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RE: [CCO-L] question regardaing billing based on counseling and/coordination of care time

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  • Quinten Buechner
    I m not sure I d bring that consultant back . S(he) hasn t read CPT very closely or well. CPT is very clear that time can t be used as a basis of documenting
    Message 1 of 5 , Feb 23, 2013
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      I'm not sure I'd bring that consultant back . S(he) hasn't read CPT very
      closely or well. CPT is very clear that time can't be used as a basis of
      documenting E&M when the E&M is done with Psychotherapy. Look at page 485 in
      the Professional version right column, last paragraph and the first
      paragraphs of the next column, paragraph number 3. Those who don't have a
      Professional edition should look at the initial introduction to
      Psychotherapy. How is your Doc who didn't want to do E&Ms doing with this
      change?



      Quinten A. Buechner, M.S., M.Div.,
      ACS-FP/GI/PEDS(BAMC), CPC(AAPC), CCP(PHIA), CMSC(PAHCS)

      President and CEO

      ProActive Consultants, LLC

      1659 3rd Ave, Cumberland, WI 54829

      E-mail: QuinB@...

      Phone: 715.822.8284

      Cell: 715.307.4448

      Fax: 715.822.8299



      From: CCO-L@yahoogroups.com [mailto:CCO-L@yahoogroups.com] On Behalf Of
      Meernik, Shirlene
      Sent: Thursday, February 14, 2013 8:53 AM
      To: 'CCO-L@yahoogroups.com'
      Subject: [CCO-L] question regardaing billing based on counseling
      and/coordination of care time





      We had a consultant who came to provide education to our providers regarding
      the new CPT codes for psych. The consultant encouraged our providers to
      document and bill based on counseling and/or coordination of care rather
      than the E/M coding requirements because it was easier and requires less
      documentation. While I certainly agree there are instances when this is
      appropriate and beneficial I would not expect to see every service to every
      patient be billed in this manner. They are insisting however that they can
      use counseling time for all services and levels of E/Ms. Am I being too
      conservative in my thinking and what is the group's thoughts or opinions on
      basing all outpatient E/M services on counseling time?

      For patients that are stable and/or improved, no med changes, no side
      effects, no change in diagnosis would it be medically necessary to bill this
      as counseling time when there is no evidence of the need for counseling and
      the counseling provided is documented as counseled on medication and
      possible side effects and encouraged patient to get adequate sleep. From
      what I know about medical necessity and E/M documentation this would satisfy
      counseling time for billing a 99214.

      I am not discouraging or discounting use of counseling time but I just am
      not sure that the intent of it is for it to be used for all E/M services for
      every patient at every visit. I have read the guidelines regarding the new
      codes and understand them I believe, but we are disagreeing on the
      counseling time intent and because a consultant told them this that is what
      they believe. I personally think she gave them that as an option which I
      agree with but that she did not say to use it all the time.

      Advice would be much appreciated!
      Thanks.

      ________________________________

      This transmission is for the use of the individual or entity named on this
      e-mail. Unauthorized disclosure or access may be prohibited by Public Law
      99-474 (The Computer Fraud and Abuse Act of 1986), Public Law 104-294
      (National Information Infrastructure Protection Act of 1996), 18 U.S.C.
      1030, or other applicable criminal laws, and can result in administrative,
      disciplinary or criminal proceedings. This mail system, including this
      transmittal, may be internally monitored for all lawful purposes, including
      ensuring compliance with applicable privacy and security rules as specified
      by HIPAA, Mental Health Code and Pine Rest Christian Mental Health Services'
      policies and procedures. Transmission of unencrypted Protected Health
      Information is prohibited.

      ________________________________

      If this was sent to you in error, please notify the sender by reply e-mail
      and destroy all copies and attachments of the original message.

      [Non-text portions of this message have been removed]



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      Version: 2013.0.2899 / Virus Database: 2639/6101 - Release Date: 02/13/13
      Internal Virus Database is out of date.



      [Non-text portions of this message have been removed]
    • Meernik, Shirlene
      Our providers insist they are not doing psychotherapy during the session but are just counseling patients on meds and side effects, etc. My concern is using
      Message 2 of 5 , Feb 25, 2013
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        Our providers insist they are not doing psychotherapy during the session but are just "counseling" patients on meds and side effects, etc. My concern is using counseling when there doesn't appear to be a reason or necessity for med counseling. According to the providers this consultant pretty much encouraged them to use counseling time rather than the key components for almost of their services and that has me very concerned and I disagree with it. I suppose it is possible there are a lot of consultants out there giving bad advice but for a consultant to tell them to always using counseling time just doesn't sit well with me.

        To answer your question about how the doc is doing with the new codes, the answer is: not too well because now that he thinks he can always use counseling time he thinks it is pretty easy. Probably why I am getting so much push back from all of them. When a consultant tells a provider something they want to hear, then who am I when I am giving them advice they disagree with?

        So knowing they aren't providing psychotherapy but just "counseling", does that change your opinion any about using the over 50% counseling time for most E/M visits which used to be billed using 90862? In my opinion they are using the length of the appointment for the time factor because the documentation really hasn't changed much since 90862 days, yet because the consultant told them to use time, they would like to use 99214.

        From: CCO-L@yahoogroups.com [mailto:CCO-L@yahoogroups.com] On Behalf Of Quinten Buechner
        Sent: Saturday, February 23, 2013 1:30 PM
        To: CCO-L@yahoogroups.com
        Subject: RE: [CCO-L] question regardaing billing based on counseling and/coordination of care time



        I'm not sure I'd bring that consultant back . S(he) hasn't read CPT very
        closely or well. CPT is very clear that time can't be used as a basis of
        documenting E&M when the E&M is done with Psychotherapy. Look at page 485 in
        the Professional version right column, last paragraph and the first
        paragraphs of the next column, paragraph number 3. Those who don't have a
        Professional edition should look at the initial introduction to
        Psychotherapy. How is your Doc who didn't want to do E&Ms doing with this
        change?

        Quinten A. Buechner, M.S., M.Div.,
        ACS-FP/GI/PEDS(BAMC), CPC(AAPC), CCP(PHIA), CMSC(PAHCS)

        President and CEO

        ProActive Consultants, LLC

        1659 3rd Ave, Cumberland, WI 54829

        E-mail: QuinB@...<mailto:QuinB%40centurytel.net>

        Phone: 715.822.8284

        Cell: 715.307.4448

        Fax: 715.822.8299

        From: CCO-L@yahoogroups.com<mailto:CCO-L%40yahoogroups.com> [mailto:CCO-L@yahoogroups.com<mailto:CCO-L%40yahoogroups.com>] On Behalf Of
        Meernik, Shirlene
        Sent: Thursday, February 14, 2013 8:53 AM
        To: CCO-L@yahoogroups.com<mailto:%26%2339%3BCCO-L%40yahoogroups.com>'
        Subject: [CCO-L] question regardaing billing based on counseling
        and/coordination of care time

        We had a consultant who came to provide education to our providers regarding
        the new CPT codes for psych. The consultant encouraged our providers to
        document and bill based on counseling and/or coordination of care rather
        than the E/M coding requirements because it was easier and requires less
        documentation. While I certainly agree there are instances when this is
        appropriate and beneficial I would not expect to see every service to every
        patient be billed in this manner. They are insisting however that they can
        use counseling time for all services and levels of E/Ms. Am I being too
        conservative in my thinking and what is the group's thoughts or opinions on
        basing all outpatient E/M services on counseling time?

        For patients that are stable and/or improved, no med changes, no side
        effects, no change in diagnosis would it be medically necessary to bill this
        as counseling time when there is no evidence of the need for counseling and
        the counseling provided is documented as counseled on medication and
        possible side effects and encouraged patient to get adequate sleep. From
        what I know about medical necessity and E/M documentation this would satisfy
        counseling time for billing a 99214.

        I am not discouraging or discounting use of counseling time but I just am
        not sure that the intent of it is for it to be used for all E/M services for
        every patient at every visit. I have read the guidelines regarding the new
        codes and understand them I believe, but we are disagreeing on the
        counseling time intent and because a consultant told them this that is what
        they believe. I personally think she gave them that as an option which I
        agree with but that she did not say to use it all the time.

        Advice would be much appreciated!
        Thanks.

        ________________________________

        This transmission is for the use of the individual or entity named on this
        e-mail. Unauthorized disclosure or access may be prohibited by Public Law
        99-474 (The Computer Fraud and Abuse Act of 1986), Public Law 104-294
        (National Information Infrastructure Protection Act of 1996), 18 U.S.C.
        1030, or other applicable criminal laws, and can result in administrative,
        disciplinary or criminal proceedings. This mail system, including this
        transmittal, may be internally monitored for all lawful purposes, including
        ensuring compliance with applicable privacy and security rules as specified
        by HIPAA, Mental Health Code and Pine Rest Christian Mental Health Services'
        policies and procedures. Transmission of unencrypted Protected Health
        Information is prohibited.

        ________________________________

        If this was sent to you in error, please notify the sender by reply e-mail
        and destroy all copies and attachments of the original message.

        [Non-text portions of this message have been removed]

        _____

        No virus found in this message.
        Checked by AVG - www.avg.com
        Version: 2013.0.2899 / Virus Database: 2639/6101 - Release Date: 02/13/13
        Internal Virus Database is out of date.

        [Non-text portions of this message have been removed]


        ________________________________

        This transmission is for the use of the individual or entity named on this e-mail. Unauthorized disclosure or access may be prohibited by Public Law 99-474 (The Computer Fraud and Abuse Act of 1986), Public Law 104-294 (National Information Infrastructure Protection Act of 1996), 18 U.S.C. 1030, or other applicable criminal laws, and can result in administrative, disciplinary or criminal proceedings. This mail system, including this transmittal, may be internally monitored for all lawful purposes, including ensuring compliance with applicable privacy and security rules as specified by HIPAA, Mental Health Code and Pine Rest Christian Mental Health Services' policies and procedures. Transmission of unencrypted Protected Health Information is prohibited.

        ________________________________

        If this was sent to you in error, please notify the sender by reply e-mail and destroy all copies and attachments of the original message.


        [Non-text portions of this message have been removed]
      • Quinten Buechner
        If they are documenting the items specified in the description on page 6 and certify more than 50% (time in and time out)of X total time then they can do so
        Message 3 of 5 , Feb 25, 2013
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          If they are documenting the items specified in the description on page 6
          and certify more than 50% (time in and time out)of X total time then they
          can do so for anything other than psychotherapy. They do need to realize
          that the CPT book must be followed unless they have something different, in
          writing, from CMS. I think you should use the old trick of challenging the
          consultant in writing (blind CC to the boss). Ask her what is her source,
          given that it contradicts CPT page 485,right column, paragraph # 2.
          Alternatively, you could write a similar letter to

          The Medicare Medical Director. As another option identify her to me off
          list, I may know her and get her to clarify.



          When CPT says Counseling they only mean the items specified on page 6. Even
          then they will have trouble because of the statement on page 485. CPT does
          not mean supportive, behavior modification, cognitive methods or other
          psychotherapy techniques. If the docs are insisting on time as a measure
          then you have to kick it up the ladder because without a document from the
          AMA or CMS, you will loose money about 3 years from now on audit. The first
          thing an auditor sees is time as the measure of E&M, they may let it pass,
          but when they see it for every visit you will have trouble. The auditors are
          not stupid but they are sticklers for details in the rules. I do not see
          prescription for medicines in the list of counseling rationales. I do see
          telling the patient what the meds will do, but not actually providing the
          med, so in my opinion (also reviewed and agreed with by psychiatrists I work
          with) there is no counseling going on.

          Quinten A. Buechner, M.S., M.Div.,
          ACS-FP/GI/PEDS(BAMC), CPC(AAPC), CCP(PHIA), CMSC(PAHCS)

          President and CEO

          ProActive Consultants, LLC

          1659 3rd Ave, Cumberland, WI 54829

          E-mail: QuinB@...

          Phone: 715.822.8284

          Cell: 715.307.4448

          Fax: 715.822.8299



          From: CCO-L@yahoogroups.com [mailto:CCO-L@yahoogroups.com] On Behalf Of
          Meernik, Shirlene
          Sent: Monday, February 25, 2013 7:34 AM
          To: 'CCO-L@yahoogroups.com'
          Subject: RE: [CCO-L] question regardaing billing based on counseling
          and/coordination of care time





          Our providers insist they are not doing psychotherapy during the session but
          are just "counseling" patients on meds and side effects, etc. My concern is
          using counseling when there doesn't appear to be a reason or necessity for
          med counseling. According to the providers this consultant pretty much
          encouraged them to use counseling time rather than the key components for
          almost of their services and that has me very concerned and I disagree with
          it. I suppose it is possible there are a lot of consultants out there giving
          bad advice but for a consultant to tell them to always using counseling time
          just doesn't sit well with me.

          To answer your question about how the doc is doing with the new codes, the
          answer is: not too well because now that he thinks he can always use
          counseling time he thinks it is pretty easy. Probably why I am getting so
          much push back from all of them. When a consultant tells a provider
          something they want to hear, then who am I when I am giving them advice they
          disagree with?

          So knowing they aren't providing psychotherapy but just "counseling", does
          that change your opinion any about using the over 50% counseling time for
          most E/M visits which used to be billed using 90862? In my opinion they are
          using the length of the appointment for the time factor because the
          documentation really hasn't changed much since 90862 days, yet because the
          consultant told them to use time, they would like to use 99214.

          From: CCO-L@yahoogroups.com <mailto:CCO-L%40yahoogroups.com>
          [mailto:CCO-L@yahoogroups.com <mailto:CCO-L%40yahoogroups.com> ] On Behalf
          Of Quinten Buechner
          Sent: Saturday, February 23, 2013 1:30 PM
          To: CCO-L@yahoogroups.com <mailto:CCO-L%40yahoogroups.com>
          Subject: RE: [CCO-L] question regardaing billing based on counseling
          and/coordination of care time

          I'm not sure I'd bring that consultant back . S(he) hasn't read CPT very
          closely or well. CPT is very clear that time can't be used as a basis of
          documenting E&M when the E&M is done with Psychotherapy. Look at page 485 in
          the Professional version right column, last paragraph and the first
          paragraphs of the next column, paragraph number 3. Those who don't have a
          Professional edition should look at the initial introduction to
          Psychotherapy. How is your Doc who didn't want to do E&Ms doing with this
          change?

          Quinten A. Buechner, M.S., M.Div.,
          ACS-FP/GI/PEDS(BAMC), CPC(AAPC), CCP(PHIA), CMSC(PAHCS)

          President and CEO

          ProActive Consultants, LLC

          1659 3rd Ave, Cumberland, WI 54829

          E-mail: QuinB@... <mailto:QuinB%40centurytel.net>

          Phone: 715.822.8284

          Cell: 715.307.4448

          Fax: 715.822.8299

          From: CCO-L@yahoogroups.com <mailto:CCO-L%40yahoogroups.com>
          [mailto:CCO-L@yahoogroups.com <mailto:CCO-L%40yahoogroups.com> ] On Behalf
          Of
          Meernik, Shirlene
          Sent: Thursday, February 14, 2013 8:53 AM
          To: CCO-L@yahoogroups.com <mailto:CCO-L%40yahoogroups.com> '
          Subject: [CCO-L] question regardaing billing based on counseling
          and/coordination of care time

          We had a consultant who came to provide education to our providers regarding
          the new CPT codes for psych. The consultant encouraged our providers to
          document and bill based on counseling and/or coordination of care rather
          than the E/M coding requirements because it was easier and requires less
          documentation. While I certainly agree there are instances when this is
          appropriate and beneficial I would not expect to see every service to every
          patient be billed in this manner. They are insisting however that they can
          use counseling time for all services and levels of E/Ms. Am I being too
          conservative in my thinking and what is the group's thoughts or opinions on
          basing all outpatient E/M services on counseling time?

          For patients that are stable and/or improved, no med changes, no side
          effects, no change in diagnosis would it be medically necessary to bill this
          as counseling time when there is no evidence of the need for counseling and
          the counseling provided is documented as counseled on medication and
          possible side effects and encouraged patient to get adequate sleep. From
          what I know about medical necessity and E/M documentation this would satisfy
          counseling time for billing a 99214.

          I am not discouraging or discounting use of counseling time but I just am
          not sure that the intent of it is for it to be used for all E/M services for
          every patient at every visit. I have read the guidelines regarding the new
          codes and understand them I believe, but we are disagreeing on the
          counseling time intent and because a consultant told them this that is what
          they believe. I personally think she gave them that as an option which I
          agree with but that she did not say to use it all the time.

          Advice would be much appreciated!
          Thanks.

          ________________________________

          This transmission is for the use of the individual or entity named on this
          e-mail. Unauthorized disclosure or access may be prohibited by Public Law
          99-474 (The Computer Fraud and Abuse Act of 1986), Public Law 104-294
          (National Information Infrastructure Protection Act of 1996), 18 U.S.C.
          1030, or other applicable criminal laws, and can result in administrative,
          disciplinary or criminal proceedings. This mail system, including this
          transmittal, may be internally monitored for all lawful purposes, including
          ensuring compliance with applicable privacy and security rules as specified
          by HIPAA, Mental Health Code and Pine Rest Christian Mental Health Services'
          policies and procedures. Transmission of unencrypted Protected Health
          Information is prohibited.

          ________________________________

          If this was sent to you in error, please notify the sender by reply e-mail
          and destroy all copies and attachments of the original message.

          [Non-text portions of this message have been removed]

          _____

          No virus found in this message.
          Checked by AVG - www.avg.com
          Version: 2013.0.2899 / Virus Database: 2639/6101 - Release Date: 02/13/13
          Internal Virus Database is out of date.

          [Non-text portions of this message have been removed]

          ________________________________

          This transmission is for the use of the individual or entity named on this
          e-mail. Unauthorized disclosure or access may be prohibited by Public Law
          99-474 (The Computer Fraud and Abuse Act of 1986), Public Law 104-294
          (National Information Infrastructure Protection Act of 1996), 18 U.S.C.
          1030, or other applicable criminal laws, and can result in administrative,
          disciplinary or criminal proceedings. This mail system, including this
          transmittal, may be internally monitored for all lawful purposes, including
          ensuring compliance with applicable privacy and security rules as specified
          by HIPAA, Mental Health Code and Pine Rest Christian Mental Health Services'
          policies and procedures. Transmission of unencrypted Protected Health
          Information is prohibited.

          ________________________________

          If this was sent to you in error, please notify the sender by reply e-mail
          and destroy all copies and attachments of the original message.

          [Non-text portions of this message have been removed]



          _____

          No virus found in this message.
          Checked by AVG - www.avg.com
          Version: 2013.0.2899 / Virus Database: 2641/6129 - Release Date: 02/24/13



          [Non-text portions of this message have been removed]
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