1. 2015 Compliance TrainingBilling Compliance Office Dermatology Staff Meeting 1/22/2015 BWH/BWPO Billing Compliance Office 801 Massachusetts Avenue, 5th Floor Boston Mass 02118 Phone 617-582-0090 & 617-582-0095 (fax)

2. Efficiency, Growth, Financial Performance Physician Billing Compliance • New Modifiers – X {EPSU} Modifiers • Copy and Paste

3. NEW MODIFIERS

4. New Modifiers • Not mandatory yet • Effective for Medicare only • Before applying 59 Modifier, make sure you are using the most appropriate choice

5. When to use the X {EPSU} Modifiers These modifiers define specific subsets of the -59 modifier. CMS will not stop recognizing the -59 modifier but notes that CPT instructions state that the -59 modifier should not be used when a more descriptive modifier is available. CMS will continue to recognize the -59 modifier in many instances but may selectively require a more specific –X {EPSU} modifier for billing certain codes at high risk for incorrect billing.

6. Copy and Paste • Always document the HPI based on the patient’s description that day-never copy it from a previous encounter • Only use the Review of Systems components that are relevant to that day’s encounter • Only use past medical, family and social history from a previous note if it is reviewed with the patient • Modify or delete template language when it does not apply to the visit that day • The individual performing the copy/paste function is responsible for the documentation regardless of who authored the original information

7. Risks • Inaccurate or outdated information may adversely affect patient treatment • With each copy/paste replication, notes are lengthened and errors accumulate • Inability to accurately support medical necessity or defend services for professional or technical billing • Inability to identify authors…..who thought what

8. Payors and Regulatory Agencies National Government Services (Medicare) Cloned documentation will be considered a misrepresentation of the medical necessity requirement for coverage of services due to lack of specific individual information for each unique patient. Identification of this type of documentation will lead to denial of services for lack of medical necessity and the recoupment of all overpayments made. OIG Medicare contractors have noted an increased frequency of medical records with identical documentation across services. We will review multiple E/M services for the same providers and beneficiaries to identify HER documentation practices associated with potential improper payments

9. Partners Health Care Health Information Services EHR Policy PH-140 Copy and pasting information that originated within the Partners electronic record is not recommended, as it could create redundant information. It should only be copy and pasted if it is critical that information be repeated in the current note and had a direct impact on patient care rendered during that encounter

10. Questions