How ASCs Can Effectively Handle CMS Quality Reporting: Q&A With Allison Errickson of ProVation

Allison Errickson of ProVationAllison Errickson, CPC-H, director of coding compliance for ProVation Medical, part of Wolters Kluwer Health, discusses the biggest challenges for ambulatory surgery centers with quality reporting for The Centers for Medicare and Medicaid Services and what to watch for in the future.

Q: What are the biggest challenges ASCs face with the new Medicare quality reporting system?

Allison Errickson: I think one of the biggest challenges is the overall process change, not only for the nurses in terms of their documentation, but also for the coders and billers.

The quality reporting program requires ASCs to report five quality measures by submitting G-codes on the CMS-1500 claim form for Medicare patients. Documentation of the measures, which  include patient burn, patient fall, wrong site/wrong side/wrong patient/wrong procedure/wrong implant, hospital admission/transfer, and prophylactic IV antibiotic timing, will most likely be found in the nursing documentation. Coders/billers are not in the habit of waiting for nursing documentation to complete the coding for a patient encounter. So ASCs need to ensure the coders/billers receive a copy of the nursing documentation to ensure the appropriate G-codes are included on the bill. These G-codes need to be included on the bill for Medicare patients even if none of the events occurred.

Sites really need to have a designated person monitoring this program to ensure they are staying ahead of the game. The five measures I mentioned are just the first wave of this program. Starting in 2013, there will be two new measures sites will have to report; safe surgery checklist use in 2012 and volume of certain procedures in 2012.

The 2013 measures are a great example of why it's so important to have a designated person monitoring this program. Even though these two measures don't have to be reported until 2013, the data that sites will report on is from 2012. They will have to report if they used a safe surgery checklist in 2012 and the procedure volume will be based on 2012 numbers. Sites that haven't been tracking this information in 2012 may have trouble when it comes time to report this in 2013. If sites are unable to report on this information, they'll face financial penalties down the road.

Another challenge is that the guidelines are not always fully specified or may change as the program evolves. For example, in 2012, ASCs are supposed to report the G-codes on claims where Medicare is the primary payer. But, starting in January, they need to include these codes on claims where Medicare is primary or secondary. This may make it a bit trickier for sites when Medicare is the secondary payor. Its possible primary payors may reject the claim based on the G-codes.

Q: How well have surgery centers managed the change so far?


AE:
These measures have changed the workflow, which can be really difficult. There have absolutely been some growing pains with figuring out the most efficient way to get these codes on the bill and out the door to ensure accounts receivable aren't impacted.

What has been particularly helpful for many ASCs has been the information on the ASCA website about the changes. For example, they have a cheat sheet that gives clear and concise information about handling these claims. These types of resources are helpful reminders for coders and billers in particular.

Q: Are there any tricks for surgery centers to make sure they are submitting these claims correctly?


AE: It's really important for surgery centers to know that they have to code when something happens and also code if nothing happened. They must include a code no matter what.

Sites should ensure someone, most likely the coder or biller, is tasked with reviewing the remittance advice notices from CMS. This will help sites confirm if the G-codes were actually passed into the system. Data reports are incredibly useful as well. The threshold for reporting is 50 percent, meaning ASCs will not face the 2 percent payment reduction in 2014 if they successfully report the G-codes on 50 percent of their Medicare claims.

Q: What additional changes should ASCs be prepared for in the future?


AE: This is just one phase of the program. In 2013, we'll see the safe surgery checklist and procedure volume reporting. The mechanism they've been using to report the initial five measures will also change; starting in July of 2013, they will have to go to the CMS QualityNet website to report their total surgical care volume and use of a safe surgery checklist.

That means they have to have someone enter that information. Though ASCs don't have a lot of extra people sitting around with free time, having someone watching these measures will make sure they are on top of what is coming.

As of right now, reporting influenza vaccination coverage among healthcare professionals will be added as a measure in 2014 and most articles you read indicate that more requirements will be added in the following years.

For software platforms, the idea is that you are going to have to have the ability to report on these measures in some kind of electronic format. That is the best way to go, whether it's a product like ours or something else. You should be able to enter that information and pull a report based on data elements and not comb through handwritten nursing documentation. It's a big challenge for ASCs to handle.

More Articles on Surgery Centers:

10 Key Issues for ASCs

6 Tips on Managing Business Office Staff in an Ambulatory Surgery Center

6 Tips to Overcome Payor concerns With Spine surgery in ASCs


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