Curbside Consult with Dr. Jayne 9/29/14

As a CMIO, I often feel my attention is all over the place. I’m dealing with clinical documentation needs for various constituencies while trying to ensure compliance with a host of federal, state, and other quasi-regulatory standards bodies. I’m also trying to implement tools to measure patient, physician, and employee satisfaction while maintaining my sanity in what seems like an upside-down healthcare world.

Given that background, you can’t imagine the serendipity I found when Dr. Andy’s recent CMIO Rant coincided with my weekend project to review E&M coding.

Due to some discrepancies in coding volumes after a recent ambulatory EHR upgrade, our compliance officers asked for a thorough review of the system’s E&M calculation tools. There are quite a few nuances to how the system codes and we’ve also had some recent coding education outside of the EHR, so I wasn’t convinced we weren’t dealing with another variable.

Our system is flexible and allows physicians to choose either 1995 or 1997 guidelines for each encounter. What if the recent coding class had physicians making different choices than they did previously? What if they were scared by the gloom-and-doom predictions of a RAC audit and undervalued their documentation?

I had been sitting for several hours with my trusty-rusty paper coding review forms, scoring visit documentation based on the guidance from our coding and compliance team. Once a visit was scored, I compared the results to the EHR’s calculations. Our EHR breaks down its coding suggestions parallel to E&M guidelines, so it is fairly easy to compare the bullets it counted vs. what I counted on paper.

Fortunately, our system does not advise on the level of Medical Decision Making, but rather requires providers to select that coding component. I can’t imagine how controversial the review would be if the EHR was prompting it.

There’s so much going on with HIStalk I tend to get behind from time to time. When I couldn’t handle any more bullet-counting, I took a break to catch up on HIStalk Connect and HIStalk Practice. Imagine my delight when I found Dr. Andy’s response to the AMA’s comments on EHR design. His first counter-request for the AMA is for them to help us fight “regulations that require overly detailed physician documentation, like the CMS E&M coding guidelines, which really set a floor of complexity below which we cannot sink.”

I laughed out loud, as I do every time I receive an email from CMS advocating their brand of “administrative simplification,” which has to be the biggest oxymoron ever. Just that morsel would have been enough to make my day, but then he covered their seemingly contradictory request for EHRs to lower cognitive workload while requiring them to enable dozens more tasks than we ever handled on paper. “Massive cognitive workflow” were the words he chose. Having had a 40+ patient clinic day this week, I can attest to the massive nature of the volume of information I had to process to care for them.

Note that I didn’t say data. Data implies the information is in the EHR or another accessible system that I could theoretically review. The reality is that physicians have to handle information on a much broader scale – the patient’s history, family members’ version of the same events, stories about what the patient read on Google, the physical exam itself, in-office testing, and more – on top of the actual electronic data available. Add to that mountain of information the fact that we’re now caring for patients in the office that would have been cared for in the hospital five years ago and it would be easy to become buried.

Reflecting on this massive cognitive workload inspired my new and improved “guidelines” for E&M coding. I didn’t have enough time (or martini fixings) to flesh out the entire scheme, so let’s confine our thoughts to established patient office visits.

Traditional E&M coding poses five levels of service – 99211, 99212, 99213, 99214, and 99215. The value of the visit (and thus the payments) increase as the level of service increases. Typically 99211 and 99212 are not used to bill actually physician services, so I threw them out. Talk about administrative simplification – I just slashed the number of things I have to think about by 40 percent.

Looking at the rest of the codes and what you have to have to justify documentation in the traditional coding construct, I identified some sample visits that were reflective of the codes even by conservative standards. They fell into nice groupings based on the amount of information the physician had to interact with during the visit. I’m not just talking about information that one would have to review, but also information one might have to deliver. Out of ten charts reviewed for each level of coding, I had a 90-100 percent concordance when using the “information burden” scheme to value my efforts.

Here’s how it works.

99213 – Now called “Mild Information Burden”

• Patient has fewer than three issues he/she wants to be seen for today.
• Patient has been seen at fewer than three healthcare facilities/providers in the last three months.
• None of today’s issues will cause death or serious consequences if left untreated.
• Determination of proper treatment requires review of fewer than three data sources (EHR, clinical data warehouse, HIE, antibiogram, CDC bulletin, guidelines website, Sanford guide, discussion with colleague, etc.)
• Treatment requires fewer than three instructions, outside orders, or documents (patient education handouts, prescription, therapy order, referral, prior-auth, FMLA papers, etc.)
• Visit requires less than 15 minutes for documentation.

99214 – Now called “Moderate Information Burden”

• Patient has more than three issues he/she wants to be seen for today.
• Patient has been seen at three or more healthcare facilities/providers in the last three months.
• At least one of today’s issues will cause death or serious consequences if left untreated.
• Determination of proper treatment requires review of three or more data sources.
• Treatment requires three or more instructions, outside orders, or documents.
• Visit requires more than 15 minutes for completion, including documentation.

At this point, based on my “rules of three” and the two levels of coding, you could quit. However, neither category covers what I had to manage for several patients seen in this week’s clinic. I decided to reserve the highest coding level for those special circumstances, but in keeping with the rules of three:

99215 – Now called “Severe Information Burden”

• There are three or more non-office personnel in the exam room (patient, family members, children, interpreter, etc.)
• Patient has been seen by facilities/providers that are members of three or more ACOs.
• At least one of today’s issues will lead to hospitalization in the next three months.
• There are three or more possible ways to treat one of today’s issues, depending on the patient’s insurance status and/or ability to pay for non-covered services.
• More than three separate logins and passwords are required to access the data needed to care for the patient.
• Visit takes long enough that it requires cutting three or more subsequent appointments short in order to catch up.

Maybe it’s just me, but those rules would be much easier to follow than what we currently have. I’d rather use my cognitive skills to deliver quality care and build relationships with patients than to remember whether I’m supposed to be documenting by organ systems or body areas. What does “expanded problem focused” mean anyway? Or “detailed”? I like to think that all my visits are detailed, if not comprehensive. Current E&M coding turns those perfectly good words into something incomprehensible.

Give it a shot – pull a couple of visits and see whether my proposed coding system holds up under the stress of your clinic day.

Do you dream of a world without E&M coding? Email me.

Email Dr. Jayne.