Access Feedback: New MSP time frame prompts reader question

Possible provider risk cited

Liz Kehrer, CHAM, system administrator for patient access at Centegra Health System in McHenry, IL, raises questions about the practicality of implementing a recent change to the Medicare Secondary Payer (MSP) rule.

In a program memorandum dated March 22, 2002, the Centers for Medicare & Medicaid Services (CMS) stated that the frequency with which providers must get an MSP questionnaire signed for reference laboratory accounts now is every 90 days.

Kehrer has suggested to her Centegra colleagues that the subject bears discussing, and welcomes feedback from Hospital Access Management readers.

"We don’t have a mechanism to know when the 90 days have expired and that the services the patient is receiving for the current visit apply to the MSP questionnaire on file," she points out. Kehrer gives as an example a patient who is having his blood checked every two weeks to measure levels of a drug that controls blood pressure.

"One month after the initial visit for the med-level check, the patient has a lab test to check a wound that is related to an injury," she continues. "The patient cut his leg at a store on a jagged shelf, and so liability insurance should be billed before Medicare."

The looser time frame for the MSP questionnaire, Kehrer says, could put the hospital at risk in such a situation. The result, she adds, could be a heavy fine for not having a valid MSP questionnaire for the wound-check specimen and penalties for fraudulent billing.

More on obtaining consents

Readers at two different hospitals offer feedback this month on obtaining consents, in response to a question in the April issue of Hospital Access Management from Jean Steinbrecker, admissions manager at Children’s Mercy Hospital in Kansas City, MO.

Particularly in the case of direct admits, where her facility’s young patients bypass admissions and go directly to the nursing floor, Steinbrecker noted, her staff have had trouble getting the consents signed. Parents are sometimes hard to reach, and the nurses don’t believe getting the form signed is their responsibility, she explained.

Ellen Cozart, director of patient financial services at Children’s Medical Center of Dallas, says she and admissions manager Suzette Rivera also faced the problem of consistently not getting consent forms signed, for the same reasons Steinbrecker mentioned.

"As part of a performance improvement project," Cozart adds, "we worked with the director of medical records to have the coders check for consent forms on each inpatient chart as it was coded. They did so, and also noted by floor which charts did not have consents. That helped us to narrow down where we had the greatest problems and gave us a base measurement [number of charts with no consents at the time of coding vs. total number of coded charts]."

In addition, Cozart explains, "we requested that the health unit coordinators on each unit review all charts upon arrival of the patient to see if there were a consent form in the chart." If no consent form is found, she adds, the coordinators call a "consent form hotline" set up to notify the admissions office daily of those patients needing consent.

"An admitting representative checks this voicemail box several times a day," Cozart says. "If a consent is needed, a patient access representative goes to the floor or locates the family for a signature. On some floors, the health unit coordinators have been trained to obtain consent and have [the form] signed by the parent, which is even more efficient."

"With this collaborative effort by medical records, nursing, and admissions, we consistently have less than 1% error rate," she says. "We continue to send out the statistics monthly by unit as a continuing performance measurement."

Shelly R. Seher, registration manager at Bryan LGH Medical Center in Lincoln, NE, says her hospital, which has 500-plus beds, also had a challenge with consent forms. "In the past, admissions staff had to go to the floor and obtain signatures on direct admits. We faced many of the same issues [Steinbrecker] did."

Her department’s solution, Seher notes, was as follows: "For those patients who bypass admissions, such as obstetrics patients or those who come by ambulance, we attach a notice to the front of the admission paperwork that requires nursing to collect the patient signature. 

"Medical records performed an audit to track compliance with the new procedure and provide feedback to the necessary managers. We had buy-in from nursing administration to help in this process since these patients bypassed the admissions area."

[Editor’s note: Please send feedback on these and other access issues to Lila Moore, editor, at or by calling (520) 299-8730. Liz Kehrer can be reached at Ellen Cozart can be reached at (214) 456-8804 and at]