a particular provider in charge of providing treatment to a child is not a registered sex offender or that a psychologist has the qualifications necessary to provide you with sound advice.

    Competency and performance reviews are a fundamental part of the credentialing process. Organizations who implement this process leave no stone unturned in determining whether a practice or healthcare professional is worthy of being credentialed. As a result, patients can feel safe going for treatment to clinics and hospitals whose staff are all credentialed.
  2. Prevents Lost Revenue.

    Insurance carriers do not reimburse for services rendered if the provider and/or entity is not credentialed, or enrolled, with them. It is important to note here, that being enrolled with a payor and being “in network” are two different things. Once the provider is enrolled with the payor, services rendered may then be billed. Becoming “in network” means that the provider now has a contract with the payor and rates are set as per the agreement and cannot be negotiated until the agreement term has expired.

    Furthermore, it is illegal for the payor to reimburse anyone prior to having completed their own Primary Source Verification process. Therefore, at all times, a payor will advise you NOT to see their patients until the provider or organization is credentialed with them.

    Once enrolled with a payor, you are ready to bill for services rendered and will be reimbursed according to the agreed upon fee schedule. You just opened the door to an entirely new set of patients, thereby increasing your revenue!

    In addition, as previously mentioned, the provider will also be added to the roster and registry for patients who call in to request a particular type of provider in their area. So, the payor, is driving more patients through your door.
  3. Mitigate and manage risk.

    With the latest increase in lawsuits over lack of appropriate credentialing on behalf of an entity, it’s one of the most basic parts of your practice that you want to protect. As immunity began to lose ground as a viable legal argument, the 1957 case Bing v. Thunig firmly established that hospitals have an ethical responsibility for the medical care received by patients.

    A few years later, the 1965 case of Darling v Charleston Community Memorial Hospital—in which a staff provider so severely erred in the setting of a broken leg that it eventually had to be amputated—set the legal precedent that a hospital could be held negligent for failing to assess or monitor the competency of their medical staff.

    To limit liability in the aftermath of these cases, hospitals implemented more   rigorous credentialing and privileging protocols. Unfortunately, this led to another problem… Providers being denied appointment or privileges by a hospital’s governing body turned to the Sherman Act and state antitrust laws to claim that the practice of credentialing amounted to anti-competitive collusion. Providers claiming injury under the Sherman Act must demonstrate that the denial or revocation decision negatively impedes the availability of medical services within the community.

    Stuck between a rock and a hard spot of this legal minefield, hospital and medical staff leadership, in particular those assigned with peer review responsibilities, were reluctant to deny medical staff appointment or privileges. The Health Care Quality Improvement Act (HCQIA) of 1986 provided those physicians involved in peer review activities a layer of protection against lawsuits filed by the physician under review in retaliation for a negative decision by their peers. Improperly used, HCQIA can be seen as a shield inviting abuse by those in a peer review position for decisions that benefit themselves directly or indirectly. As a result, antitrust claims continue.

    Over the years, hospitals have recognized that strong and transparent credentialing and privileging processes provide the greatest guarantee of qualified and competent medical staff and the best defense against legal risks. CFR regulations (U.S. Code of Federal Regulations (CFR)  have, as a result, become the best standard for due diligence.

Know the Law


As healthcare credentialing becomes increasingly more important, be sure that you know your way around. Hospitals generally follow a basic credentialing and privileging framework established within the section of the U.S. Code of Federal Regulations (CFR) comprising the Public Health Service Act. However, these CFR Title 42 regulations (Conditions of Participation—CoPs) only specify credentialing and privileging requirements for hospitals to gain or maintain accreditation to participate in Medicare and Medicaid.


Even though Title 42 CoPs do not directly affect hospitals outside of Centers for Medicaid and Medicare Services (CMS) jurisdiction, they are still important to an unregulated health sector operating in a patchwork of federal, state, and civil legal landscape.


Create a Credentialing Process


Be clear on what you expect your providers to present to you for all background checks and scans as well as for payor enrollment purposes. That way, you will be able to streamline. Be sure to assign a person to the task. It can be a very tedious and time-consuming process, so it’s usually best if you have help that can handle all tracking of enrollment applications as well as any expirables that may be coming up.


Don’t miss the reappointment dates! If reappointment dates are missed you are back to square one in the credentialing process of payor enrollment, and if you miss any within your organization, you are no longer in compliance with your accrediting agency and neither is the provider!


If you choose to outsource, which is becoming exceedingly more popular now, be sure to choose a reputable organization. Many organizations are popping up nowadays, so it is definitely important that your Credentials Verification Processor (CVO) knows what they’re doing as regulations absolutely need to be followed.


About My Company


There are also enrollment companies and one stop shops available, such as Emerge and See, LLC where we handle the entire process for you. Emerge and See is based on a solid foundation of seasoned Credentialing Specialists. We become your full-service Credentialing Department while saving you an enormous amount of money on payroll. Please feel free to visit our website at www.emergeandsee.com, it would be our pleasure to be at your service!


As we say in the credentialing world… Happy Credentialing!

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Auditing, Managing Denials Is Important to Good A/R Hygiene
Auditing

Wrestling the Dragon

Avoiding Medical Denials When the Problem is Elusive


Written by Carl J Byron, CCS, CHA, CIFHA, CMDP, CPC, CRAS, ICDCTCM/PCS, OHCC and CPT/03 USAR FA (Ret)


In the first part of this series, we looked at a young patient in their early 20s who, in spite of 24- hour care by multiple specialties, died and all claims were denied in their entirety.

In this new case, we have a long-term inpatient who was attacked by an exotic animal a friend was keeping “as a pet.” Almost every specialty is called in on the case and the inpatient stay lasts well over a year. But during that time, after about 3 weeks of visits, Infectious Disease doctors stop billing for their services. They are worried with what little they have to go on that their claims will be denied out of hand “anyway.” They know the episode (the entire hospital stay once the patient is finally released) will be reimbursed on a limited basis and they would rather the payments go to the doctors with more detailed codes. For nine months, not one claim is filed. As you would expect, especially if you have seen any exotic animal attack cases that made the news, the damage to the victim’s body was immense and multiple large surgeries were required.

This time, the dragon is facing us and ready to charge. We don’t have to chase it, we know the problem. We have to wrestle it. We have to bring enormous complexity to a patient stay that has so many aspects, details and nuances that the argument for submitting the claims and getting paid is difficult because the patient’s condition is so poor the insurance company will have difficulty understanding all of the medical complexities. This is somewhat different than a pre-payment audit because the claims have not yet been completed. Infectious Disease (ID) providers, with decades of experience, are reluctant to file claims because of fear of denials and, by extension, accusations of fraud. Again, we are dealing with a problem. Although it is physically obvious, it is not so clear when reduced to codes which fall far short of the extent of the providers’ work to save the patient. The payor guidelines are equivocal and do not address a unique situation like this. But there is a statement that the medical decision making and clinical reasoning of the providers for any patient will be given primary weight. This is critical. Unless I can find something unique, the ID providers are stuck with only three procedure codes: 99231, 99232, and 99233. Not much room to maneuver.

My manager assigns me all of the ID claims and asks me to conduct a 100% records audit for the nine months. As in Part 1 of this series, the first thing I do is look at the progress notes. Due to the sheer volume, I determine (1) how many encounters there are total; (2) what would be a statistically significant sample number and then pull encounters from random dates throughout the hospital stay. Now the real work starts.

The first thing that strikes me is the enormous amount of damage done to the patient’s body. From the documentation alone, I could tell the damage was beyond anything I had ever seen. Extremely deep scratches were documented as well as punctures from fangs that tore through skin, muscle and tendon and literally shredded bones. Dislocated joints from being grabbed and pulled so hard the body could not tolerate the shearing forces. Grafts as well as vascular and orthopaedic repairs have to be done in “bouts” throughout the stay because the damage is so comprehensive the repairs cannot be done at one surgical visit. This is critical because it tells me even with gauze, coverings, etc., the patient’s underlying skin, muscle, tendons, blood vessels, lungs and even heart are in serious jeopardy of infection. A note was made and I proceeded from there. Inference tells me that, with so many surgeries completed and yet to be done, much of this patient’s skin and underlying structures are now open, even with the best suturing on the planet and antibiotics. Inference further tells me so many grafts present an infection potential of their own. Think of a paper cut: painful, obstinate, those things just don’t want to heal. Now, take that cut and make it into a long tear down to the bone and imagine 75%+ of your body area being torn, bitten, scratched or surgically open like that. You might get about a 5% picture of this patient’s daily situation. Just “maintenance” required a Herculean effort.

There are times when an auditor needs to let the inferences guide the direction of the audit, at least in part. Such was the case here, both with the documentation and with photos, and I will clarify it shortly. The next step, and I will admit I could be accused of changing my random audit to a targeted one, I looked for all the encounter dates I could find with photographs and x-rays. The photos were pretty gruesome but they displayed a very important fact: the opportunity for infection was always dangerously high. So, my first argument was made for me. Even if all ID did was maintain this patient, it was a serious accomplishment. It is said a picture speaks a thousand words. Those, coupled with the documentation, made an ironclad argument and I already knew we had a good chance.

As in Part 1, when I had assembled my audit structure and determined how I would proceed, I looked at every progress note. Then, I looked at every non-infectious disease progress note and another point showed itself: almost every note I read, referenced either reviewing the last ID note or speaking with the ID provider on service that day. Their evaluation on any given day was sought out even if it did not change from the previous day(s). So, as in Part 1, I contacted the providers. Again, they all agreed to meet but, due to the volume of work they did, they asked to include the Department Chair so he could fill in any blanks and keep me focused on ID-specific issues.

The meeting was eye opening. First, I let my inferences guide the opening of the meeting. If the damage to the patient was so massive, then perhaps smaller details existed to show the work these doctors and non-physician providers did. So I asked about how these providers dealt with labs. Turns out they almost lived in the laboratory; they relied on so many tests. The damage was so extensive that infection may not have been obvious on observation and the trauma to the skin went so deep the ID physicians needed lab tests to guide them every day. This is additional work and another argument when the claims are filed. Then came the biggest surprise, and the best details I may have overlooked if I had relied solely on the notes.

The providers started by telling me about how the deep bites, scratches, punches and open shearing wounds could cause infection in different ways, and even different infections. But these physicians were unfamiliar with many exotic animals and they had to make international calls to other countries’ zoos, biologists, veterinarians and animal experts to get help and advice treating this patient. These calls were made almost daily throughout the patient’s stay. But if information did not change, the providers only made a short notation in the progress note which could easily be overlooked.

Then, they took the photos and x-rays I brought with me and explained what they saw, what the photos meant, and how they drove their decisions at any given visit. They segregated specific labs and showed me what they looked for and why, in their medical judgment, so many had to be run. This was news indeed and the way the providers put it gave a detailed report I never could have arrived at without their assistance. As I mentioned earlier, other providers relied on their findings to determine how to proceed. This was also the case with the ID providers and they were in continuous contact with vascular surgery, orthopaedic surgery and especially reconstructive surgery and dermatology. The ID providers concluded by telling me that although the notes looked like maintenance-only treatment, because of the critical damage done to the patient/victim, they had to proceed with considerable caution because they were not the only specialty on this patient’s case. Every specialty had to make certain (as much as possible) that no other provider was negatively impacted by anything another provider did. This was an extreme learning experience for all of them.

Armed with this information, the only real difficulty I faced was putting the argument for payment together coherently and precisely. Every detail I could have wished for was in place. My manager allotted plenty of time but we were talking about nine months of claims for every day of the week. So my last possible hurdle was removed, thanks to a manager who wanted an accurate, complete audit. She reassigned my secondary duties to others on our team, even taking some herself. It was time to sprint to the finish line.

First, I printed a copy of the insurance company’s guidelines and where there were blanks (especially with inference) I pulled CMS guidelines. CMS allows inference if it can be clearly determined. This, coupled with the insurer’s statement that medical decision making of the provider will be given the most weight, made clinical medical necessity my focus rather than payor guidelines. As in Part 1, I still had to argue two types of medical necessity: why the doctors believed the patient needed treatment and did the treatments fall within the insurer’s guidelines.

Inference had shown me immediately that the damage and trauma to the patient was life-threatening. Inference from ID running so many labs was that the providers were either investigating something or making certain something was not showing up. Inferences from the documentation led me to know I had to get copies of all photos, x-rays and other very specialized procedures. When I did, the picture was so clear even a non-medically educated person could see this was an exceptional case. It also showed me how I needed to approach the most important medical necessity argument: why the providers did what they did, every day, every week, every month. With the information gained from meeting with the providers, every aspect of this specialty’s patient care became clear: the medical reasoning, the timing of procedures, everything. This is the value of inference and I never do an audit without it as a guideline.

The first was admittedly fairly easy. The risk of infection was so high that hour by hour oversight was critical to the ID providers and they not only had to prevent infection but they had to be ready to attack an infection from an exotic animal that the American medical field knew little about. Here is where I entered the evidence of so many international calls and constant consultations with other specialties involved. Then, I stated how after every surgery, and every surgery was major, the patient had to be cut open again. Next, came the extensive lab work and direct quotes from the meeting I had with the providers. Then, I tied it all together and made the photographs, x-rays, labs and other concurrent treatments separate exhibits. The photos especially were unnerving and separating them made them even more effective. Explaining what the doctors saw from the labs, x-rays, etc., and referencing them in a separate exhibit I believed also made them easier to find. This “pre-appeal” was going to be BIG. I completed my argument with information I gained at the meeting that I believed would be helpful.

Now for the codes. For the diagnoses, as with the examples in Part 1, they were not very specific and it could be assumed the payor would balk. I called the ID department chair back and asked him if he would be willing to have all of his staff involved (which was the entire department, as it turned out) review a few notes and give me some ideas. I had them within a couple of days. Since much of the treatment was prophylactic, meaning trying to keep infection from occurring, I reiterated the extent of the damage and specific statements made at our meeting. This showed the constant threat of infection and how, due to the mechanism of injury, it was not a well-known threat potential. I also used as many post-surgery and open wounds codes as I could because any area open to the air was a primary infection entrance point. Therefore, what might be misconstrued as maintenance was in fact treatment to stay on the offensive, prevent even the opportunity for infection to occur, and be ready to treat it immediately if any signs appeared.

Then came the procedure codes. This one was risky because I assigned every claim a 99233, the highest level allowed. Few additional procedures were done so my argument here was the elusive nature of the injuries and how difficult an infection could be to discover quickly. So many international calls to zoos, biologists and others; continuous consultations, even if informal, with other specialties to maintain a preventive stance on potential infections; and the need for so many labs to give an objective, data driven picture of the patient’s status. Again, I referenced the photo exhibits to give a very sharp picture to any reviewer that this patient was in dire straits and was constantly high risk for infection. Like one of the cases in Part 1 where I had a heated argument with a reviewer, I added a statement I would not necessarily recommend, but in special circumstances could be warranted. I closed this portion by stating it was unfortunate the highest the providers could bill was a 99233 because the work they did far exceeded any understanding of how the definition of this code was interpreted but, because of late filing, the ID department was willing to settle for this code alone. In addition, the department was willing to forego billing for the international phone calls (which is legal) for the same reason but, should the insurer balk, we reserved the right to appeal and these codes would be added for every call made. It was risky, but the case was so strong in my mind that I had to throw a final punch that I hoped would influence the claims in our favor.

I intentionally used the clinical-medical reasoning as my first argument. It was far and away the most important and it drove the codes I would recommend. In addition, it showed the patient and providers as people: a victim, and medical experts in their field with an extremely unique but serious injury on their hands. I do not recall the number of pages but I do know the file I sent to the payor was an inch thick. I made my Executive Report and met with my manager with the clear recommendation to proceed with claims submission. I further recommended, since the claims package was so large and required a physician knowledgeable in the finer details of my argument and results, that it be submitted directly to the insurer’s Medical Director. For the next three days it was raised along the flagpole. On the third day my manager told me every claim had been submitted. She told me that even she thought perhaps my requirement for everything going to the Medical Director was risky, because the medical reviewers and claims auditors might feel slighted and mistreat us in the future. At the same time, she saw the value of having another doctor have the first and last say in such high stakes (and high cost) medical treatments.

Shortly after, my manager received word that every claim had been submitted under the late filing guidelines at the insurer, meaning the claims were allowed similar to an appeal. All claims, arguments, statistics, reports, photos, results, etc., were allowed as one package. Every claim was accepted and reimbursement was promised.

I informed the Infectious Diseases Department and gave the chairman, as was his right, an electronic copy of my package for his review. Oddly, he called my director and requested a meeting just between him and I. My director called me directly, and I told my manager. She said, “Set it up.” Now, this is where I need to do some explaining. I also train healthcare auditors in quality assurance, or “why auditors need to be audited.” This chairman and I did not get along. I neither liked nor hated him but if I knew he was around, I avoided him. He saw my work as an irritation and if I reported any negative performance on his staff’s part he was sharp and fast in his critiques of my work. This could have caused a conflicting bias on my part, should I have been a QA or external auditor.

If I were auditing him or his staff, this argument would hold. However, I wore two hats in this organization. One was denials and appeals management; the role I was in here. The second was as an inpatient professional auditor, where I would audit the encounters of all departments including his. In my role here, it was imperative I believe in and trust the motivations and judgments of the providers. These providers had worked tirelessly and deserved every break allowable. Whether I liked an ID provider or not was absolutely irrelevant. Trusting them to act in the best interests of the patient was paramount. Being one person, yet both types of auditor, are not mutually exclusive. In this case, I was looking at the big picture rather than intricate technical details. I was looking at the good to the patient rather than data points and compliance to insurer guidelines which was secondary to why these providers acted and proceeded as they did. Auditing the providers for compliance is an ongoing process and should an insurer wish to challenge my audit based on this it is certainly their right. But in an appeal-type audit, I believe we shift focus from the technical physician to the wellbeing and survivability of the patient. Both can be done effectively as long as the auditor keeps these tenets firmly established in her or his behavior.

As it turned out, the chairman wanted to ask some details about the results and especially why I had the claims all submitted when the animal’s owner was being sued on multiple fronts and medical funds most likely had already run out. This is another priceless benefit of being an appeals auditor. I was able to tell the doctor that, as the funds ran out the lawsuit would inevitably go against the estate. He did not know this and promised he would forward the news to his staff. He thanked me for the work and told me he would be watching for the next audit rotation in his department, and we parted on good terms but quietly. Imagine my surprise when he requested my presence at another staff meeting. The chairman showed me to a seat up front and asked me to listen to the meeting.

I was not expecting the amount of information these providers had to take in at any given time and it became clear they wore a lot of hats. When they weren’t seeing patients in the office, they were seeing them in the hospital, or they were training new doctors, or they were getting documents ready for publication, or SOMETHING. Then, as the meeting closed the chairman told the group of our success with the animal attack victim and told the group they should thank me for my efforts. He also told them that in the future they needed to cooperate with me when they were audited and errors were found. I think every provider shook my hand before they left and I received congratulatory emails from them for the next few days.

A good auditor always learns and always strives to become better. With this one case, both the providers and I learned important new information. They learned that even if I audited them, I was trying to train them and improve their performance and was not an antagonist; I did have their best interests at heart. And I learned the doctors have an unbelievably difficult job and are constantly pulled in many directions; they deserve our respect. From that point on, if questions arose from an audit they met with me and we hammered out our differences to the point where Infectious Diseases became one of the most consistent, highest scoring auditee departments in the organization.

About the Author

Carl J Byron, CCS, CHA, CIFHA, CMDP, CPC, CRAS, ICDCTCM/PCS, OHCC and CPT/03 USAR FA (Ret)

Carl is an experienced professional and contracted auditor with the military. His background includes HCC auditing for CMS, coding and auditing for a large global healthcare network, and serving as a compliance educator and speaker for AIHC. He currently volunteers as a subject matter expert for AIHC, a non-profit licensing and certification partner with CMS.

Click here to learn about our Clinical Documentation Improvement course. For other courses and certifications, visit our Certifications Store: https://dev-main.aihc-assn.org/certifications/

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Auditing, Managing Denials Is Important to Good A/R Hygiene
Auditing

Chasing the Dragon

Appealing Medical Denials When the Problem is Elusive


Written by Carl J Byron, CCS, CHA, CIFHA, CMDP, CPC, CRAS, ICDCTCM/PCS, OHCC and CPT/03 USAR FA (Ret)


Picture a young patient in their early 20s who is transported to the hospital feeling sick with “just ain’t doing right” descriptions of their symptoms. Findings are inconclusive and equivocal  and the patient never stabilizes so they are admitted. Despite 24-hour care by multiple specialties, in just over a month the patient succumbs to the illness and dies. A full 35 claims were denied in their entirety.

My job was to audit all of the involved records and prepare an Auditor’s Executive Report on whether I believed these denials should be appealed. I called up the patient’s chart and did quick scans of every encounter to see of anything “popped out.” Nothing did; the patient never improved and many encounters were repeat labs, scans, etc., and no definitive diagnosis was ever reached. As I sat turning this patient’s stay over in my mind, I imagined a Chinese dragon, like in the drawing above, and thought “those doctors are really chasing the dragon on this one.” If you look at the picture, although in mythology the Chinese dragon was helpful and stood for good fortune, how would you ever catch it? Then my blueprint began to show itself. Just because they couldn’t catch the dragon, by no means meant they were doing nothing; they were chasing it.

The Social Security Act, Title XVIII, Section 1801 prohibition against federal interference specifically states “…Nothing in this title shall be construed to authorize any Federal officer or employee to exercise any supervision or control over the practice of medicine or the manner in which medical services are provided, or over the selection, tenure, or compensation of any officer or employee of any institution, agency, or person providing health services; or to exercise any supervision or control over the administration or operation of any such institution, agency, or person.” But the Act is for Medicare, right? Yes, but every insurer should have a limitation on interference in, or acceptance of, the trained and licensed doctor’s medical-clinical reasoning.

Sure enough, the payor did; it was almost a carbon copy of the Social Security Act’s. In addition, the insurer had a statement of understanding that they realized the patient may not get better or improve. As long as documentation showed regular attempts to find a cause and cure, they would pay the claims. I went back into the chart and started looking at exact wording from the providers and found they had been working around the clock on this patient and were communicating with each other in and out of the hospital suite and even regularly after hours. And then the aha moment presented itself. Because the illness was so elusive, the providers at many points went above and beyond all day, every day.

The next step was to contact all of the providers who saw the patient face to face, identify myself and my purpose, ask them to review all the records they could and recall what they did, and why. If they did not mind, when they were through I wanted to meet personally with them. To my surprise, every provider agreed to a one-on-one meeting. They went through everything from training to known exotic diseases to outreaches to external experts; which, even though only brief mentions, were documented. It quickly became clear, from the newest physician assistant to the most experienced MD, these people cared a lot and they exhausted every human means to attempt to identify this disease and beat it, only to have the illness be the victor. I discussed the disease (process) with them individually, and together we came up with a constellation of symptoms, each unique to the specialties working on the patient (although by the force of the illness, some overlapped). They were all uncomfortably unclear, even to the providers; but they were honest, truthful and as accurate as possible given the vague presentation of the problem(s).

What did I learn and how was it useful? There is an old Army axiom that goes: “Observe, Orient, Decide and Act” (The OODA Loop). My observations had shown me, that despite their best efforts and constant shifting of methods, the patient still died. I observed the disease never got a name; it was so lethal and so elusive even the International Classification of Diseases (ICD) Signs and Symptoms codes were of little value. But the providers constantly put forth effort; they never rested and they never stopped trying. Even when the patient did not improve, they put forth great effort and creativity; so what the payor termed “maintenance” was far from it and often small, subtle changes were made to maintenance regimens to see if any improvement could be achieved. So I “Oriented” the providers were practicing professional, top-of-the-line medicine and I “Decided” all 35 claims would be appealed as far as I could go. I “Acted” on it using the payor’s own rules. I used information gained from my personal meetings to fill in any potential gaps in documentation. Remember, if clinical logic and treatment can be clearly inferred, it needs to be allowed.

I addressed the critical aspect of medical necessity: why the providers had to treat the patient even if improvement was not forthcoming. I had their own clinical reasoning to support my argument. Now I had to address the “other” medical necessity: the diagnosis and procedure codes. This was a hefty challenge and a part of the dragon even I had to chase. This is where I reached out to colleagues near and far; and as far as confidentiality would let me, I looked for ideas. As you would expect, they came almost exclusively from Signs and Symptoms, with a common code being unconscious or unresponsive. I believed this would at least show any medical reviewer that the patient could neither verbalize nor show any physical manifestations of the providers’ work because of the elusive disease process and that the disease process was critical. But assigning as many Signs and Symptoms codes as I could, along with the unresponsive codes, the argument was made that the providers had little choice with procedure codes because there aren’t that many of them, so the insurer will see codes repeated extensively. I made certain to remind the insurance company there was no prohibition against them linking with the assigned diagnosis codes (the insurer’s go-to excuse not to pay: “medical necessity was not met”).

So the dragon escaped at the cost of the patient and my OODA Loop was complete; or was it? I still had to present the appeal to the payor. I chose to hammer through constant repetition, my first definition of medical necessity (completing the Observe, Orient, Decide and Act). The patient was terribly ill and at a point it was recognized the illness was lethal if no cure could be found. The doctors and other providers worked non-stop with each other, communication was constant, the best of every provider’s skills were brought to bear and they cared deeply for the patient as a human who trusted them with their care. Although I added some diagnosis codes, I left most the providers already assigned and I did not change any E&M codes - after my meetings, the doctors felt the levels were sufficient for what they were able to do given the entirety of each encounter’s circumstances. I submitted 35 separate appeals and identified independent and individual information for each, again, based on education from my one-on-one meetings. I stated how diagnosis codes were extremely difficult to choose and together we all coded as definitively as possible. I concluded stating the providers did care deeply; they treated the patient with the utmost medical care and respect and were exhausted physically and emotionally when the patient died. I asked my manager for approval to submit and she gave the green light.

Every encounter was denied again. I submitted my appeal again and each was again denied. After the second submission, the medical reviewer threatened to have us prosecuted for fraud and we got into a heated argument. Going nowhere, I demanded to speak with her superior and although unwilling at first, I told her if she was so sure we would be prosecuted what would be the harm? The Director himself called me three days later and asked me to fax him every piece of paper I had since I began the appeals. He called me later that day and apologized for his company representative’s belligerent attitude and promised the medical reviewer would be disciplined.

This case highlights several critical elements to appeals not usually taught in formal academic settings. First, and far away the most important, is BELIEVE IN YOUR PROVIDERS. Before I even looked at the first note, I knew they were worth my time however much might be needed. Second, the fact the patient fell victim to a mortal illness by no means meant the providers only “maintained” the patient. We must be ready to state what was done, noting small and large modifications in the treatments (there was no “plan” as such - the patient turned critical and unstable too fast). State things like this. Also, specifically point to extraordinary work. For example, if a doctor on 2nd shift calls a doctor from 1st shift to brainstorm. In short, no detail is too small.

Last, when you make the decision to fight an appeal, be ready to fight. The vast majority of payors are hyper-focused on cost containment. You are focused on just and financial recognition of your providers’ services, skills and time. Be ready to go the distance whatever the distance may be, even a higher court, especially with federal payors like Medicare. You would rather lose putting up a hard but fair fight than give in. I would never recommend arguing with a reviewer but if you believe in the case strongly enough, I would submit it is a viable option. Never stop at an argument with the first line reviewer; find a superior who has authority to override the decision, or threats, made by the reviewer. Intimidation is not an appeal denial; it is intimidation. You and your providers are guaranteed due process. Chances are decent that in the future you will not have the same difficulty in appeals with that insurer; you will have gained the payor’s respect and they will seek weaker, less determined and prepared appeals managers. You can even simultaneously contact your State’s Insurance Board. Almost every state has rules of conduct and rights of providers you can call on.

About the Author

Carl J Byron, CCS, CHA, CIFHA, CMDP, CPC, CRAS, ICDCTCM/PCS, OHCC and CPT/03 USAR FA (Ret)

Carl is an experienced professional and contracted auditor with the military. His background includes HCC auditing for CMS, coding and auditing for a large global healthcare network, and serving as a compliance educator and speaker for AIHC. He currently volunteers as a subject matter expert for AIHC, a non-profit licensing and certification partner with CMS.

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