One of CBIZ KA Consulting Services’ clients was facing a perfect storm of compliance and revenue-related issues, as they were implementing a new electronic health record (EHR) at the same time as the significant changes to the 2021 E&M codes went into effect. This behavioral health organization believed that they could face a number of risks related to how their providers were utilizing their new EHR and applying the 2021 E&M standards, and they reached out to us.
Working with the chief compliance officer and the chief medical officer, CBIZ undertook a coding and billing review, and uncovered a number of issues that, if unchecked, could have led to significant issues with compliance and reimbursement.
In our review, CBIZ found several issues that needed immediate attention. A number of the templates in their new EHR were causing problems for their providers and clinical staff. This template issue led to sub-standard documentation. CBIZ also found substantial irregularities for specific time-based HCPCS codes that are billed in unit increments. In evaluating the units-billed issue in more depth, we found a pattern of over-coding, which could have led to potential compliance concerns.
Also in our review, we documented place-of-service issues and the incorrect utilization of modifiers. In addition, we found several E&M-related problems regarding the application of the 2021 regulations.
Presenting our findings to the client, we then agreed on several steps aimed at reducing compliance issues and improving clinical documentation and coding accuracy.
Perhaps most importantly, the organization worked with their EHR vendor to fix specific issues with their physician templates. Once these changes were made, we saw a reduction in EHR-related documentation issues.
We then incorporated targeted education programs to address the modifier discrepancies and the units-billed/time-based documentation issues. The education sessions led to an overall improvement in documentation and optimized revenue. We also instituted a training session for the new E&M regulations, which has helped with coding and documentation for outpatient visits.
We continue to work with the organization even after the initial engagement. The organization changed several protocols in their methadone clinic, leading to more consistent physician documentation. In addition, we are in the process of a clinical chart review to validate that the new E&M regulations continue to be implemented correctly.
Ultimately, CBIZ has helped identify and correct a number of potentially serious compliance-related issues for this organization. The net effect of our efforts has been a significant reduction in potential compliance risk. In addition, the organization, as a result of our findings, has fixed several serious issues with its electronic health record and has streamlined its documentation and billing practices for their healthcare providers, leading to more uniform and appropriate code assignment, and optimized revenue.
CBIZ works with many organizations in billing and coding compliance. We also have a number of educational and clinical solutions to assist with implementing the 2021 E&M regulations. For more information about our services, please contact Adam Abramowitz at 609-220-5627 or at email@example.com.
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