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

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  • 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 1 of 5 , Feb 25, 2013
      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.

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      (National Information Infrastructure Protection Act of 1996), 18 U.S.C.
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      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.

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