Health Policy Committee Update
RUC Business
AANA and the AAOS presented three codes for revaluation at the May RUC meeting in Chicago. CMS had requested the revaluation as part of the Five Year Review. The Review is mandated to ensure that CPT codes that describe both E and M and procedures are “properly” valued. The codes under review were 29881: Arthroscopic Menisectomy, Medial OR Lateral, 29880: Arthroscopic Menisectomy Medial AND Lateral and 29826: Arthroscopic Acromioplasty. The three codes were all revalued by the RUC and their new RVU value will take effect in 2012. Because the deliberations of the RUC are confidential, I cannot describe how the codes will change for 2012 until the first newsletter of next year.
The RUC process is becoming more predictable making it somewhat less adversarial. There will, however, be continued initiatives by CMS to decrease the value of what we do. When we are asked to revalue codes we will need to send out RUC surveys to members for completion. It is essential that the surveys are completed accurately and completely to ensure that the RUC approves appropriate RVU levels for each code surveyed. There is a RUC Survey Primer on the Health Policy and Practice Community on the
AANA website for anyone who needs to learn about the survey process. It is imperative that all orthopaedic surgeons completing the surveys submit the proper time data elements for proper CPT code RVU valuation. If there are any questions concerning this process, please contact me at lfm@woapc.com.
AANA Website & the Health Policy and Practice Community of Practice (CoP)
The AANA website Community of Practice (CoP) is now functional and the Health Policy and Practice area has been initiated. The HPP CoP has all the past Coding Corner and HPP newsletter articles as well as a list of commonly used arthroscopic CPT codes, a primer on RUC survey completion, a primer on the essentials of E and M coding, a presentation on EMR for the private practice and information on hospital employment for the orthopaedic surgeon. A FAQ on common coding questions is in development. Also in development is a reporting mechanism for denials of payment based on any published treatment guidelines cited by insurance companies. Please visit the site and make recommendations for other information that could add value for AANA members.
Coding Corner
New Practical Procedures and Regulations
There are many “new” regulations that are important because the regulators have pledged increased attention to their compliance. Here are several examples:
1. NEVER use a signature stamp. Documentation for all items or services ordered MUST have a signature and the signature MUST be legible. Electronic signatures must be affixed by the person who provides the service (the provider must sign or e-sign). Signature must be present on the order at the time the claim is billed!!!!
2. “Change Request 6698” (a new regulation) mandates: Signature must be on all services order for CMS “contemporaneously with the time the service is provided.” So if your practice submits claims in 24 hours but you do not sign within that time frame you must change this practice or be at risk for:
a. Recoupment for overpayment
b. Prosecution based on “The Fraud Enforcement and Recovery Act of 2009” which amended the
False Claims Act
3. The Fraud Enforcement and Recovery Act of 2009 states:
a. Liability – if a party “knowingly conceals or knowingly and improperly avoids or decreases an obligation.”
b. Obligation – includes “an established duty, whether or not fixed, arising from… statute or regulation, or from the retention of any overpayment.”
The Health Information Portability and Accountability Act (1996) imposed compliant coding on all Medicare providers. So the expectation is that you are compliant and have been performing periodic reviews of your coding. If you haven’t there may be an issue. If you review your old charts and find over-billing then you are required by the above statute to repay the overpayment. Is there over-payment or under-documentation? It is imperative you seek advice from your healthcare attorney to determine a plan for moving forward! Get compliant and get educated. Good luck.