AMERICAN OSTEOPATHIC ASSOCIATION

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AMERICAN OSTEOPATHIC ASSOCIATION

• 5010 Data Standard, ICD-10-CM/PSC, Osteopathic
  Manipulative Treatment and Medicare
• December 3, 2011
• DIVISION OF
• SOCIOECONOMIC AFFAIRS

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Socioeconomic Affairs Staff

• Yolanda Doss, MJ, RHIA,
• Director, Division of Socioeconomic Affairs
• Sandra Peter, MHA
• Assistant Director, Clinical Practice Outreach
• Michele Campbell, CPC,
• Coding Reimbursement Specialist
• Kavin Williams, CPC, CCP
• Health Reimbursement Policy Specialist

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Yolanda Doss, MJ, RHIA

• Responsibilities include
• Helping to secure reimbursement for osteopathic
  services
• Securing the acceptance of osteopathic
  credentials
• Addressing Medicare issues
• HIPAA compliance
• Fraud and Abuse

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Sandra Peters, MHA

• Responsibilities include
• Develop educational material on physician
  advocacy, manage care, quality and performance
  measures impacting osteopathic medicine
• Design and manage a set of member services to
  enhance their manage care interactions and to
  promote their opportunities to participate in
  manage care
• Provide update to the AOA leadership on health
  care trends particularly in the areas of pay for
  performance and physician profiling

5
Kavin T. Williams, CPC, CCP

• Responsibilities include
• Assists AOA members with reimbursement and health
  payment policies.
• Oversees and assists AOA members with coding and
  payment disputes with carriers.
• Oversees the AOA Coding and Reimbursement
  Advisory Panel.
• Represents the AOA at national reimbursement
  policy meetings.

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Are you ready for ICD 10 and the HIPAA 5010 Data
Standard?

• Objectives
• To educate physicians on the ICD 10 and HIPAA
  5010 implementation compliance dates
• To educate physicians on the  impact the new
  coding sets will have on the current
  reimbursement and coding structure
•  

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The Transition to HIPAA 5010

• Have you heard of the HIPAA 5010 Data Standard?
• Have you begun testing?
• Will you be ready for January 1, 2012?

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Background of HIPAA 5010 Data Standard

• The current version of the standards
  (4010/4010A1) are identified as lacking certain
  functionality for health care needs
• Version 5010 will accommodate the ICD 10 codes

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Mark Your Calendars

• Important dates for 5010 Implementation
• January 1, 2011-begin external testing of the
  5010 version for electronic claims
• December 31, 2011-to be at level II compliance
  external testing of the 5010 for electronic
  claims must be completed
• January 1, 2012 All electronic claims must use
  Version 5010. Version 4010 claims will no longer
  be accepted

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Getting Started

• Now is the time.
• Testing should be conducted both internally and
  externally with current business partners
• Internal testing of version 5010 should have been
  completed by December 31, 2010
• External should be completed by December 31, 2011

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Getting Started

• Testing early will allow you to identify any
  potential issues, and address them in advance
• As HIPAA covered entity, CMS has to ensure that
  its business processes, systems , policies and
  those of ist contractors, providers, health
  plans, etc. are compliant with HIPAA

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Pitfalls

• Lack of testing with your vendors, clearing
  houses, insurers to ensure that you can accept
  and send transactions is probably the top barrier
  to success
• Cost
• Timing (deadlines)

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Summarize

• Implementation date to be compliant for the 5010
  HIPAA Data transaction is January 1, 2012
• If you have not begun testing the time is NOW!!
• Contact your vendors to inquire/schedule your
  internal and external testing

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Vendor Model Letter

• Dear Vendor (Clearinghouse, EMR system, Medicare,
  private payers)
•  
• My (name of practice)________________ uses your
  ___________________ product/services, version
  ___________. As ICD-10-CM implementation
  approaches, we would like some information and
  clarification about your plans to upgrade your
  systems.
•  
• Specifically, we would like to know your plans
  for updating software to comply with HIPAA
  transactions.  Can you provide a timetable for
  the following.
•  
• When will you be installing upgrades and will
  there be a charge for this data?
•  
• Will my practice need additional hardware or
  support services to install the upgrade(s)?
•  
• Thank you in advance for complying with and your
  prompt attention to this request. 
•  
• Sincerely,
•  

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ICD-10-CM/PCS
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History

• The International Classification of Diseases,
  Tenth Revision, Clinical Modification (ICD-10-CM)
  is the United States' clinical modification to
  the World Health Organizations (WHO)
  International Classification of Diseases, Tenth
  Revision (ICD-10). ICD-10 was adopted by the
  World Health Assembly in 1990. Following the
  publication of ICD-10, a number of countries
  performed an analysis to determine if the WHO
  classification would meet their needs given the
  changes to the roles of ICD since the ninth
  revision.

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History

• The United States remains the only industrialized
  nation that has not yet implemented ICD-10 (or a
  clinical modification) for morbidity, meaning
  diseases or causes of illness typically coded in
  a healthcare facility. Since 1999, however, the
  US has used ICD-10 for mortality reporting the
  coding of death certificates (typically done by a
  vital statistics office, not the healthcare
  facility). Implementing ICD-10-CM will maintain
  data comparability internationally and between
  mortality and morbidity data in the U.S.

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Development

• In 1994 under the leadership of the National
  Center for Health Statistics (NCHS), the United
  States began their process of determining whether
  an ICD-10 modification should be developed. NCHS
  awarded a contract to the Center for Health
  Policy Studies to decide if a clinical
  modification was necessary. A Technical Advisory
  Panel (TAP) was formed and their recommendation
  was to create a clinical modification. In 1997,
  the entire draft of the Tabular List of ICD-10-CM
  and the preliminary crosswalk between ICD-9-CM
  and ICD-10-CM were made available on the NCHS
  website for public comments. The public comment
  period ran from December 1997 through February
  1998. Since that time revisions were based on
  further study and the comments submitted. Draft
  versions of ICD-10-CM were made available in
  2002, 2007, 2009, 2010, and 2011. Limited code
  updates will continue to occur to this draft
  prior to implementation of ICD-10-CM.

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Development

• While ICD-10 provides many more categories for
  diseases and other health-related conditions than
  previous revisions, the clinical modifications
  thus far to ICD-10 offer a higher level of
  specificity by including separate codes for
  laterality and additional character and
  extensions for expanded detail. In addition,
  other changes included combining etiology and
  manifestations, poisoning and external cause, or
  diagnosis and symptoms into a single code.
  ICD-10-CM also provides code titles and language
  that complement accepted clinical practice.
  ICD-10-CM codes have the potential to reveal more
  about quality of care, so that data can be used
  in a more meaningful way to better understand
  complications, better design clinically robust
  algorithms and better track the outcomes of care.
  ICD-10-CM incorporates greater specificity and
  clinical detail to provide information for
  clinical decision making and outcome research.

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ICD 10

• Implementation date is October 1, 2013
• Benefits of ICD 10
• Have you started preparation for ICD 10?
• How do I get started?
• How do I find the necessary resource information?

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Benefits of ICD 10

• The Benefits of ICD-10-CM
• ICD-10-CM incorporates much greater clinical
  detail and specificity than ICD-9-CM. Terminology
  and disease classification have been updated to
  be consistent with current clinical practice. The
  modern classification system will provide much
  better data needed for
• Measuring the quality, safety, and efficacy of
  care
• Reducing the need for attachments to explain the
  patients condition
• Designing payment systems and processing claims
  for reimbursement
• Conducting research, epidemiological studies,
  and clinical trials

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Benefits of ICD 10

• Setting health policy
• Operational and strategic planning
• Designing health care delivery systems
• Monitoring resource utilization
• Improving clinical, financial, and
  administrative performance
• Preventing and detecting health care fraud and
  abuse and
• Tracking public health and risks.
• Non-specific codes still exist for use when the
  medical record documentation does not support a
  more specific code

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ICD 9 vs ICD 10

• Here are some SIMILARITIES AND DIFFERENCES
  BETWEEN THE TWO CODING SYSTEMS
• ICD-10-CM uses 37 alpha and numeric digits and
  full code titles, but the format is very much the
  same as ICD-9-CM (e.g., ICD-10-CM has the same
  hierarchical structure as ICD-9-CM).
• The 7th character in ICD-10-CM is used in several
  chapters (e.g., the Obstetrics, Injury,
  Musculoskeletal, and External Cause chapters). It
  has a different meaning depending on the section
  where it is being used (e.g., in the Injury and
  External Cause sections, the 7th character
  classifies an initial encounter, subsequent
  encounter, or sequelae (late effect)).

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Similarities Differences contd

• Primarily, changes in ICD-10-CM are in its
  organization and structure, code composition and
  level of detail

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ICD-9-CM

• 35 digits
• First digit is alpha (E or V) or numeric (alpha
  characters are not case sensitive)
• Digits 25 are numeric and
• Decimal is used after third character.
• Examples
• 496 Chronic airway obstruction, not elsewhere
  classified (NEC)
• 511.9 Unspecified pleural effusion and
• V02.61 Hepatitis B carrier.

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ICD-10-CM

• 37 digits
• Digit 1 is alpha Digit 2 is numeric
• Digits 37 are alpha or numeric (alpha
  characters are not case sensitive) and
• Decimal is used after third character.
• Examples
• A78 Q fever
• A69.21 Meningitis due to Lyme disease and
• S52.131A Displaced fracture of neck of right
  radius, initial encounter for closed fracture.

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What will change?

• Coding
• Code set will increase from 17,000 to 140,000
  therefore the code books and styles will
  completely change ( both ICD 10-Cm and ICD
  10-PCS)
• Clinical knowledge-Coders may need to be
  reeducated on anatomy and physiology
• All staff who handle coding, from the front
  office staff to the practice manager

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Additional Changes

• Laterality ( left, right, bilateral)
• For example
• C50.511- Malignant neoplasm of lower-outer
  quadrant of right female breast
• H16.013- Central corneal ulcer, bilateral
• L89.012- Pressure ulcer of right elbow, stage II

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Changes Contd

• Combination codes for certain conditions and
  common associated symptoms and manifestations
• Example
• K57.21-Diverticulitis of large intestine with
  perforation and abscess with bleeding
• E11.341- Type 2 diabetes mellitus with severe
  nonproliferative diabetic retinopathy with
  macular edema

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Changes Contd

• Combination codes for poisonings and their
  associated external cause
• Example
• T42.3x25-Poisoning by barbiturates, intentional
  self-harm, sequela. (The x character is used as
  a 5th character placeholder in certain 6
  character codes to allow for future expansion and
  to fill in other empty characters (e.g, character
  5 and/or 6) when a code that is less than 6
  characters in length requires a seventh character

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Changes Contd

• Example
• T45.1x5A-Adverse effect of calcium-channel
  blockers, initial encounter
• T15.02XD-Foreign body in cornea, left eye,
  subsequent encounter
• Inclusion of clinical concepts that do not exist
  currently in ICD-9-CM (e.g., underdosing, blood
  type, blood type, blood alcohol level)

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Changes contd

• Example
• T45.526D-Underdosing of antithrombotic drugs,
  subsequent encounter
• Z67.40-Blood alcohol level of 120-199 mg/100mL
• Expansion of codes
• Example-E10.610-Type 1 diabetes mellitus with
  diabetic neuropathic arthropathy

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Other changes in ICD 10

• Injuries are grouped by anatomical site as
  opposed to type of injury
• Category restructuring and code reorganization
  have occurred in a number of ICD-10-CM chapters
  resulting in the classification of certain
  diseases and disorders that are different from
  ICD -9-CM

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Other changes contd

• Certain diseases have been reclassified to
  different chapters or sections in order to
  reflect current medical knowledge
• New code definitions
• Example-Acute Myocardial Infarction is now 4
  weeks rather than 8 weeks
• ICD-9-CM V codes (factors influencing health
  status and contact with health services) and E
  codes( External Causes of Injury and Poisoning)
  are incorporated in the main classification as
  opposed to being separated into supplementary
  classifications as they do currently in ICD-9-CM

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Documentation Is the Center Piece for Successful
Reporting of ICD-10 Diagnosis Codes
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Why get started now

• Due to the potential significant financial and
  clinical impact ICD-10 and the changes required
  for transition to the information systems that
  are being mandated, physicians should be taking
  steps now to understand how to successfully
  prepare for ICD-10

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ICD-10

• Coding and billing systems will need to be
  updated to support the new code set
• Currently the code set has 3-5 digits and ICD-10
  will increase to 5-7 digits
• Documentation will be impacted severely which
  will cause a domino effect from productivity to
  increased claims delays

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Steps to take to get started

• 2. Understand the potential impact this will
  have on physicians practice
• Financial How much will this transition cost a
  practice (training, software, etc)
• Productivity How significant will this be for a
  practices bottom line and for how long?
• Education-what is needed and for whom is it
  needed (coders, billers, front office staff, lab
  personnel, etc)

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Quiz

• True or false? V and E codes are supplemental
  classifications in ICD-10-CM.
• True or false? In ICD-10-CM, injuries are
  grouped by anatomical site rather than injury
  category.
• What is the maximum number of characters in
  ICD-10-CM?
• How many chapters does ICD-10-CM contain?
• True or false? The first modification to ICD-10
  was published in 2001
• True or false? The final rule, published in the
  Federal Register naming ICD-10-CM as a new
  medical code set standard to replace the ICD-9-CM
  diagnosis codes, sets October 1, 2013 as the
  implementation for ICD-10.
• True or false? ICD-10-CM uses extensions in some
  sections to identify an initial encounter,
  subsequent encounter or sequelae.
• Which letter of the alphabet is not utilized in
  ICD-10-CM?
• The first character of an ICD-10-CM code is
  always an alphabetic letter.

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Osteopathic Manipulative Treatment (OMT)

• Reporting of OMT Services
• E/M
• Modifier-25
• Documentation
• Compensatory Changes
• OMT Survey

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Osteopathic Manipulative Treatment (OMT)1-2 Body
Regions Involved
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Vignette

• A 25 yr. old female presents with right lower
  neck pain of two weeks duration. Somatic
  dysfunction of cervical and thoracic regions are
  identified on exam.

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Description of Pre-Service Work

• The physician determines which osteopathic
  techniques (eg, HVLA, Muscle energy,
  Counterstrain, articulatory, etc) would be most
  appropriate for this patient, in what order the
  affected body regions need to be treated and
  whether those body regions should be treated with
  specific segmental or general technique
  approaches. The physician explains the intended
  procedure to the patient, answers any preliminary
  questions, and obtains verbal consent for the
  OMT. The patient is placed in the appropriate
  potion on the treatment table for the initial
  technique and region(s) to be treated.

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Description of Intra-Service Work

• Patient is initially in the supine position on
  the treatment table. Motion restrictions of C6
  and C7 are isolated through palpation and treated
  using muscle energy technique. Dysfunctions of T1
  and T2 are treated using passive thrust (HVLA)
  technique. Patient position is changed as
  necessary for treatment of the individual somatic
  dysfunctions. Patient feedback and palpatory
  changes guide further technique application as
  appropriate.

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Description of Post-Service Work

• Post-care instructions related to the procedure
  are given, including side effects, treatment
  reactions, self-care, and follow-up. The
  procedure is documented in the medical record

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Osteopathic manipulative treatment (OMT) 9-10
body regions involved
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Vignette

• A 40 year old male presents with sub-occipital
  headache, and pain in the neck, upper and lower
  back, left shoulder and chest, and right ankle.
  He was involved in a rear-end MVA two weeks ago.
  X-rays in the ED were negative. He has been
  taking prescribed analgesic and muscle relaxant
  medications with minimal improvement. On
  examination, somatic dysfunction is identified at
  the occipitoatlantal, left glenohumeral and right
  tibiotalar joints, as well as the cervical,
  thoracic, costal, lumbar, sacral and pelvic
  regions.

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Description of Pre-Service Work

• The physician determines which osteopathic
  techniques (eg, HVLA, Muscle energy,
  Counterstrain, articulatory, etc) would be most
  appropriate for this patient, in what order the
  affected body regions need to be treated and
  whether those body regions should be treated with
  specific segmental or general technique
  approaches. The physician explains the intended
  procedure to the patient, answers any preliminary
  questions, and obtains verbal consent for the
  OMT. The patient is placed in the appropriate
  position on the treatment table for the initial
  technique and region(s) to be treated.

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Description of Intra-Service Work

• Patient is initially in the supine position on
  the treatment table. Motion restrictions of
  identified joints are isolated through palpation
  and treated using a variety of techniques as
  follows occipitoatlantal joint and sacrum are
  treated using muscle energy and counterstain
  techniques right glenohumeral joint and pelvis
  are treated with articulatory technique lumbar,
  thoracic, cervical and right ankle are treated
  with passive thrust (HVLA) technique costal
  dysfunctions are treated using muscle energy
  technique. Patient position is changed as
  necessary for treatment of the individual somatic
  dysfunctions. Patient feedback and palpatory
  changes guide selection of further technique
  application as appropriate.

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Description of Post-Service Work

• Post-care instructions related to the procedure
  are given, including side effects, treatment
  reactions, self-care, and follow-up. The
  procedure is documented in the medical record

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OMT RVUs

• 2011

• 2012

• 98925 0.45
• 98926 0.65
• 98927 0.87
• 98928 1.03
• 98929 1.19
• Conversion Factor 33.9764

• 98925 0.46
• 98926 0.71
• 98927 0.96
• 98928 1.21
• 98929 1.46
• Conversion Factor 24.6712

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Medicare
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The Objective is to Provide Informationon the
Following Topics

• Medicare 2012 Updates
• Evaluation Management
• Medicare Audits
• Recovery Audit Contractors (RAC)
• Incident To Services

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Medicare 2012 Updates

• Physician Fee Schedule is facing a 27.4 percent
  reduction
• Physician Quality Reporting Initiative (PQRI)
  Bonus Payment 2
• E-Prescribing Bonus Payment 2
• OMT Survey

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Physician Documentation

• This is critical to your reimbursement
• If it was not documented it did not happen
• Clear and Legible, words to document by
• Chief complaint (this is the driver to most
  insurance auditors)
• Familiarize yourself with your documentation
  style- is it 1995 guidelines that you follow or
  1997?

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Documentation Guidelines

• The medical record should be complete and
  legible.
• The documentation of each patient encounter
  should include
• reason for the encounter and relevant history,
  physical examination findings and prior
  diagnostic test results
• assessment, clinical impression or diagnosis
• plan for care

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Documentation Guidelines Cont.

• The patients progress, response to and changes
  in treatment, and revisions of diagnosis should
  be documented.
• The CPT and ICD-9-CM codes reported on the health
  insurance claim form or billing statement should
  be supported by the documentation in the medical
  record.
• Hospital visits should be included in the
  patients chart

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Evaluation Management (E/M) Coding

• Coding for office visits
• Modifier usage when billing an E/M with a
  procedure (OMT)
• Time Based Coding

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Chief Complaint (CC)

• The chief complaint is a concise statement
  describing the symptom, problem, condition,
  diagnosis, physician recommended return, or other
  factors that is the reason for the encounter,
  usually stated in the patients own words.
• Documentation Guidelines states that the medical
  record should clearly reflect the chief complaint

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Medical Necessity

• This area is not black/white
• There are numerous definitions of medical
  necessity
• Linking the appropriate diagnosis to the
  appropriate procedure to support the necessity of
  the procedure performed is critical.
• Medicare defines medical necessity as services or
  items reasonable and necessary for the diagnosis
  or treatment of illness or injury to improve the
  functioning of a malformed body member.

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Coding For Time

• When is it appropriate to code for time?
• What is the auditor looking for when they review
  a chart that was billed as time being the
  controlling factor?

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Tips For Verbiage When Billing For Time

• Example of correct documentation of time
• In your note it should read I spent 45 minutes
  with the patient and over 50 of that time was
  spent discussing
• Example of incorrect documentation of time
• I spent 45 minutes with the patient, discussed
  surgical options versus medical management.

63
How Would Code This Date of Service
64
What Is An Audit?

• An effective tool used by Medicare and other
  payors to recover monies lost to fraud and
  erroneous billings.

65
Why Audits Are Initiated?

• Suspicion (Billing Pattern)
• Outlier Physicians
• The Senior Patrol
• Whistleblowers
• Procedure Codes

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Who Are The Auditors?

• The Office of the Inspector General (OIG)
• Medicare
• The Department of Justice (DOJ)
• The Federal Bureau of Investigation (FBI)
• Carriers

67
Types of Audits

• Prepayment Audits
• Post-Payment Audits
• Statistical Sampling Method

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What Auditors Look For?

• Billing for services or supplies that were not
  provided.
• Billing for non-allowable or non-covered
  services.
• Altering claim forms to receive a higher payment
  amount.
• Unbundling claims.

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How To Respond To A Request For Documentation

• Reply to the audit notice in a timely fashion.
• Gather and submit Only the requested
  documentation.
• Be cooperative.
• You may want to conduct an internal audit.

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How to Respond to the Audit Findings

• If the findings are not favorable
• Attempt to discuss the findings with the
  reviewer.
• If necessary request redetermination.
• If necessary request a level one appeal.

71
Medicare Recovery AuditContractors (RACs)
71
72
RAC Legislation

• The RAC program was created by the Medicare
  Prescription Drug, Improvement, and Modernization
  Act of 2003 which pays incentive fees to
  third-party auditors that identify and correct
  improper payments paid to healthcare providers in
  fee-for-service Medicare.
• The Medicare Prescription Drug, Improvement, and
  Modernization Act of 2003 also requires permanent
  and nationwide RAC program by no later than 2010

72
73
The RAC Demonstration Project

• The RAC demonstration project took place of New
  York, Florida, and California.
• By 2010 the RAC covered all 50 states.

74
RAC Program Mission

• To detect and correct past improper payments,
• To implement actions that will prevent future
  improper payments.
• Providers can avoid submitting claims that dont
  comply with Medicare rules
• CMS can lower its error rate
• Taxpayers future Medicare beneficiaries are
  protected

74
75
The New RACs Are

• Diversified Collection Services, Inc. of
  Livermore, California, in Region A, initially
  working in Maine, New Hampshire, Vermont,
  Massachusetts, Rhode Island and New York.
• CGI Technologies and Solutions, Inc. of Fairfax,
  Virginia, in Region B, initially working in
  Michigan, Indiana and Minnesota.
• Connolly Consulting Associates, Inc. of Wilton,
  Connecticut, in Region C, initially working in
  South Carolina, Florida, Colorado and New Mexico.
  
• HealthDataInsights, Inc. of Las Vegas, Nevada, in
  Region D, initially working in Montana, Wyoming,
  North Dakota, South Dakota, Utah and Arizona.
• Additional states will be added to each
  RAC region in 2009

76
Minimize Provider Burden

• Limit the RAC look back period to three years
• Maximum look back date is October 1, 2007
• RACs will accept imaged medical records on CD/DVD
  
• Limit the number of medical record requests

76
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Medical Record Limit Example

• Outpatient Hospital
• 360,000 Medicare paid services in 2007
• Divided by 12 average 30,000 Medicare paid
  services per month
• x .01 300
• Limit 200 records/45 days (hit the max)

77
78
Summary of Medical Record Limits (for FY 2009)

• Inpatient Hospital, IRF, SNF, Hospice
• 10 of the average monthly Medicare claims (max
  200) per 45 days per NPI
• Other Part A Billers (HH)
• 1 of the average monthly Medicare episodes of
  care (max 200) per 45 days per NPI

78
79
Summary of Medical Record Limits (for FY 2009)
Continued

• Physicians (including podiatrists, chiropractors)
  
• Sole Practitioner 10 medical records per 45 days
  per NPI
• Partnership 2-5 individuals 20 medical records
  per 45 days per NPI
• Group 6-15 individuals 30 medical records per 45
  days per NPI
• Large Group 16 individuals 50 medical records
  per 45 days per NPI
• Other Part B Billers (DME, Lab, Outpatient
  hospitals)
• 1 of the average monthly Medicare services (max
  200) per NPI per 45 days

79
80
RAC Validation Contractor (RVC)

• CMS has contracted with Provider Resources, Inc.
  of Erie, PA, to work as the Recovery Audit
  Contractor (RAC) Validation Contractor.
• The RAC Validation Contractor (RVC) will work
  with CMS and the RAC to approve new issues the
  RACs want to pursue for improper payments, as
  well as perform accuracy reviews on a sample of
  randomly selected claims on which the RACs have
  already collected overpayment.
• The RVC is another tool CMS will use to provide
  additional oversight and ensure that the RACs are
  making accurate claim determinations in the
  permanent program.

81
For Additional Information on RAC

• http//www.cms.hhs.gov/MLNMattersArticles/download
  s/MM6125.pdf
• http//www.cms.hhs.gov/RAC/Downloads/RAC20Evaluat
  ion20Report.pdf
• http//www.cms.hhs.gov/rac/

82
Medicare Incident to Physician Services

• The OIG reviews Medicare services that are
  incident to physicians services to determine
  the qualifications and appropriateness of the
  staff who performed them.

83
Physician Defined

• The physician refers to physician or other
  practitioner (listed below), who are authorized
  to receive payment for services incident to his
  or her own services.
• physician assistants
• nurse practitioners
• clinical nurse specialist
• nurse midwife, and
• clinical psychologist

84
Professional Service

• A direct, personal, professional service which is
  rendered by the physician
• To meet the incident to guidelines, the
  physician must initiate the course of treatment,
  and
• Conduct subsequent physician services to show
  ongoing involvement

85
Coverage Requirements

• To be covered, service and supplies must be
• An integral, though incidental, part of the
  physicians or on-physician practitioners
  professional services
• Commonly furnished in a physicians office or
  clinic
• Furnished by the practitioner or auxiliary
  personnel under the physicians direct supervision

86
Supervision Requirements

• Direct physician supervision of auxiliary
  personnel is required.
• Auxiliary personnel
• any individual (employee, leased employee, or
  independent contractor) who is acting under the
  supervision of a physician
• Auxiliary personnel include nurses, medical
  assistants, technicians, etc.

87
Direct Supervision in the Office

• Physician must be present in the office suite
• Physician must be immediately available to assist
  if needed
• Does not require that the physician be in the
  same room

88
Direct Supervision in the Office Continued

• Scenarios that do not meet the direct supervision
  requirement
• Availability of a physician by telephone
• Physician presence somewhere in an institution

89
Documentation

• To support the use of the incident to provision,
  the documentation should clearly indicate
• Who performed the Incident to service
• The physicians presence in the office suite
  during
• the service/procedure

90
Division Website

• Go to www.do-online.org and sign onto DO-Online.
• First time users will need their AOA member
  number to sign up.
• On DO-Online, click on Practice Management for
  the division website.
• There is also a Division email address
  practicemanagement_at_osteopathic.org.

91
What the DO-Online Practice Management Website
has for You

• Billing and Coding
• E/M documentation
• ICD-9-CM code updates
• OMT information
• Legal
• Litigation fund
• Updates on class action suits

• CMS/Medicare
• Links to local carrier information
• Information on each CPT code
• Enrollment information
• CMS Medlearn
• CCI link
• Fee schedules, new and prior

92
What the DO-Online Practice Management Website
has for You

• Preventive health services
• Demonstration projects
• CERT- fraud and abuse information

• HIPPA
• Managed care
• Osteopathic Advocacy Resources

93
Division CME Seminars

• Conducted in conjunction with state associations
  and specialty colleges.
• Seminars available include Medicare Compliance,
  HIPAA Privacy Compliance, and Documentation
  Guidelines and Coding Reimbursement.
• Call Yolanda Doss, MJ, RHIA at 800-621-1773 ext.
  8187 or ydoss_at_osteopathic.org for info.

94
Contact Information

• Yolanda Doss 1-312-202-8187
• ydoss_at_osteopathic.org
• Sandra Peters 1-312-202-8088
• speters_at_osteopathic.org
• Kavin T. Williams, -312-202-8194
• kwilliams_at_osteopathic.org