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Your reimbursement will change dramatically when nationally uniform facility assessment criteria are implemented by Medicare, probably in January 2004, predicts Caral Edelberg, CPC, CCS-P, president of Medical Management Resources in Jacksonville, FL. "This will be huge news for the ED," she predicts.
At press time, the proposed guidelines were expected to be released this summer by the Dallas-based American Hospital Association and the American Health Information Management Association in Chicago. Once analyzed by the Centers for Medicare & Medicaid, there will be a comment period, followed by anticipated implementation in January, Edelberg predicts.
Expect to see a transition from the five-level evaluation and management (E/M) coding system (99281-99285), currently used for facility coding, to a three- level system based primarily on case examples for each level, says Edelberg. You will need to prepare for a financial impact analysis to determine how this new coding and payment system will affect your ED’s revenues, she advises.
The jury is out on whether your reimbursement will increase or decrease, but you can expect a significant change, she says. "Once the new guidelines are released, a field testing of the new criteria will be performed on previously coded records to determine whether the new criteria will increase or lower ED facility revenues for facility E/M levels," she explains.
To be sufficiently prepared for the transition, take these steps recommended by Edelberg:
• Collect data on the hospital distribution of ED nursing levels for discharged Medicare patients. "You will need to compare current facility distribution to the projected distribution with the new code levels," says Edelberg. "Then determine the financial impact."
• Determine the Medicare payment per patient for the existing facility nursing level distribution (currently billed with E/M levels 99281-85). "You will need to know the current payment per level to compare to the new payment per level, assuming it is changed," says Edelberg. "If not, many services will track to a new level, thus, a different payment amount."
• Have the hospital pull a sample of ED records to code with the new coding system once it’s introduced. Record the codes that originally were assigned so that the difference can be tracked, says Edelberg. "You’ll need to compare the historical coding utilizing existing criteria with the revised coding under new criteria to determine the impact," she says. This also will help you determine how ED nurses must document services to ensure they are identified for the correct code level, Edelberg adds.
• Form a committee with nursing, physician, coding, and business office representation to participate in identifying any problems that arise from the transition. Here are some examples of potential problems for each area:
For more information on the proposed new evaluation and management coding levels, contact:
• Caral Edelberg, CPC, CCS-P, President/CEO, Medical Management Resources, 8001 Belfort Parkway, Suite 200, Jacksonville, FL 32256. Telephone: (904) 296-0671. E-mail: firstname.lastname@example.org.