Here is a follow-up article, to a prior blog post, that was reported by Karen Long of Part B News Practices that followed WPS carrier instructions to document extended history of present illness (HPI) with three or more chronic conditions when using the 95 E/M guidelines must retrain staff to follow the “four or more elements” requirement to avoid lost payments.
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If physicians choose to use the 97 guidelines, they can document the status of three chronic conditions but must record whether those conditions are improving, stable or declining, says David Zetter of Zetter Healthcare Management Consultants in Mechanicsburg, Pa.
As of April 19, WPS will no longer allow the use of the status of three chronic or inactive conditions in the HPI with the 95 guidelines, according to a March 22 email from the Medicare administrative contractor (MAC) for Iowa, Kansas, Missouri and Nebraska. WPS also is a legacy Part B carrier for Illinois, Michigan, Minnesota and Wisconsin.
Instead, physicians using the 95 guidelines will have to complete at least four of the eight elements of an HPI, Zetter says.
The change will make it more difficult to obtain the HPI elements for patients who do not have complaints, says Dianne Wilkinson, RHIT, a compliance auditor at West Tennessee Healthcare in Jackson, Tenn. Follow-up questions asking about disease maintenance wouldn’t make sense because the patient does not have a complaint.
The change will mean more documentation for physicians, who then will have less time to interact with patients, says Dr. Chris Tashjian of Ellsworth (Wis.) Medical Clinic, a family practice.
WPS no longer using CMS communication
WPS had allowed the status of three chronic conditions in the HPI using the 95 and 97 documentation guidelines based on a years-old CMS communication, the MAC states in the email. But because the comprehensive error rate testing (CERT) contractor does not “adjudicate documentation that way,” WPS made the change.
Neither WPS nor CMS responded to Part B News’ request for comment by press time.
Practices that have documentation templates – on paper or in their EHR systems – that are based on the acceptance of the status of three chronic conditions with the 95 guidelines will have to change those materials, Zetter adds.
- WPS Evaluation and Management (E/M) Coding Guide:www.wpsmedicare.com/j5macpartb/resources/provider_types/_files/em-coding-guide.pdf