Medical Necessity

1. Medical Necessity Glenn Krauss, BBA, RHIA, CCS, CCS-P, CPUR, FCS, PCS, CCDS, C-CDI Manager Accretive Health

2. Medical Necessity • Medical Necessity • Fundamental to Medicine • Integral to Revenue Cycle • Basis for healthcare delivery transformation • Right care • Right time • Right reason • Right place • Right documentation

3. NEW PEPPER Target Areas

4. Two-Midnight Rule • “When a patient enters a hospital for a surgical procedure not on the inpatient only list, a diagnostic test, or any other treatment and the physician expects the beneficiary will require medically necessary [emphasis added] hospital services for 2 or more midnights (including inpatient and pre-admission outpatient time), the services are generally appropriate ...”

5. Two-Midnight Rule • “Documentation in the medical record must support a reasonable expectation of the need for the beneficiary to require a medically necessary stay lasting at least two midnights.” • The entire medical record may be reviewed to support or refute the reasonableness of the decision,but entries after the point of the admission order are only used in the context of interpreting what the physician knew and expected at the time of admission

6. Clinical Documentation Improvement Today Today Holistic Documentation What Why Where am I? Where am I going Complete and Accurate Medical Record Documentation Hospital Physician Patient • Principal Diagnosis • Secondary Diagnosis • Present on Admission • Query Process

7. Medical Necessity • What is Medically Necessary Care? • Care that needs to be provided during a stay at the hospital • Medically necessary for diagnosis & treatment (Social Security Act §1862(a)(1)(A)) • Documentation to establish medical necessity • Clinical status of the patient

8. Medical Necessity • Not just a “hospital thing” • Information used by Medicare is contained within the medical record documentation of history, examination and medical decision-making.

9. Medical Necessity • Medical necessity of E/M services is based on the following attributes of the service that affected the physician’s documented work: • Number, acuity and severity/duration of problems addressed through history, physical and medical decision-making. • The context of the encounter among all other services previously rendered for the same problem. • Complexity of documented comorbidities that clearly influenced physician work. • Physical scope encompassed by the problems (number of physical systems affected by the problems).

10. Physician Engagement Physician Engagement Getting physicians’ Attention Getting physicians’ Involved Getting physicians’ Committed

11. Physician Engagement • An engaged physician is directly proportional to the degree of satisfaction with his/her profession and specific situation • Engaging physicians • Improving their outlook and viewpoint on documentation • Query process • “Burden” vs. “Benefit”

12. Clinical Documentation Improvement • Expanded CDI Chart Review • Real documentation improvement opportunities • Severity of illness congruent with intensity of service • H & P-context of admission • Progress notes • Discharge summary • Documentation mutually beneficial • Services that are reasonable and necessary

13. CERT Resource • Documentation Improvement Opportunities abound • Read the report of findings WPS Medicare CERT Error Summary-1st QT 2014 • http://www.wpsmedicare.com/j5macparta/departments/cert/j5mac-1st-qtr-error-summary.shtml • http://www.wpsmedicare.com/j5macparta/departments/cert/j5nat-1st-qtr-error-summary.shtml • Identify your facility opportunities

14. Thank you. Questions?