WHAT YOU NEED TO KNOW/DO ABOUT RANSOMWARE

By Emilie DiChristina MBA, for PracticeFirst

In the NEWS…RANSOMWARE

Last week, approximately June 28, 2017, major organizations in Europe and the US were attacked by the “Petya” RANSOMWARE. In Pittsburg, Pennsylvania, Heritage Valley Health System were hot by this malware, impacting the safety and treatment of patients across their hospitals and health centers.

About 6 weeks ago everyone heard of the RANSOMWARE attack on the Erie County Medical Center Corporation, and of course on companies across the world.

Possibly the first RANSOMWARE attack in our immediate area, occurred in May 2016 impacting the public, mental and health departments of the Niagara County Health Departments?

SCARY STUFF

Whether you are a provider or a patient, having your records held hostage is scary. The risk of incorrect prescribing, delayed surgeries, unknown allergies and delayed test results and possibly completely lost records cannot be oversold.

Having your records possibly viewed by a hacker is scary. Although the medical information loss is worrisome, the loss of vital identifiers can also be frightening. Your DOB, SS, address, bank account information…shall we go on?

Even scarier, the inability to get the information back, explaining to the government why you were unable to secure your data, and possible law suits, penalties and the loss of trust.

GOVERNMENT?

Let’s review what you, as a covered entity are required to do regarding electronic data…

CMS requirements for Electronic Security for any “covered entity” which means anyone:

  • Any provider of medical or other health care services or supplies who transmits any health information in electronic form in connection with a transaction for which HHS has adopted a standard
  • Any individual or group plan that provides or pays the cost of health care (e.g., a health insurance issuer and the Medicare and Medicaid programs).
  • Health Care Clearinghouses – A public or private entity that processes another entity’s health care transactions from a standard format to a non-standard format, or vice-versa.

Why then, if healthcare providers are following the CMS Electronic Security Rules, are they falling victim to RANSOMWARE attacks, or in fact, any virus?

CMS/HIPAA General Rules of meeting the Security Standard includes the following safeguards:

ADMINISTRATIVE – Security Management Process – Assigned Security Responsibility – Workforce Security – Information Access Management – Security Awareness and Training – Security Incident Procedures – Contingency Plan – Evaluation – Business Associate Contracts and Other Arrangements

PHYSICAL – Facility Access Controls – Workstation Use – Workstation Security – Device and Media Controls

TECHNICAL SAFEGUARDS – Access Control – Audit Controls – Integrity – Person or Entity Authentication – Transmission Security

So therefore, if an organization has policies, procedures, and documentation requirements in place to meet the CMS requirements for electronic device and information security, viruses and RANSOMWARE should not be a problem…Right?

Unfortunately, there are 2 major issues (and a host of minor ones) that may put your organization at risk from either a violations of the EPHI security requirements of CMS, or of suffering a virus or RANSOMWARE attack.

THE THINGS THAT PUT YOUR ORGANIZATION AT RISK

The first MAJOR RISK is that we all use, or are, PEOPLE.

The 2017 Level 3 Healthcare Security Study conducted by HIMSS Analytics and sponsored by Level 3 Communications found that approximately 80% of surveyed health IT executives and professional report that employee security awareness is their greatest concern regarding healthcare data security.

In large organizations there are large numbers of people, from the big guns of the Administrators and Providers, extending to housekeeping, students, security and Business Associates.

These big entities have people writing HIPAA and E-Security policies, giving inservices, even auditing HiPAA and e-Security. The job of these “people” are specifically to insure that the rules of CMS are followed up to and including those regarding E-Security.

So, why have these big entities been hit by viruses and RANSOMWARE?

Unfortunately, the sheer volume of people in these organizations make security a real issue both in physical plant (how to prevent someone claiming slip and fall injury), ID theft (people stealing a patient’s demographic information), HIPAA violations (both inadvertent such as the lobby conversation and deliberate as in reviewing the info of a VIP patient), and of course in E-Security.

E-Security can also be the defining factor in the theft of patient information or HIPAA data breaches as well as malware and viruses entering your IT system. Just think how many people have personal phones or other devices such as IPADs, as well as institution provided electronic devices. How many Medical and Dental residents are coming into these places in July, each getting their own usernames, passwords, VPN access to all kinds of IT systems and programs?

People are the issue in small and medium sized healthcare businesses as well. In these situations, the problem may be too little people, with not enough expertise to handle IT concerns, or a feeling that as a small business neither CMS nor RANSOMWARE attackers will come after you.

Personnel working in smaller practices may use their personal electronic devices for work, or may, as with any business plug them into the workstation by USB. Further, people in smaller organizations often travel between offices, take home HIPAA material or electronic devices. Also, more often than not, you begin to think of staff as family members or you have family members working there so you cannot conceive of them doing something that could harm your practice.

When you see this screen in smaller organizations, it is likely that data from your PC can be migrated to the personal device, or from the personal device. This is a common sources of virus and malware transmission as well as HIPAA breaches and data theft!

 

Bottom line? Unless every person you hire, use as a Business Associate, allow to intern, shadow, contract, clean, etc. for you is completely honest, follows all the rules, never opens personal email or uses personal devices on your system, never uses open Wi-Fi, and always turns off their computer at least once per week (not logging off, turning off) to allow for patches, people put you at risk.

The Identity Theft Resource Center and CyberScout released a survey in 2017 that showed the leading causes of healthcare data breaches was employee error or negligence.

The second MAJOR RISK(s) would be a combo of time, money and fatigue.

The HIMSS Analytics survey listed competing priorities and budget concerns as the top barriers in adopting a comprehensive security program.

While budget concerns may limit the number of people we have monitoring employee behavior, the ability to afford full time IT support, or even whether or not you have purchased licenses for the newest operating systems, the competing priority and fatigue issues may be worse.

In every organization, your specific priority depends on your role in the organization. A CEO or CIO will have different priorities that a clinical provider who just wants to log on, complete a task and get the job done.

The smaller practice gets impact by monetary priority fairly significantly as they cannot always afford IT personnel or regular updates to computer programs, they are often the entities using older Operating Systems, and many do not even have a written compliance and E-Security plan, let alone constantly reminding staff about it. If you are working in a small practice, go to your Administrator or Principle MD and say, “Does our practice have E-security threat intelligence, sandboxing or DDoS mitigation in place?” and watch their eyes glaze over.

And fatigue – One major reality of health care is overall fatigue, mental and physical. It is as real as what we call ICU alarm fatigue – too many things beeping and we tune everything out and miss something important.

We have been bombarded with HIPAA training for about 2 decades. When E-Security was added, we were already so exhausted by HIPAA, we barely listened to the new training.

We have passwords and usernames for so many programs we do the unthinkable, that is to use the same passwords where allowed or to write everything down and stick it near our work station or on our phones, etc.

We also, although trying to remember to log out of programs, or even the PC we are using, often do not turn the actual PC off (the necessary patches and updates to prevent malware can take place when the PC is turned back on0. The reason most of us conveniently forget to turn off the PC is the delay we experience when turning the PC back on, the patches and updates can take quite a bit of time if the machine hadn’t been turned off recently.

We are also so focused on getting our jobs done that we forget the exact policy or process related to IT security, for example clicking on an attachment in an email you think is from a colleague, or accessing streaming sites for radio, music, YouTube, or worse, accessing your Facebook from your work computer.

And we allow people to plug their personal USB or USB driven devices into their work stations!! Making it easy for malware to get into our system and for ePHI or Demographic data to be transferred to the personal device!!!

The HIMSS Analytics study also listed clinical workflows, employee awareness and in-house expertise as top security program barriers.

As they say – brown stuff happens, and sometimes it hits the fan!

So, if you have limited time, limited money, conflicting priorities, your best bet to protect your organization against malware, viruses or RANSOMWARE, even in the smallest organization, is to have a thorough and effective E-Security program as required by CMS.

Sounds too simple? Think about this…

RANSOMWARE attacks, virus intrusions, malware all violate the major 3 tenets of HIPAA Security:

Confidentiality – EPHI is accessible only by authorized people and processes (obviously if your system is hacked… someone unauthorized may be looking

Integrity – EPHI is not altered or destroyed in an unauthorized manner (RANSOMWARE threatens to destroy your data, which would include patient records if you don’t pay up, and even if you don’t pay, some data may still be lost depending on how long ago you backed up data.

Availability – EPHI can be accessed as needed by an authorized person (When a virus or RANSOMWARE locks up your system, and no one can access patient records… well you get the drift).

SUMMARY

  1. Make sure you are following the regulations put forth by CMS, no matter how small your organization may be, and that you have the required policies, enforce those policies and audit staff performance under those policies. This may not stop RANSOMWARE or other malware but it can indeed mitigate some of the financial, penalty and risk fallout after the event.
  1. Updated the policies and procedures and have your people sign off on each of them or the entire manual, minimally yearly, when hired and if found to be doing something incorrect.
  2. Have a plan to work without your electronic medical records. How will you cancel patients, move patients, schedule patients? How will you treat those needing immediate care? How will you record your treatment, and then insure if gets updated into the full EMR later?
  3. Strictly enforce, and punish, use of personal devices, use of personal email, opening of streaming radio, YouTube, Facebook, and any email download without first putting through a virus check.
  1. Require all staff in small offices, offices where workstations are not shared, etc. to not only log off, but also shut down their PCs and workstations at the end of their work week so IT updates (if you have an active IT provider), operating system patches, and Anti-Virus and Malware program updates can be installed when the computer is turned on again at the beginning of the week.
  1. Make sure that all of your systems, EMR, medical equipment related, billing related, even things like Quickbooks, etc. are updated regularly.

 

 

 

 

BILLING UPDATES – JANUARY 2017

By Tammy Bartlett, Billing Manager

IRS INSURANCE COMPANY PAYMENT SUMMARY

PF will aggregate your IRS Form 1099’s through February 17th.  These forms (1099-Misc) represent all of the payments made to you during calendar year 2016.  The IRS matches the aggregate of all 1099’s to the appropriate line of your entity’s tax return, to make sure recipients properly report their income.  In addition, any interest paid on claims is separately reportable on IRS Form 1099-Int.  This information is also matched and it is critical to properly report this income on the correct line of your tax return to avoid IRS scrutiny for under reporting income.

By law, insurance carriers are required to mail them by January 31st.  However, our past experience indicates that they do not comply with the due date and therefore they are not all generally received until the third week in February.  At that time, we will send them to you by mail or through our courier service. If you have any questions, please feel free to contact us.

UNIVERA – IMPORTANT UPDATE REGARDING PRODUCTS

Univera Healthcare will offer Medicaid Managed Care, Child Health Plus and Health and Recovery Plan (HARP) to Erie County residents beginning in the summer of 2017, pending approval by the New York State Department of Health.

Per Univera, you will have an opportunity to provide services for these product lines under your existing Participating Provider Agreement. The reimbursement schedule will be available on the secure portion of their website on or around February 1, 2017 at: UniveraHealthcare.com/Provider

Univera will provide further administrative details and other important information prior to the date when these products will be offered in Erie County. Please direct questions to your Provider Relations representative directly, or call the Provider Relations department at 716-857-4647.

For Billing questions, please contact Tammy Bartlett at 716-348-3923 or tammyb@pracfirst.com

 

CODING CORNER… NOVEMBER 2016

By Betsy Priest, Coding Manager

As of Oct 1, 2016, updates to the ICD-10 codes were put in to effect.  Some areas that may be of interest to you are:

  • Code assignment/Clinical criteria – A diagnosis will be added when a provider states that a condition exists. It is no longer dependent on showing the clinical criteria that brings the Physician to that diagnosis.
  • Laterality – The laterality of any injury needs to be documented to assign a code. If one side is treated and no longer is an issue, then the documentation needs to change from bilateral to the side that is now affected (cataracts are a good example).
  • Pathologic Fractures – 7th character A is for when the patient is receiving active treatment – not whether the provider has seen the patient before. 7th character D is for after the patient has completed active treatment.
  • Long Term use of Insulin – This needs to be documented so that it can be coded.

In addition to the above bullets, some diagnoses have been added, now requiring a 4th, 5th and 6th digit. It is important to look at any and all code lists that you use to ensure that they include all of the most up to date codes.

If you would like more information about how we can tailor our services to meet your needs, please contact Betsy Priest, Coding Manager at 716.348.3904 or Betsyp@pracfir

BILLING UPDATES – OCTOBER 2016

BLUE CROSS

Last month, our client memo indicated the new partnership between Blue Cross and Amerigroup for Medicaid Managed Care (MMC) and Child Health Plus (CHP) members. Blue Cross has indicated that the effective date has been delayed until November 1, 2016.

MEDICAID NEWS

On September 29th, the NYS Dept. of Health notified the provider community that NYS has redesigned the Common Benefit Identification Card for Medicaid beneficiaries. Cards with the new design will begin statewide in late September. An image of the new card is reflected below.

There will be no mass replacement of existing cards as a result of the new card design. Existing cards will remain active throughout the transition period.

Additional information on the new card design is located at:  www.otda.ny.gov/workingfamilies/ebt.asp

mEDICAID

HEALTH REPUBLIC UPDATE

As a first step in the claims adjudication process, a third party will conduct an independent audit of the existing inventory of policy claims. Based on the audit results, Explanation of Benefits (EOB’s) will be issued for each policy claim to providers.

The EOB’s will advise providers of the amounts of their respective claims against the estate and their rights. It is anticipated that EOB’s will begin to be mailed to providers in the first quarter of 2017.

If a provider accepts the EOB, they are not required to take any further action. If a Provider disagrees with the EOB, they will have the opportunity to appeal the determination through Health Republic’s website or by paper to the address indicated in the Claims Adjudication Procedure.

The written appeal and supporting documentation must be submitted within 60 days of the date of mailing of the EOB. The Liquidator will review each appeal and, within 60 days, either grant the appeal and issue a revised EOB or deny the appeal and provide the reasons for the denial.

It is anticipated that the total amount of allowed claims will not be known until at least mid-2017.

For additional information, please access Health Republic’s website at: www.healthrepublicny.org

For Billing questions, please contact Tammy Bartlett at 716-348-3923 or tammyb@pracfirst.com

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THE SMARTPHONE – POSSIBLE RISK TO YOUR PRACTICE?

By Emilie DiChristina for PracticeFirst

Almost everyone has a smartphone now, but even the old style flip phone can be a risk to your practice.

Patient phones can present a HIPAA problem, a customer service nightmare and a medico-legal/malpractice issue. This shouldn’t be a surprise to you, but may be overlooked due to the ubiquitous nature of the technology. We are used to seeing a cell phone in everyone’s hand, no big deal right?

It can be a big deal from a medico-legal standpoint as the presence of a cell phone in the examination room can mean:

  • Your interaction, or your staff member’s interaction is being recorded – even if the phone is not out in the open, it may be recording the conversation. This could be a positive in that the patient is hoping to not miss any vital instruction. It could also be a negative in that any interaction the patient is unhappy with can wind up on social media, or in the hands of a lawyer.
  • When a second person is in the exam room with the patient, they may appear to be playing a game on this phone but may instead by video- taping the interaction. Now you have the same issues of the interaction ending up on social media, or in the hands of a lawyer, or being a civil rights/HIPAA violation.
  • Also, whether it is an old style flip phone or smart phone, pictures can be taken of charts, records, dirt in the corner of an exam room, over-flowing sharps containers…you get where this is going.

Staff and provider phones can also present HIPAA, customer service and medico-legal/malpractice issues as well as Human Resource issues.

  • Customer service can be impacted when employees or providers are perceived as being too involved with their phones. You may be looking up a PDR notation, but to the patient, you are not looking at them. When phones are seen on the desks of staff, patients will assume the worst as well.
  • Of course, recording or video-taping can also be an issue with employees. There are many stories of HIPAA violations when employees have taken pics of a special tattoo, or piercing and posted them on social media for example. Staff can also take a pic of a patient demographic sheet or computer screen as well, allowing PHI or ID information to leave the practice quit easily.
  • Other examples of HIPAA risk include providers and staff texting any information about a patient without using proper encryption software, losing a phone that has any PHI on it, and…
  • An often forgotten risk – the employee plugging their phone into a computer via USB to recharge. Unless your computers are hardened against intrusion, when the phone is plugged in, it becomes a storage device potentially allowing the download of PHI or ID information such as Social Security #’s, DOB, addresses, etc. directly on to the phone. One requirement of HIPAA/OCR is that you have a plan in place to prevent this because the risk is so significant.
  • For people with access to the financial records of the practice or providers, downloading this data to the phone can be a nice safeguard for potential termination.
  • When phones (and other devices) are plugged into computers used for patient care or practice issues there is also the risk of a virus or malware transferring into the computer and/or network. If insurers and governments can get hacked or be held hostage to data breach, your practice is at risk as well.

And there are HR risks as well. Allowing your staff to have a cell phone readily available to them during hours of operation reduces productivity. Practice costs are high enough, but hearing there is not enough time for your staff to get their work done, when you have seen them with their phone in hand should trigger an alert.

Human resources professionals often recommend that employee phones not be allowed in personnel meetings whether it is a positive or negative meeting. You may be aware of the trend for employees to post reviews of former employers, but if they have audio or video to go with their claims, the problems rises to a recruitment nightmare and possible Labor Board investigation should the recorded meeting be juicy enough.

So what do you do?

  • All phones that are used for texting/emailing PHI need to be owned by the practice, be password protected, be able to be wiped immediately if lost or stolen, and should use proper encryption software. These phones should also not be used for personal purposes by staff.
  • Non-provider staff members should not be allowed to use their personal phones at that work station, nor should they be carrying them on their person (e.g. keep them in locker or purse), and use should; be restricted to break time only, and only in a non-patient care area like a break room. Staff members should also be prohibited from charging their personal devices on a practice computer.
  • Providers using their phones in front of patients should explain why/what they are doing so the patient understands that they are not being ignored.
  • Practices should consider requesting that no cell phones be used in examination rooms, even by an accompanying visitor. To make this more palatable, it should be explained that the medical experience is improved when all parties are paying attention to the patient.<

BILLING UPDATES – AUGUST 2016

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COMPLIANCE UPDATES – APRIL 2016

OCR LAUNCHES PHASE 2 OF HIPAA AUDIT PROGRAM

As part of its continued efforts to assess compliance with the HIPAA Privacy, Security and Breach Notification Rules, the HHS Office for Civil Rights (OCR) has begun its next phase of audits of covered entities and their business associates.

The audit process begins with verification of an entity’s address and contact information. This is handled through an e-mail sent to covered entities (CE) and business associates (BA) requesting that their contact information be provided to OCR in a timely manner. Once verification has been received, a pre-audit questionnaire will be transmitted to gather data from the CE. OCR will ask that the covered entity identify their business associates. They are encouraging covered entities to prepare a list of each business associate with their contact information, so they are able to respond to this request. The data that is gathered will be used along with other information to create a potential audit subject pool.

If a CE or BA does not respond to OCR’s request for verification or their pre-audit questionnaire, OCR will use publically available information about the entity to create its audit subject pool. Therefore, if no response is received, the entity may still be selected for an audit or be subjected to a compliance review.

Please check your junk or spam e-mail for any e-mails from OCR. As your business associate, please notify Becky Amann at Practicefirst, should you receive any e-mails from the OCR regarding a Phase 2 audit. This will allow us to watch for any e-mails from OCR as well.

Additional information regarding Phase 2 of the HIPAA Audit Program is available at: http://www.hhs.gov/hipaa/for-professionals/compliance-enforcement/audit/index.html

For Compliance questions, please contact Becky Amann at 716-348-3902 or beckya@pracfirst.com

BILLING UPDATES – APRIL 2016

By Jacqueline Lucas, Billing Manager

MANDATORY ELECTRONIC PRESCRIBING BECAME EFFECTIVE March 27, 2016

As you know, effective March 27, 2016, electronic prescribing for both controlled and non-controlled substances is now required in New York State. In order to process Electronic Prescriptions for Controlled Substances (EPCS), a prescriber must have selected and be utilizing a certified electronic prescribing computer application that meets all federal requirements. This application had to be registered by the practitioner with the NYS Dept. of Health, Bureau of Narcotic Enforcement (BNE).

UNITED HEALTHCARE (UHC) COMMUNITY PLAN – HARP

Beginning July 1, 2016 UHC Community Plan will start offering a Health and Recovery Plan (HARP). This is a new Medicaid plan benefit for members with significant behavioral health needs.  Any provider that is currently participating in UHC Community Plan will automatically participate in the HARP plan.  However, if you wish to opt out of HARP you must notify UHC in writing by April 15, 2016. The mailing address is:

UnitedHealthcare PCDM
PCDM Fulfillment
780 Shiloh Rd
Plano TX 75074

If you have any questions regarding this new plan, please contact UHC at 866-362-3368

GENERAL COMMENTS

In the near future, I will reach out to you for a convenient time to meet with physicians and your office staff.  My goal is to enhance our current processes to ensure we provide the most comprehensive billing service for all.  Please feel free to contact me prior to our meeting for any questions you may have. I look forward to meeting you in person.

Jackie Lucas

For Billing questions, please contact Jackie Lucas at 716-348-3923 or jackiel@pracfirst.com.

HEALTH REPUBLIC UPDATE

As you know, Health Republic ceased operations effective November 30, 2015. Claims processing and payments ceased in early November.  Due to the non-payment of claims, we have adjusted the outstanding balances owed by Health Republic from your Accounts Receivable. We have a history of each unpaid encounter in case the government makes a determination to issue payments on these claims. The total amount of Health Republic adjustments will be reflected in your month-end reports for March.

If you would like information regarding these adjustments, please contact Becky Amann at 716-348-3902.

BILLING UPDATES FEBRUARY 2016

By Jacqueline Lucas, Medical Billing Director 

IRS INSURANCE COMPANY PAYMENT SUMMARY

PF will aggregate your IRS Form 1099’s through February 15th.  These forms (1099-Misc) represent all of the payments made to you during calendar year 2015.  The IRS matches the aggregate of all 1099’s to the appropriate line of your entity’s tax return, to make sure recipients properly report their income.  In addition, any interest paid on claims is separately reportable on IRS Form 1099-Int.  This information is also matched and it is critical to properly report this income on the correct line of your tax return to avoid IRS scrutiny for under reporting income.

By law, insurance carriers are required to mail them by January 31st.  However, our past experience indicates that they do not comply with the due date and therefore they are not all generally received until the third week in February.  At that time, we will send them to you by mail or through our courier service. If you have any questions, please feel free to contact us.

INDEPENDENT HEALTH

To align with NYS Medicaid, Independent Health (IHA) will be eliminating coverage for immunization administration code 90461. This code is not covered by Medicaid. Effective April 1, 2016, 90461 will not be covered for IHA’s MediSource, Essential Benefit Plan or Child Health Plus members.

UNIVERA

Univera has announced that Telemedicine services will be available to select members effective March 1, 2016. Telemedicine services will be delivered by MDLive, a nation-wide network of physicians who are board-certified in the state in which the patient is located at the time of service. MDLive physicians will be available by phone or secure video 24 hours a day, seven days a week, including holidays to provide advice and/or treatment for non-emergency medical conditions. If you have any questions regarding Telemedicine services, please contact Univera’s Customer Care Dept. at 866-265-5983.

YOURCARE HEALTH PLAN

In-mid January, YourCare issued duplicate EFT payments. They have been identified in providers’ bank accounts beginning on January 19, 2016.  PF has contacted YourCare provider representative, Tina Burns, who indicated they will be reaching out to the various providers requesting a refund check, for the duplicate payments.

RAILROAD MEDICARE

Railroad Medicare’s Medical Review unit will begin a service-specific review of Evaluation and Management CPT Code 99214 (office or other outpatient visit of an established patient). This code was selected based on internal data analysis. At the conclusion of the review, they will publish their findings on their website.

For Billing questions, please contact Jackie Lucas at 716-348-3923 or jackiel@pracfirs

CODING CORNER… JANUARY 2016

By Betsy Priest, Coding Manager

2016 NEW, DELETED, AND REVISED CPT AND HCPCS CODES:

Revisions, addition and deletions to the CPT and HCPCS code set are effective January 1, 2016. Use of deleted codes will delay payment, as we will need to “Chart Return” the charge slips to your office for the correct code.

To determine which clients will be impacted by the 2016 changes, we have compared these changes to each client’s procedures performed in 2015.

We will be faxing, mailing or delivering customized reports to our Clients that are impacted by the 2016 CPT changes.

If you would like a complete listing of all the Deleted, New, and Revised Codes, we can provide that upon request.

DOCUMENTING TIME FOR E&M LEVELING:

During some visits you may spend a lot of time with a patient counseling them or coordinating their care.  If this happens, and you have the correct documentation in your note, leveling of your Evaluation and Management codes can be captured by time in lieu of the 3 main components.

It is a good tool for those patients that use a lot of your time, knowledge and resources and wind up with a very straight forward problem.

A good example of documentation needs for coding by time is: “This encounter was 30 minutes long and over half of that time was spent on counseling and coordination of care”.  You can also give a brief overview of what was discussed, if you would like.  But it will not be needed in this statement if the rest of your note supports that.

Your visit can be coded by time if the statement above is listed in the body of the note.  “This was a 45 minute visit” or “I spent 45 minutes with the patient” is not considered to be acceptable by the payers.

If you would like more information about how we can tailor our services to meet your needs, please contact Betsy Priest, Coding Manager at 716.348.3904 or Betsyp@pracfir