1 Don’t Let Data Become a Monkey Wrench to Your Outpatient CDI Efforts Laurie Benz, AS, CCS, CDIP, CPC Outpatient CDI Compliance and Education Manager AMN Healthcare Revenue Cycle Solutions Tampa, FL Christine Poleon Director, Business Analytics & Intelligence AMN Healthcare Revenue Cycle Solutions Tampa, FL 2 Learning Objectives At the completion of this educational activity, the learner will be able to: • Develop skills in analyzing commercial and Medicare data to benefit outpatient CDI • Discuss formulas for government and commercial payers to facilitate real‐ time data analysis • Discover how data can justify the creation of an outpatient CDI program 2019 Copyright, HCPro, a division of Simplify Compliance LLC. All rights reserved. These materials may not be copied without written permission.
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Don’t Let Data Become a Monkey Wrench to Your Outpatient CDI … 6_2019... · Data Analytics: Saboteur or Conservator? 4 Why Now? •Increase in outpatient services –Outpatient
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Don’t Let Data Become a Monkey Wrench to Your Outpatient CDI Efforts
2019 Copyright, HCPro, a division of Simplify Compliance LLC. All rights reserved. These materials may not be copied without written permission.
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Where to Find the Data: Step One
1. Step One ‐ Navigate to the CMS website: www.cms.gov
2. Step Two – Search for Hospital Outpatient PPS: Hospital Outpatient Prospective Payment System Rulemaking
3. Step Three – select 2019 NPRM OPPS Cost Statistics Files from the related links listed at the bottom of the page.
4. Step Four – Directs you to the following page: License for Use of Current Procedural Terminology. Click Accept: https://www.cms.gov/Medicare/Medicare‐Fee‐for‐Service‐Payment/HospitalOutpatientPPS/Addendum‐A‐and‐Addendum‐B‐Updates.html. Open or Save the zip file.
5. Step Five ‐ Save NPMR APC Cost Stats & NPRM CPT Cost Stats. You will pull national data totals from both.
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What to Do With It: Step Two
1. Add the total number of HCPCS per corresponding APC in the set
2. Divide each HCPCS/APC total into the set total that equals the % of total per HCPCS/APC
3. Apply the same formula using your facility data
4. Subtract % of MedPAR HCPCS from % of facility HCPCS
2019 Copyright, HCPro, a division of Simplify Compliance LLC. All rights reserved. These materials may not be copied without written permission.
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Example Using ED Visits
HCPCS APC Payment Rate National Visits National Observed Hospital A VisitsHospital A Benchmark Variance
2019 Copyright, HCPro, a division of Simplify Compliance LLC. All rights reserved. These materials may not be copied without written permission.
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Observation Conversion Analysis: Step Three
National OBS Conversion Rate Subject OBS Conversion Rate Conversion Variance Average OBS Payment Payment Variance
15.16% 8.68% ‐6.48% $2,348.33 ‐$701,480.51
$159,525.00 + $701,480.51 = “Cost” of the variance
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Observation to Inpatient Conversion Analysis: Step Four
# of Medicare Discharges # of Observation Claims OBS to IP
Assumption: MissedConversion Opportunity Average OBS Payment Payment Variance
2,497 417 14.3% 5% $9,551.00 ‐$1,78,785.45
$159,525.00 + $701,480.51 + $1,078,785.45 = “Cost” of the variance
$1,939,790.96
2019 Copyright, HCPro, a division of Simplify Compliance LLC. All rights reserved. These materials may not be copied without written permission.
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How? Data Analysis
• Where?
– Accounts receivable reports
• Denial/takeback report
• Evaluation and management report
• Payer report by CPT®/APC
– Electronic health record
• Diagnosis reports
– Purchased data from data analysis vendors
– Published CMS data
• https://data.cms.gov
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Denial Report
• Helps to identify significant trends and opportunities
– Zero pays, partial pays, takebacks
Invoice Number
Date of Service Total Charge
Provider Name Total Pay
Total Adjustments Balance Rejection Reason Cause
A100819 06/05/2019 $172.00 Dr. X $0.00 $172.00 $0.00 Inadequate/ Insufficient documentation Documentation
A757214 08/08/2018 $478.00 Dr. A $0.00 $478.00 $0.00Maximum number of hours days exceeded for this provider to be paid Coding
16050396 08/14/2018 $23.00 Dr D. $0.00 $23.00 $0.00 Procedure is inconsistent for place of service Coding
A888412 02/05/2019 $370.00 Dr. A $0.00 $370.00 $0.00 Timely filing limit expired Billing
A115421 06/05/2019 $172.00 Dr. X $0.00 $172.00 $0.00 Inadequate/ Insufficient documentation Documentation
A325987 02/26/2019 $275.00 Dr C. $0.00 $275.00 $0.00 Timely filing limit expired Billing
A685196 06/02/2019 $172.00 Dr. X $0.00 $172.00 $0.00 Inadequate/ Insufficient documentation Documentation
A785214 11/19/2018 $430.00 Dr D. $0.00 $430.00 $0.00 Inadequate/ Insufficient documentation Documentation
A652147 05/17/2018 $172.00 Dr. X $0.00 $172.00 $0.00 Inadequate/ Insufficient documentation Documentation
A345871 06/06/2019 $172.00 Dr. X $0.00 $172.00 $0.00 Inadequate/ Insufficient documentation Documentation
A258963 03/02/2019 $172.00 Dr. X $0.00 $172.00 $0.00 Inadequate/ Insufficient documentation Documentation
2019 Copyright, HCPro, a division of Simplify Compliance LLC. All rights reserved. These materials may not be copied without written permission.
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Identify the Root Cause
• In the case of Dr. X
– EHR template restrictions
– Incorrect template use
– Documentation gaps
– Template to charge mismatch
– Provider education opportunities
• Medical necessity = documented
clinical complexity
• Thoughts to paper
• Clinical considerations matter
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Evaluation and Management Data
National Bell Curve – Established Patient Family Medicine “Your Family Practice Data”
0
10
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30
40
50
60
99211 99212 99213 99214 99215
Family Practice
0
10
20
30
40
50
60
99211 99212 99213 99214 99215
Family Practice
2019 Copyright, HCPro, a division of Simplify Compliance LLC. All rights reserved. These materials may not be copied without written permission.
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Evaluation and Management Data (cont.)
• Identify outliers if they exist
– Perform a retrospective review on a reasonable percentage of outlier charts.
– Be sure to include a sample of charts for each provider.
– Validate medical necessity:
• Does your documentation meet medical necessity for the services provided to your patient based on the patient’s clinical picture at the time of the encounter?
• Does it reflect the true clinical picture of the patient and substantiate the reason for your assessment, treatment, and referrals?
– If the answer is yes to both of the questions above, there is no need to worry about recoupment. You can compliantly keep your money and rest assured that you are not a payer target.
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APC by Payer Data
APC Code Procedure Description
Total Medicare Payments
Total Number of Procedures
Average Payment per Procedure
Expected Payment Minus Coinsurance Variance Overall Loss
5491 Cataract removal with insertion of lens
$160,383 138 $1,162.00 $1,701 ($539) ($74,354.40)
– Review
– APC‐specific payer data for each chart in the sample
– Review documentation and diagnosis billed
– Identify gaps and root cause
– Remediate through collaboration with departments/providers involved
– Provide education as needed
2019 Copyright, HCPro, a division of Simplify Compliance LLC. All rights reserved. These materials may not be copied without written permission.
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CPT by Payer Data
CPT Code Procedure Description
Total Medicare Payments
Total Number of Procedures
Average PaymentPer Procedure
Expected Payment Minus Coinsurance Variance Overall Loss
20610 Drain/inj joint/bursa w/o us
$74,383 1,586 $35.00 $72.24 ($37) ($59,062.64)
– Review
– CPT‐specific payer data for each chart in the sample
– Review documentation and diagnosis billed
– Identify gaps and root cause
– Remediate through collaboration with departments/providers involved
– Provide education as needed
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The Patient’s Clinical Truth
• Diagnosis specificity
– Supports medical necessity for services provided and ordered
– Provides accurate diagnosis statistics to payers and national agencies
– Enriches evidence‐based medicine clinical outcomes
– Accurately reflects the complexity of a patient’s complete clinical picture
– Reflects accurate risk adjustment factors for your patient population
– Promotes patient safety
– Reduces healthcare costs
2019 Copyright, HCPro, a division of Simplify Compliance LLC. All rights reserved. These materials may not be copied without written permission.
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Diagnosis Data
• Diagnosis report reflects the most utilized diagnoses for your practice
– Identify opportunities based on lack of specificity related to uncaptured medical necessity
In order to receive your continuing education certificate(s) for this program, you must complete the online evaluation. The link can be found in the continuing education section of the program guide.
2019 Copyright, HCPro, a division of Simplify Compliance LLC. All rights reserved. These materials may not be copied without written permission.