Your longstanding but technically illegal habit of allowing non-physician staff to log into CMS’ web-based Provider Enrollment Chain and Ownership System (PECOS) using the physician’s username and password soon will become legal under a new surrogate program. But you must first learn to navigate the program’s multiple registration scenarios.

A physician or coder might be tempted to assign a higher level of service to a claim that uses one comment in a physician’s documentation for the history of present illness (HPI) and review of systems (ROS), but that practice can lead to denials.

Practices continue to struggle with whether one physician comment in his documentation can count in the HPI and ROS, as evidenced by a recent string on the Part B News listserv.

Fix the weaknesses you’ll inevitably find during a security risk analysis (SRA) to protect patient information, meet meaningful use and keep providers’ $18,000 bonuses.

Finding and mending faults when safeguarding protected health information (PHI) is required by measure 15 of CMS’ electronic health records (EHR) incentive program.

This chart shows the overall denial rates of seven observation codes, comparing the 2009 rate with the 2010 rate for each code. The numbers, based on the latest Medicare claims data available, do not reflect the new codes for subsequent observation care (99224-99226) since they were not introduced until 2011. Note: The seven codes included below were not replaced by any of the new observation codes in 2011, meaning they all still apply today.

How do you avoid E/M denials when using modifier 25 (Separately identifiable E/M service) and a surgical code? For example, is there a reason for denying claims billed as 99213 (Level 3 E/M, established patient) with modifier 25 and 20610 (Arthrocentesis, aspiration and/or injection; major joint or bursa)? CMS is denying our claims because the “new code edit guidelines are not met for the use of this modifier.” Is that right? How do you document the services so the claims get paid?

Those of you in Ohio and Kentucky received startling news from your Medicare administrative contractor (MAC) – Cigna Government Services (CGS) – last month that examination must always be documented on an established patient E/M note, regardless of the level.If CGS is your MAC and you receive an E/M denial for that reason, mount an appeal, experts say.

Avoid becoming a high-billing practice suspected of inappropriate level 4 and level 5 selection by conducting thorough internal audits of your E/M services. If you have an electronic health records (EHR) system, your physicians are especially prone to improper E/M billing.

Cloned E/M notes on electronic health records (EHR) are one of the top reasons you could be over-billing for E/M levels 4 and 5, and they put you at risk of losing payments in a review. EHR experts see that as a frequent cause of inaccurate and medically inappropriate E/M visit notes created by doctors with good intentions. Even worse, the vendors will frequently promote cloned notes as a product benefit.

Your providers’ $18,000 meaningful use bonuses could be at risk, even if you’ve conducted a security risk analysis (SRA) to comply with HIPAA. While you’re already required to follow security standards for electronic health information, an SRA asks providers to implement security updates and correct security deficiencies as needed.

A final rule implementing new penalties of up to $1.5 million per HIPAA violation could be issued as early as this month, so evaluate how well your practice keeps patient records safe from privacy and security breaches to protect your revenue.