As 2021 approaches and new E/M changes are being implemented, it’s time to prepare your practice and sign up for training. Contact RT Welter and sign up today to have these new policies under your belt before 2021.
Ginger Avery, CPC, CPMA, CRC, is the Coding and Compliance Manager at RT Welter & Associates, Inc. Below, she is providing fourteen operational extremities on how to plan ahead in order to be ready for these administrative changes!
The 2021 E/M code changes are set to deliver a powerful mix of updates to help streamline documentation practices and reduce administrative burden. Medical practices are encouraged to start planning now for operational and administrative workflow adjustments that will be a result of this momentous occasion.
1. Identify/Assign Project Lead. This transition will affect everyone in the organization including coders, billers, other non-clinical staff, clinical staff, and clinicians. A designated project lead will help assure your clinic is prepared to streamline processes before the changes take effect on January 1, 2021.
2. Make Time for Meetings. Schedule time for meetings to review the changes and address questions. Track goals and milestones during the transition process. Organizations are encouraged to recognize the significance of this event and prioritize time to prepare for changes.
3. Make a List of Necessary Changes. Forms, templates, and contracts need updated, electronic health records and practice management systems need upgraded, several experts will be noted.
4. Update Policies, Procedures, Practice Protocols & Compliance Plan. Policies, Procedures, Protocols should all be in alignment with the new guidelines.
5. Review Medical Malpractice Liability. Although the “counted” documentation requirements have lessened with the updates, clinicians are reminded to tell clear stories, documenting the clinically relevant details of each encounter. The new guidelines state that office visits include “a medically appropriate history and/or physical examination when performed.” Regardless of the changes, it is important to remember that the burden of proof lies within the documented details. Supportive documentation will help guard against fraud & abuse law infractions.
6. Assess Financial Impact. Guard against an unanticipated financial impact by understanding the rules in advance and performing a prospective payment analysis. Be prepared to adjust business practices depending on practice needs.
7. Check with EHR vendors. Check with EHR vendors to assure their systems are updated appropriately prior to Jan 1st.
8. Consider Coding Support. Establish strong coding/auditing resources and expertise early in the planning process.
9. Conduct Current Coding/Documentation Assessment. Review current documentation practices and system functionality to address specific areas of interest for education development. This small audit sample should be conducted by an outside auditing source to provide an unbiased evaluation with appropriate recommendations.
10. Provide Education. Educate clinicians appropriately about documentation that impacts medical decision making and how to become proficient with recognizing complexity in alignment with the new guidelines. The new guidelines provide definitions and descriptions that clarify many details that were previously left subject to interpretation. For example, an Undiagnosed new problem with uncertain prognosis is defined in the 2021 guidelines as, “A problem in the differential diagnosis that represents a condition likely to result in a high risk of morbidity without treatment. An example may be a lump in the breast.”
11. Conduct a Time Study. Have clinicians track the total time related to each patient encounter for the day to determine whether current processes are set to capture total encounter time appropriately.
12. Understand Employer and Payor Requirements. Employers or payors may still require documentation of additional information above and beyond the new E/M office visit coding guidelines. Careful evaluation of the flexibilities allowed under the new guidelines will ensure that the documentation satisfies any other obligations and requirements that they may be expected to fulfill within their contracts.
13. Consider How the New E/M Guidelines Impact Your Specialty. For example, pain management practices will use the new E/M guidelines for office visits, but they’ll need to stick to the current guidelines for codes such as subsequent hospital visit code 99232 and subsequent nursing facility code 99308, which were among the top 10 E/M visit codes for the specialty according to the latest Medicare Part B utilization data.
14. Download and study the materials the AMA has published. The guidance includes a new medical decision making (MDM) table, new coding guidelines for office visits and prolonged service codes and a detailed list of relevant definitions.