Tuesday, December 18, 2012
On January 1 the American Medical Association (AMA) will change almost all the Current Procedural Technology (CPT) psychiatry service billing codes – the 908XX series of codes (see AMA Revises Mental Health CPT Billing Codes, Effective January 1, 2013 ). What should organizations expect? This change will bring a flurry of new clinical documentation standards to accompany the CPT codes, including these three “trickle down” demands:
Clinical documentation processes and workflows need to be updated
Organizational coding and compliance manuals need to be updated
Fiscal and clinical staff training needs to take place
The immediate threat for many organizations is not getting paid – correct coding is essential for getting paid by third party payers. But having the new, proper documentation in the clinical record will also protect you in the event of a future audit. And don’t think otherwise – this change in CPT codes will lead to more audits.
I see a need for renewed focus on the role clinical professionals play by recording the information payers require in clinical records. This information must support medical necessity and the rationale for code choice, so specific information must be included in the record for every consumer interaction. For example, clinical professional will have to understand that psychotherapy codes are now timed with more specificity than previous codes. They are expected to choose the code that most closely reflects the actual time spent with a client; 90832 and 90833 is a 30-minute code with a range of 16-37 minutes allowed; 90834 and 90836 is a 45-minutes code with a range of 38-52 minutes allowed; 90837 and 90838 is a 60-minute code with a range of 53 or more minutes.
While there are exceptions, based on my conversations with managers of provider organizations, I think many organizations are not prepared. The most common misperception is that the only change is assigning the new CPT code on the claim. If you are in this group, what can you do in short order to prepare? I see five action items:
Conduct an assessment of your current billing department – This assessment should address staffing levels, ensure continuing education on the coding changes, and review current medical record coding processes.
Identify areas that need improvement – Failure to adjust to the new coding will mean an immediate loss of money. The solution is to identify the trouble spots through a review of clinical documentation standards and the new workflows clinicians will use. Introduce and teach concurrent documentation to capture real-time and accurate data from the client.
Benchmark coding performance – Performance benchmarks, while always a good idea for many aspects of running a provider organization, are an important tool to help organizations identify baseline coding expectations or billing gaps, with concrete percentages, and to seek a reduction in coding errors.
Review all related policy and procedure manuals – Non-compliance is not an option. Review coding and compliance policies and procedures, and any relevant manuals to ensure compliance with the coding changes.
Start a record documentation improvement program – If your organization hasn’t taken the time to look over its record documentation program, now is the time to develop and improve that program, set goals, invest resources, ensure organization-wide buy-in, and continuously work on the improvements that really should be happening anyway.
The coding changes are coming. Managers can either take the upcoming changes as an opportunity to introduce, refine, and reinforce best practices in clinical documentation – or pay a steep price in lost revenue and audits recovery in 2013. These five steps will get your organization on the right track with the right pay for the new year.
Lisette Wright, M.A.
Senior Associate, OPEN MINDS
For another free resource, see: When Billing Medicare for Mental Health Services, Do CPT Codes Right all members
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