account for all cpo servicesstatic.aapc.com/5548a1af-4c9f-49a2-bfe0-bfa7d... · on by icd-10 and...

Plus: 2011 Salary Survey • ICD-10 A&P • ESRD • Medicare Revalidation • Capsule Endoscopy

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Kristine Cuddy, CPC, CIMC

Account for All CPO Services

Certification / Recertification

Monthly

Care Plan OversightCare Plan Oversight

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Coding Edge AD_RVGCrosswalk 09_2011_print.pdf 1 8/1/11 3:25 PM

www.aapc.com October 2011 3

[contents] 7 Letter from the Chairman and CEO

8 Letters to the Editor

11 Letter from Member Leadership

12 Coding News

In Every Issue

16 Help ICD Make People Count RhondaBuckholtz,CPC,CPMA,CPC-I,andDonnaL.Stewart,CPC,CPC-H,CPC-P,CPC-I

20 Filter Out Bad ESRD Coding MichelleA.Green,MPS,RHIA,CPC,FAHIMA

24 Chemodenervation Injections: Do Modifiers Apply? MarvelJ.Hammer,RN,CPC,CCS-P,PCS,ACS-PM,CHCO

26 Don’t Overlook Care Plan Oversight KristineCuddy,CPC,CIMC

36 Timely Medicare Revalidation May Prevent Deactivation or Revocation DellyE.Parham,AS,CPC

44 Capsule Endoscopy Coding, Made Simple G.J.Verhovshek,MA,CPC

46 Clinical Trials Under Scrutiny DuwayneBarrett,MBA,RPSGT,CPC-P

On the Cover: Kristine Cuddy, CPC, CIMC, makes the most out of billing by accounting for care plan oversight (CPO) services: certification and recertification of home health agency (HHA) services, and monthly CPO. Cover photo by Tom Pearson, TCP Image Company (www.tcpimageco.com).

Special Features

Education

Coming Up

Contents

October 2011

44

Online Test Yourself – Earn 1 CEUGo to: www.aapc.com/resources/ publications/coding-edge/archive.aspx

9 Quick Tip: Reporting Separate Studies

32 2011 Salary Survey

50 Minute with a Member

14 AAPCCA: Continuing Ed

15 Handbook Quick Tip: Officer Requirements

38 Newly Credentialed Members

24

• 2011 Coding Changes

• Nashville Conference

• FESS

• Bogus Billing

• Humanism

Features

32

20

4 AAPC Coding Edge

Volume 22 Number 10 October 1, 2011

CodingEdge(ISSN:1941-5036)ispublishedmonthlybyAAPC,2480South3850West,SuiteB.SaltLakeCity,Utah,84120,foritspaidmembers.PeriodicalpostagepaidattheSaltLakeCitymailingofficeandothers.POSTMASTER:Sendaddresschangesto:CodingEdgec/oAAPC,2480South3850West,SuiteB,SaltLakeCity,UT,84120.

Chairman and CEOReedE.Pew

[email protected]

Vice President of Finance and Strategic PlanningKorbMatosich

[email protected]

Vice President of MarketingBevanErickson

[email protected]

Vice President of ICD-10 Education and TrainingRhondaBuckholtz,CPC,CPMA,CPC-I,CGSC,COBGC,CPEDC,CENTC

[email protected]

Directors, Pre-Certification Education and ExamsRaemarieJimenez,CPC,CPMA,CPC-I,CANPC,CRHC

[email protected],CPC,CPMA,CPC-I,CMRS

[email protected]

Director of Member ServicesDanielleMontgomery

[email protected]

Director of PublishingBradEricson,MPC,CPC,COSC

[email protected]

Managing EditorJohnVerhovshek,MA,CPC

[email protected]

Executive Editors MichelleA.Dick,BS ReneeDustman,BS [email protected] [email protected]

Production Artists TinaM.Smith,AAS ReneeDustman,BS [email protected] [email protected]

Advertising/Exhibiting Sales ManagerJamieZayach,BS

[email protected]

Addressallinquires,contributionsandchangeofaddressnoticesto:

Coding EdgePO Box 704004

Salt Lake City, UT 84170(800) 626-CODE (2633)

©2011AAPC,CodingEdge.Allrightsreserved.Reproductioninwholeorinpart,inanyform,withoutwrittenpermissionfromAAPCisprohibited.Contributionsarewelcome.CodingEdgeisapublicationformembersofAAPC.StatementsoffactoropinionaretheresponsibilityoftheauthorsaloneanddonotrepresentanopinionofAAPC,orsponsoringorganizations.Cur-rentProceduralTerminology(CPT®)iscopyright2010AmericanMedicalAssociation.AllRightsReserved.Nofeeschedules,basicunits,relativevaluesorrelatedlistingsareincludedinCPT®.TheAMAassumesnoliabilityforthedatacontainedherein.

CPC®,CPC-H®,CPC-P®,CPCOTM,CPMA®andCIRCC®areregisteredtrademarksofAAPC.

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Serving AAPC MembersThe membership of AAPC, and subsequently the readership of Coding Edge, is quite varied. To ensure we are providing education to each segment of our audience, in every issue we will publish at least one article on each of three levels: apprentice, professional and expert. The articles will be identified with a small bar denoting knowledge level:

Beginning coding with common technologies, basic anatomy and physiology, and using standard code guidelines and regulations.

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H ealth care is in the midst of dramat-ic transformation, driven not only by technological breakthroughs that

continue to expand the clinical possibilities of medicine, but also by regulatory require-ments that will alter how the business of medicine gets done.The adoption of ICD-10 in late 2013 will re-quire an overhaul of everything from trans-action standards to payer coverage deci-sions and physician documentation. Wide-spread adoption of electronic health records (EHRs)—spurred by government incen-tives (and penalties, for those who choose to forego EHRs)—has changed how we treat health data. At the same time, an al-phabet soup of anti-fraud and abuse ini-tiatives (zone program integrity contrac-tors (ZPICs), recovery audit contractors (RACs), the Medicaid Integrity Program (MIP), Comprehensive Error Rate Test-ing (CERT), etc.) has raised the stakes for health care facilities and providers. Another transformative development may be the establishment of health insurance ex-changes (HIEs), mandated by Affordable Care Act of 2010. As envisioned under the law, an HIE is a central marketplace where individuals and companies could purchase health insurance from private insurers. Qualified plans would have to meet mini-mum coverage and cost requirements. Each state must have an HIE up and running by Jan. 1, 2014; if a state fails to meet the man-date, the federal government may establish an HIE on the state’s behalf. HIEs would be open to any individual with-out health insurance, and certain workers could purchase insurance through an HIE rather than through their employer. Insur-ance premiums would be subsidized for in-dividuals with income up to 400 percent of the poverty line (currently, an income of under $10,900 annually for an individual is

considered poverty level; for a family of four, the figure is approximately $22,300). Sub-sidies would be provided in the form of a re-fundable tax credit.

More Patients Means More Need for CPCs®

Along with HIEs, the Affordable Care Act mandates that most individuals must ob-tain basic health coverage by 2014, or pay a penalty to help offset the cost of caring for the uninsured.The Congressional Budget Office estimates that nationwide 11.5 million people, includ-ing members of Congress, will get insurance through HIEs in 2014. The individual in-surance mandate will add millions more to the roles of the insured, pouring addition-al patients into an already overburdened health care system. The Affordable Care Act has provisions to encourage an expansion of primary care, but for a time we actually may see longer wait times and decreased access to care due to increased patient demand. Whether HIEs will perform as planned—universal coverage at lower prices—is far from certain. Funding for federal programs of all types is under scrutiny. The indi-vidual insurance mandate remains hotly debated, as does much of health care re-form under the Affordable Care Act. Sev-eral states have chosen to forego Depart-ment of Health & Human Services (HHS) assistance (and millions of dollars) to set up HIEs. If enough states default on the man-date, the feds may have to reconsider their approach. Whatever the future of health care holds, we’re likely to be in for a rocky ride. But along for the ride comes opportunity for AAPC members, who will step forward to code more visits by more patients, monitor EHRs to assure they’re accurate and updat-ed, audit submitted claims, and help their

practices and facilities understand and im-plement new compliance standards. Prac-tices and facilities also will look to AAPC members to help educate providers on docu-mentation and implement changes brought on by ICD-10 and new 5010 standards.Change is good for coders, and we’re about to see a great deal of change. Throughout this transformation, AAPC will be there with you. You can count on education from your organization and support from your local chapter members. Your friend,

Reed E. Pew Chairman and CEO

LetterfromtheChairmanandCEO

With Change Comes Opportunity

8 AAPC Coding Edge

LetterstotheEditor Pleasesendyourletterstotheeditorto:[email protected]

Be Sure of the Reason for Noncovered DenialsIn the article “Claims Adjustments: The Last Resort” (August 2011, pages 26-27), Wendy Grant makes some great points about claims adjustments; however, I want to comment on her advice for noncov-ered service denials. She’s absolutely correct in saying that these deni-als should be billed to the patient (when appropriate), rather than being written off, but I would advise those doing the billing to research the denial prior to billing the patient to verify that it’s not due to a correct-able circumstance.Some services will deny as noncovered only under specific circumstanc-es, such as when the diagnosis submitted on the charge is a noncovered indication for the service (due to improper ICD-9 sequencing), or be-cause the description of the problem was too vague to establish medical necessity for the service.Contact the payer to find out what they mean by “noncovered.” Is the service not covered in general, or only when it’s submitted with the di-agnosis listed? Is the service considered experimental or investigational when billed with the diagnosis listed, or is it subject to any other exclu-sions? Does the patient have a specific plan exclusion for his or her group, or a rider excluding the service?Noncovered denials often point to an error made in the coding/billing process, which can be easily corrected and result in proper payment.

There’s a reason the service wasn’t covered, and you should always un-derstand what that reason is.Brandi Tadlock, CPC, CPC-P, CPMA

Use Unlisted Code for EUS with Fiducial PlacementI was reading “Target Accurate Coding for Interstitial Device Place-ment” (July 2011, pages 34-35) and have a question which the article did not address. I code for a gastrointestinal doctor who places fiducial markers via endoscopic ultrasound (EUS)—for example, EUS with fine needle aspiration (FNA) placement of endocoil (gold fiducials). The placement is the only procedure. How would this be coded? Randa Cain, CPC

EUS has been adopted for a greater variety of procedures in recent years, but CPT® has yet to specify a code for placement of fiducial markers via EUS. Perhaps the closest code for what you describe is 43242 Upper gas-trointestinal endoscopy including esophagus, stomach, and either the duo-denum and/or jejunum as appropriate; with transendoscopic ultrasound-guided intramural or transmural fine needle aspiration/biopsy(s). When it comes to coding, however, close enough isn’t good enough. If CPT® does not contain a specific code to report a given procedure, select a sec-tion-appropriate unlisted procedure code. You may compare the proce-dure to 43242 as a pricing guide.

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Quick Tip

Neither CPT® nor the Centers for Medicare & Medicaid Services (CMS) address this issue directly, but the American College of Radiol-ogy (ACR) has offered advice in its “Coding Q and A” (www.acr.org/Hidden/Economics/FeaturedCategories/Pubs/coding_source/archives/November December2003/Coding_qa.aspx), as follows:

“Q: How should a study of an MRI of the brain and of the pituitary gland be reported?

A: If both an MRI of the brain and an MRI of the pituitary gland are sepa-rately requested and performed with a full series of specialized pulse sequences, specifically of the pituitary gland, then an MRI of the brain should be reported two times with a modifier (e.g. 59) appended to the second study. Note that clear, separate and distinct indications for two complete studies must be documented. If just an additional pulse sequence or two focused on the pituitary gland are added to the MRI of the brain, the extra sequences would be considered part of the base study and an MRI of the brain would be reported only once.

This is similar to the reporting of an MRI of brain and the internal auditory canal. Reference the March/April 2003 feature article of the ACR Radiol-ogy Coding Source™ for further discussion.”

In other words, if two distinct and medically necessary studies are performed of the brain and pituitary without and with contrast, you may report 70553 and 70553-59. Code 70543 is not appropriate to report MRI of the pituitary.

Reports from the field indicate that few third-party payers will recog-nize and reimburse for two brain MRIs (e.g., two units of 70553) dur-ing the same encounter, even if the studies are properly documented and medically necessary. Alternatively, some payers may allow you to report the brain MRI with modifier 22 Increased procedural service to describe the additional sequences (note that modifier 22 cannot be applied to hospital outpatient services). When in doubt, check with your payer for instructions in writing.

Report MRI x 2 for Separate Brain, Pituitary StudiesA Coding Edge reader asks the following question:When magnetic resonance imaging (MRI) of the brain and pituitary are done on the same day (without and with contrast), should we report multiple units of 70553 Magnetic resonance (eg, proton) imaging, brain (including brain stem); without contrast material, followed by contrast material(s) and further sequences with modifier 59 Distinct procedural service on the second unit, or should we report 70553 and 70543 Mag-netic resonance (eg, proton) imaging, orbit, face, and/or neck; without contrast material(s), followed by contrast material(s) and further sequences?

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Reading last month’s Coding Edge arti-cle by Freda Brinson, CPC, CPC-H, CEMC, “Project AAPC: Compassion

Is Contagious,” I was moved by our mem-bers’ compassion and generosity in assisting those in need both abroad and here at home. I also was proud to read about the AAPC Chapter Association’s (AAPCCA) contin-ued support of AAPC’s humanitarian effort to help feed the hungry of America.I am fortunate that I have never truly been impacted by the consequences of food short-ages or long term hunger. Wanting to better understand the cause, I decided to do my research. Here is what I discovered about food insecurities (or hunger) and its effect on Americans impacted by this epidemic.

Hunger Is EverywhereThese are statistics from the Feeding Ameri-ca’s Hunger in America organization:

• More than 50 million Americans live daily with hunger, which means they do not have dependable, consistent access to food.

• Hunger is everywhere, and is growing along with the number of unemployed, underemployed, and working poor.

• More than 17 million of these Americans are children, over three million of which are 5 years old and under, at a time when nutrition is so important to development.

• For school-aged children, funded lunch and breakfast programs provide meal help at school, but they don’t solve the problem, particularly during the summer and in November and December, when children are out of school for an extended time.

• An estimated 3.4 million elderly live below the poverty level, yet this population is the least likely to receive help through food assistance programs.

• Approximately 30- 35 percent of the hungry elderly are forced to choose between food and medical care, and/or utilities.

Working in the medical field, I was partic-ularly interested in the health implications of food insecurities. Many of these health is-sues have long-term consequences:

• Inadequate nutrition in children 0-5 years of age weakens their developing immune system, leading to increases in infection and illness, and their ability to learn and grow.

• Due to overall poor health and frequent illness, malnourished children have a 30 percent higher rate of hospitalization, which may further stress the family’s fragile economics.

• Lack of adequate nutrition in school-aged children affects cognitive and behavior development.

• In 6- to 12-year-old children, food insecurity is linked to irritability, fatigue, anxiety, aggression, psychosocial dysfunction, and difficulty concentrating, which can lead to poor math scores, absenteeism, tardiness, and grade repetition.

• Studies have shown that food insecurities in 15- to 16-year-old children are associated with suicide and depressive disorders.

• Senior citizens who lack proper nutrition are two times more likely to be in poor health than those who receive adequate nutrition, which leads to an increase in the need for expensive medical intervention and hospitalization.

Helping Hands Can Make a DifferenceThe good news is that the AAPCCA board, with the help of our local chapters, has raised just under $20,000, with approxi-mately $3,600 of that total going to Feed-ing America.

This is a great start for an organization of our size, but I believe we can do more.

We Challenge You!On behalf of the AAPC National Adviso-ry Board (NAB) and the AAPCCA board, we are challenging each member to donate just $1 (of course, we would never refuse a more generous donation) to Project AAPC. Please join us in our fight to feed the hungry in America through the upcoming holiday season and beyond.

Donating Couldn’t Be Simpler There are three ways to submit your donation:

• Through your local chapter. Contact your chapter officer for more details.

• Directly to the AAPC National Office by mail in care of: Director Local Chapter Support Marti Johnson; AAPC 2480 South 3850 West, Suite B Salt Lake City, UT 84120

• In the near future, though our AAPC website.

Best Wishes,

Cynthia Stewart, CPC, CPC-H, CPMA, CPC-I, CCS-PPresident, National Advisory Board

Project AAPC: Rise to Our Challenge

LetterfromMemberLeadership

12 AAPC Coding Edge

CodingNews

Dismissed: Third-party Complaint Against Coders and Billers in Whistleblower Lawsuit

By Christopher A. Parrella, JD, CHC, CPC, CPCO

On May 13, 2011, the U.S. District Court for the East-ern District of New York (3:09-00738) dismissed a third-party complaint against coding and billing consultants/agents for the defendants in a Medicare whistleblow-er (civil false claims) suit alleging the defendants billed Medicare for thousands of non-approved stereotactic body radiosurgery procedures.The court concluded that, although New York law per-mits claims for contribution in actions based on tort, con-tribution is inapplicable in contract or quasi-contract cases such as this. The third-party complaint against Re-gency Alliance Services and Physicians Management Group, alleged negligence, culpable conduct, and incor-rect/improper billing and coding. The court concluded that because the theories of liabili-ty asserted against the first-party defendants (the clients of the coders/billers) were equitable claims in restitution or quasi-contract, not tort claims, the third-party defen-dants were only exposed to their fair share of liability.

Apply CARC and RARC Messages for Unsuccessful eRx Beginning Jan. 1, 2012 eligible professionals (EPs) who are not successful electronic prescribers (e-prescribers) may be subject to a negative payment adjustment. Sec-tion 132 of the Medicare Improvements for Patients and Providers Act (MIPPA) of 2008 requires the Centers for Medicare & Medicaid Services (CMS) to apply this neg-ative payment adjustment to any EP who is not a success-ful e-prescriber under the e-Prescribing (eRx) Incentive Program. Claim Adjustment Reason Code (CARC) messages are used on both the electronic and paper remittance advice. CARCs are used to explain the reasons for any financial adjustments—for example, denials, reductions, or in-creases in payment. A CARC may explain why a claim was paid differently than it was billed. Remittance Ad-vice Remark Code (RARC) messages are used on a re-mittance advice to further explain an adjustment already described by an adjustment reason code or to relay infor-mational messages that cannot be expressed with an ad-justment reason code.

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CodingNews

CMS Change Request (CR) 7500 (www.cms.gov/transmit

tals/downloads/R943OTN.pdf) implements the use of one new CARC and two new RARC messages to be used on remittance advices to communicate to EPs that an ad-justment was applied related to the eRx Incentive Pro-gram negative adjustment.

CMS Releases New, Revised Medicare Enrollment FormsThe U.S. Office of Management and Budget recently ap-proved updates to the Medicare Provider-Supplier En-rollment Applications (CMS-855). The revised and new forms are now available on the CMS Provider-Supplier website (www.cms.gov/CMSForms/CMSForms/list.asp?filtertype

=dual&filtertype=keyword&keyword=855).Providers and suppliers enrolling only to order and re-fer are required to begin using the new CMS-855O form immediately. Those using other CMS-855 forms to en-roll in Medicare are encouraged to begin using the re-vised forms, but may continue to use the old forms through October 2011.Source: Palmetto GBA

Update Processing for Noncovered Ambulance Services for COBCMS recently instructed contractors to revise their claims processing systems to allow HCPCS Level II codes identifying noncovered ambulance transportation and transportation-related services into their systems for adjudication. Although these codes (A0021-A0424 and A0998) remain noncovered, accepting these claims will allow providers and suppliers to obtain a Medicare denial so they may then submit a claim for a patient with Medi-care to his or her secondary insurance for coordination of benefits (COB) purposes.Providers and suppliers should begin submitting ambu-lance transportation and transportation-related service claims beginning Jan. 1, 2012. Providers and suppliers billing for noncovered ambulance services for the pur-pose of a Medicare denial should append modifier GY Item or service statutorily excluded or does not meet the def-inition of any Medicare benefit to the appropriate HCPCS Level II code for the service.For more information, see CMS transmittal 942, Change Request (CR) 7489, available at: www.cms.gov/

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Medicine is not a static business. Health care professionals and all support staff must advance their understanding of this ever-changing industry. They do this through extracurricular learning activities and programs, similar to adult education. AAPC requires credentialed members to continue their cod-ing education throughout their career. Upon successful com-pletion of an activity or program, members earn one or more continuing education units (CEUs). CEUs serve as a perma-nent record of a member’s educational accomplishments. The real reward, of course, is the ability for certified professionals to uphold a higher standard by expanding their knowledge-base and staying up to date on changes in compliance, medi-cal coding, and government regulations.

Meet CEU RequirementsCEUs are due every two years and are applied through a rota-tion system based on membership renewal dates. Each mem-ber has a CEU Tracker available online which records the in-dex number for pre-approved CEU certificates. If the CEU Tracker does not recognize an approved index number, the in-formation can be submitted using the “no index number was found” option. You should maintain a hard copy of any submitted CEU cer-tificates for personal records for a minimum of six months after the actual certification renewal date. AAPC conducts random verifications on 25 percent of all CEU submissions for compliance verification. CEUs apply to the year they are earned, not the year they are submitted, and they do not car-

ry over to the next renewal period.There are two CEU categories: Core A and

Core B. Core A focuses on the daily, technical side of medical coding.

A member may claim 100 percent of their CEUs from

Core A topics. Core B ad-dresses general business skills.

A maximum of six CEUs per year or 33.3 percent can be ob-

tained from this area. A CPC is required to obtain 36 CEUs every

two years, which means up to 12 CEUs may be Core B and a mini-mum of 24 CEUs must be Core A.

This may seem like a tough requirement, but there are endless opportunities for earning CEUs.

Earn CEUs at Local Chapter MeetingsThe main purposes of local chapter meetings are to learn and network with other coding professionals. Members can gain valuable information from sharing with other chapter mem-bers and health care professionals. For this reason, AAPC awards CEUs to participating members. Local chapters are required to hold a minimum of six chapter meetings per year where CEUs are offered. Members earn CEUs for personally attending local chapter meetings and other preapproved live events. CEUs are not given to members who attend meetings via teleconference or to those who view or listen to recorded versions of chapter meetings or events. Members earn one CEU per hour of cod-ing-related education at a local chapter meeting. Local chap-ters may also award CEUs for seminars and review classes.To see your local chapter’s scheduled events and approved lo-cal chapter-awarded CEUs, go to the member’s area at www.

aapc.com.

Take Advantage of Other AAPC Offerings to Earn CEUsAAPC provides many other opportunities for obtaining CEUs. Some of these opportunities are offered at low or no cost and include:

• Workshops – Classroom-style, local seminars are given by skilled presenters on a variety of coding topics.

• Webinars – Interactive online events provide information on current topics.

• On-demand Events – Timesaving recorded events available as online broadcasts or downloadable podcasts include presentation slides and question-and-answer transcripts.

• National/Regional Conferences – Signature AAPC events provide educational breakout sessions and keynote presenters.

• Code-A-Round – Real-world redacted operative notes are bundled by specialty. Each bundle contains five operative notes, earning one CEU.

Look for Continuing Ed OpportunitiesHigher learning enables medical coders to uphold a higher standard and advance their careers.

AAPCCA

By Lynn Keaton Cockrell, CPC, CPC-H, CPC-I, CEMC

Creating EducationalUniqueness Standards


AAPCCA Handbook Corner

Handbook Quick Tip:

Know Chapter Officer Attendance Requirements

By Brenda Edwards, CPC, CPMA, CPC-I, CEMC

When a chapter member accepts the role of a lo-cal chapter officer, it’s important to be familiar with the AAPC Local Chapter Handbook. Chapter 4, section 1.5, addresses officer attendance at local chapter meetings.

If an officer is unable to attend a local chapter meeting, it’s his or her responsibility to contact the other officers prior to the meeting. Advance notification helps to ensure a meeting free of con-fusion and delays. It also shows respect to your fellow officers and to the members attending the meeting.

• Coding Edge – Online test yourself exercises from articles in each issue offer an opportunity for 12 free CEUs per year. CEUs earned from Coding Edge are counted based on the issue date, not the date of completion.

• In-service Education – A block of index numbers for recurrent in-services can be requested by submitting specific information to AAPC.

Looking for more CEU opportunities? Consider writing articles or post-secondary education teaching/instruction. Vendors often offer CEUs through publications, subscriptions, and seminars. Other orga-nizations may offer them as well. For example, the Centers for Medi-care & Medicaid Services (CMS) offers CEUs through its CMS Learn-ing Network and CMS National Provider Conference Calls. Since cer-tificates of attendance are not provided for CMS National Provider Conference Calls, the emailed confirmation and call description serve as proof of participation.

Lynn Keaton-Cockrell, CPC, CPC-H, CPC-I, CEMC, is a member of the AAPCCA Board of Directors, the AAPC Ethics Committee, and the Cahaba Physician Outreach and Education Advisory Committee for Tenn. She is president of LCA Medical Consult-ing and a PMCC trainer and director of health information management for Hickman Community Hospital, St. Thomas Health Network. She is the education officer of the Columbia, Tenn. local chapter.

Have you started ICD-10 Training?

Due to the clinical nature of ICD-10-CM, a strong understanding of anatomy and pathophysiology will be required. AAPC’s online ICD-10 Anatomy and Pathophysiology training covers body areas and systems for common conditions in 14 different modules. This self-paced curriculum blends online multimedia presentations with downloadable manuals and evaluation quizzes to ensure comprehension. It offers the information and CEUs you need at an affordable price.

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16 AAPC Coding Edge

ApprenticeICD-10 Roadmap

By Rhonda Buckholtz, CPC, CPMA, CPC-I, and Donna L. Stewart, CPC, CPC-H, CPC-P, CPC-I

Help ICD Make People CountBrush up on anatomy and pathophysiology (A&P) to code ICD-10 effectively.

When you hear the term International Classification of Dis-eases (ICD), what comes to mind? Do you view ICD as a method of communicating a patient’s diagnosis to an in-

surance carrier to receive payment; or do you like to think of ICD-9-CM codes as magical number combinations that unlock national and local coverage determinations and medical necessity edits? Per-haps you’re consumed with the thought of transitioning from ICD-9 to ICD-10, and wondering why something that has been working for so many years has to change. Some of you may be asking, “What’s the big deal about ICD?” An internationally endorsed classification facilitates storage, re-trieval, analysis, and interpretation of data. Standardized classifica-tion permits data comparison within populations over time and be-tween populations at the same point in time. It also allows for na-tionally consistent data. In short, ICD is a big deal because it makes people count.

Understanding A&P Is CriticalAs you make the transition from ICD-9 to ICD-10, explore ways you can help make people count. You might, for example, work to-ward gaining a better understanding of A&P. This is an important first step because for you to assign codes effectively and accurate-ly in ICD-10, you’ll need a higher level of understanding of disease processes. Consider the following examples of how A&P knowledge is neces-sary in making people count:Example 1:Myocardial infarction (MI) or acute myocardial infarction (AMI) is an interruption of blood supply to a part of the heart that causes

heart cells to die. It is commonly due to occlusion of a coronary ar-tery following the rupture of a vulnerable atherosclerotic plaque, which is an unstable collection of lipids and white blood cells (espe-cially macrophages) in the wall of an artery. The resulting ischemia and oxygen shortage, if left untreated, can cause damage or death of myocardium.The ICD-10-CM code range for MI is I21.01–I22.9. To code MI in ICD-10-CM, the following is necessary:

• Heart wall involved• Initial or subsequent• ST elevation myocardial infarction (STEMI) or non-ST

elevation myocardial infarction (NSTEMI)Transmural is associated with atherosclerosis involving a major cor-onary artery. It can be subclassified into anterior, posterior, or infe-rior. Transmural infarcts extend through the whole thickness of the heart muscle and are usually a result of complete occlusion of the ar-ea’s blood supply. Subendocardial involves a small area in the subendocardial wall of the left ventricle, ventricular septum, or papillary muscles. Subendo-cardial infarcts are thought to be a result of locally decreased blood supply, possibly from a narrowing of the coronary arteries. The sub-endocardial area is farthest from the heart’s blood supply and is more susceptible to this type of pathology.Clinically, an MI can be further subclassified into a STEMI versus an NSTEMI based on electrocardiogram (ECG) changes. The 12-lead ECG is used to classify MI patients into one of three groups:

WHO Saw the Need for a Diagnosis Classification SystemTo understand the full impact of ICD, you must first under-stand the history of the World Health Organization (WHO).

WHO is one of the original agencies of the United Nations. Its objective “is the attainment by all people of the highest possi-ble level of health.”

According to WHO, “To make people count, we first need to be able to count people.” That is what WHO did when it published ICD; it created a medical classification system that allows for counting, tracking and research of diseases, injuries, symp-toms, reasons for encounters, factors influencing health sta-

tus, and external causes of disease and death, such as acci-dents.

ICD information is used to:

• Study diseases

• Develop preventive measures

• Manage health care allocation of resources

• Measure outcomes

• Monitor and research diseases

ICD-10 CodingS06.0x1A Concussion with loss of consciousness of 30 minutes or less initial encounter

G44.311 Acute post traumatic headache intractable

M54.2 Cervicalgia

M99.01 Segmental and somatic dysfunction of cervical region

W20.8xxA Struck by falling object (accidentally) initial encounter

Y93.g3 Activity, cooking and baking

Y92.010 Place of occurrence, house, single family, kitchen

ActivityIn ICD-10 the activity of the patient needs to be documented. An activity code is only used once at the initial encounter.

External CauseThe falling cabinet is what caused the injuries. Description of the cause is required.

7th CharacterInjury codes require a 7th character extender that identi�es the encounter. Documen-tation must be clear so that the correct extender can be applied.

LocationDocumentation needs to include the location of the patient at the time of injury or other condition. In ICD-10 the details include the actual room of the house the patient was in when the injury occurred.

Applied Speci�city: ConcussionFor a concussion documentation needs to include if the patient su ered loss of consciousness.

Relief or No ReliefIntractable vs. non-intractable are an inherent part of the ICD-10 code for headaches and documentation needs to be clear for the appropriate code to be assigned.

Acute vs. ChronicDocumentation of the patient’s condition must include acute or chronic to assign the most appropriate ICD-10 code.

S: Mrs. Finley presents today after having a new cabinet fall on her last week, su�ering a concussion, as well as some cervicalgia. She was cooking dinner at the home she shares with her husband. She did not seek treatment at that time. She states that the people that put in the cabinet in her kitchen missed the stud by about two inches. Her husband, who was home with her at the time, told her she was “out cold” for about two minutes. The patient continues to have cephalgias since it happened, primarily occipital, extending up into the bilateral occipital and parietal regions. The headaches come on suddenly, last for long periods of time, and occur every day. They are not relieved by Advil. She denies any vision changes, any taste changes, any smell changes. The patient has a marked amount of tenderness across the superior trapezius.

O: Her weight is 188 which is up 5 pounds from last time, blood pressure 144/82, pulse rate 70, respirations are 18. She has full strength in her upper extremities. DTRs in the biceps and triceps are adequate. Grip strength is adequate. Heart rate is regular and lungs are clear.

A: 1. Status post concussion with acute persistent headaches 2. Cervicalgia 3. Dorsal somatic dysfunction

P: The plan at this time is to send her for physical therapy, three times a week for four weeks for cervical soft tissue muscle massage, as well as upper dorsal. We’ll recheck her in one month, sooner if needed.

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Documentation dissection highlighting the increased specificity required to code for ICD-10-CM:

One of the largest problems following the October 1, 2013 implementation date for ICD-10 will be documentation insufficient to support the specificity required for the new ICD-10 code sets. We believe a behavioral change in documentation habits for most providers will be necessary—and now is the time to start preparing.

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18 AAPC Coding Edge

It is important for coders to have a good understanding of what is

involved in the COPD disease process to properly assign a code

in ICD-10-CM. Having a strong foundation of A&P will help.

ICD-10 Road Map

1. Those with ST segment elevation or new bundle branch block

2. Those with ST segment depression or T wave inversion (suspicious for ischemia)

3. Those with a so-called nondiagnostic or normal ECG (However, a normal ECG does not rule out AMI.)

To assign a code to this example, you need to be knowledgeable in anatomy and have a good un-derstanding of the disease process.Example 2:Let’s take a look at another example found in ICD-10-CM:Chronic obstructive pulmonary disease (COPD) is one of the most common lung dis-eases, and refers to chronic bronchitis and em-physema paired together as co-existing diseas-es. You may also hear it referred to as chronic obstructive lung disease (COLD), chronic ob-structive airway disease (COAD), chronic air-flow limitation (CAL), or chronic obstructive respiratory disease (CORD).Lung damage and inflammation in the large airways can result in chronic bronchitis. Chron-ic bronchitis is defined clinically as a cough with sputum production on most days for three months during a year, for two consecutive years. The wet cough is a result of an increased number and size of goblet cells and mucous glands in the lung airways, which causes airway narrowing. Microscopically, there is infiltration of the air-way walls with inflammatory cells. This is fol-lowed by scarring and remodeling, which thick-ens the walls and results in airway narrowing.Lung damage and inflammation of the air sacs, or alveoli, can result in emphysema. Emphyse-ma is an enlargement of the air spaces distal to the terminal bronchioles, with destruction of their walls. The destruction of air space walls re-duces the surface area available for the exchange of oxygen and carbon dioxide during breath-ing. It also reduces the elasticity of the lung it-self, which results in a loss of support for the em-bedded airways of the lung. These airways are more likely to collapse, causing further limita-tion to airflow.

The ICD-10-CM code range for COPD is J44.0-J44.9. To code COPD in ICD-10-CM, you must be able to answer the following:

• Does acute lower respiratory infection exist?

• Does acute exacerbation exist?According to ICD-10-CM Official Guidelines for Coding and Reporting, an acute exacerbation is a worsening or a decompensation of a chron-ic condition. An acute exacerbation is not equiv-alent to an infection superimposed on a chron-ic condition; however, an exacerbation may be triggered by an infection. It is important for cod-ers to have a good understanding of what is in-volved in the COPD disease process to properly assign a code in ICD-10-CM. Having A&P ex-pertise will help.

ICD-10-CM A&PUpdating your A&P skills is just one way you can prepare for ICD-10-CM implementation and ensure proper use of the new code set. Your ultimate goal should be to use the code set as it was intended, by assigning codes to the highest level of specificity so meaningful data can be ex-changed.To help you build a strong A&P foundation to accommodate ICD-10’s greater specificity, AAPC is offering “ICD-10 Anatomy and Patho-physiology” training, which covers all body sys-tems in 14 modules. You can select individual modules or take the complete training course. Find out more at www.aapc.com/icd-10/anatomy-

pathophysiology.aspx.

Rhonda Buckholtz, CPC, CPMA, CPC-I, is vice president of ICD-10 training and education at AAPC.

Donna L. Stewart, CPC, CPC-H, CPC-P, CPC-I, is manager of compliance at Children’s Hospital of the King’s Daughters in Norfolk, Va. and is owner and president of Professional Impact, Inc., a Virginia Beach based consulting company. She has nearly 30 years of experience in health care coding, auditing,

consulting, compliance, and billing. As PMCC instructor, Stewart provides training for coders, auditors, physicians, and staff mem-bers, and conducts classes and seminars in coding, E/M auditing, reimbursement, compliance, and documentation. She is very active with AAPC nationally and through her local chapter. Stewart was rec-ognized as the AAPC Networker of the Year for 2004.

To discuss this article or topic, go to

www.aapc.com

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20 AAPC Coding Edge

Feature Professional

By Michelle A. Green, MPS, RHIA, CPC, FAHIMA

Filter Out Bad ESRD CodingUse severity, condition, classification, and sequencing to help clean up your claims.

End stage renal disease (ESRD) is the most severe form of chronic kidney disease (CKD). At this stage, kidney function is so impaired that patients must receive regular hemodialysis to remove waste from the body, or undergo a kidney transplant.ESRD patients undergo hemodialysis in an outpatient dialysis fa-cility several times each week where waste products (e.g., creati-nine, urea) are removed from their blood. Acutely ill ESRD pa-tients may require inpatient admission during which hemodialysis is performed,and sometimes a kidney transplant is performed. In contrast, many CKD patients perform their own peritoneal dialy-sis at home or elsewhere because the patient’s peritoneum is used as a membrane for the exchange of fluids and dissolved substances (e.g., electrolytes, urea, glucose) in their blood.ICD-9-CM classifies CKD to category 585. A required fourth dig-it indicates the severity of the condition, as defined by the patient’s glomerular filtration rate (GFR):

585.1 Stage I: GFR > 90 mL/min/1.73 m2

585.2 Stage II: GFR 60-89 mL/min/1.73 m2

585.3 Stage III: GFR 30-59 mL/min/1.73 m2

585.4 Stage IV: GFR 15-29 mL/min/1.73 m2

585.5 Stage V: GFR < 15 mL/min/1.73 m2

585.6 End stage renal disease (ESRD): GFR < 15 mL/min/1.73 m2, and the patient is on dialysis or undergoing kidney transplant

According to the ICD-9-CM Official Guidelines for Coding and Re-porting, if a patient is documented as having both CKD and ESRD, report only the ESRD (585.6).

Sequence ESRD Diagnoses with CarePatients with ESRD (and other stages of CKD) often suffer other se-rious conditions, such as hypertension, diabetes mellitus, anemia, and transplant complications. Be careful to sequence these condi-tions properly when assigning ICD-9-CM codes. To illustrate this point, consider the following:Diabetes: Section I.C.3.a.4 of the ICD-9-CM guidelines specifies, “When assigning codes for diabetes and its associated conditions, the code(s) from the category 250 must be sequenced before the codes for the associated conditions … Assign as many codes from catego-ry 250 as needed to identify all of the associated conditions that the patient has.”For example, a patient with type II diabetic ESRD presents to his physician’s office for a follow-up visit. There is no indication that the diabetes is uncontrolled. The diagnosis codes are assigned and se-quenced in the following order:

250.40 Diabetes with renal manifestations; type II or unspecified type, not stated as uncontrolled

585.6

Anemia: Section I.C.4.a.1 of the ICD-9-CM guidelines states, “When assigning code 285.21, Anemia in chronic kidney disease, it is also necessary to assign a code from category 585, Chronic kidney disease, to indicate the stage of chronic kidney disease.” Whichever condition is the reason for the encounter should be sequenced first.For example, if anemia is the reason for an encounter with a patient diagnosed with “anemia in end stage renal disease,” report:

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22 AAPC Coding Edge

285.21 Anemia in chronic kidney disease

585.6

Hypertensive CKD: Section I.C.7.a.3 of the ICD-9-CM guidelines instructs, “Assign codes from category 403, Hypertensive chronic kidney disease, when conditions classified to categories 585 or code 587 are present with hypertension ... The appropriate code from cat-egory 585, Chronic kidney disease, should be used as a secondary code with a code from category 403 to identify the stage of chron-ic kidney disease.” When reported with 585.6, subcategory code 403.0 should include fifth-digit “1” (e.g., 403.01 Hypertensive chron-ic kidney disease, malignant, with chronic kidney disease stage V or end stage renal disease). Again, the reason for the encounter should be se-quenced first. Kidney transplant complications: Section I.C.17.f.2.b of the ICD-9-CM guidelines specifies, “A transplant complication code is only assigned if the complication affects the function of the transplanted organ. Two codes are required to fully describe a transplant compli-cation, the appropriate code from subcategory 996.8 and a second-ary code that identifies the complication.”Patients who undergo a kidney transplant still may have CKD be-cause the kidneys are not restored to full function. Do not assume that a patient who has had a kidney transplant and CKD developed the CKD because of the transplant. Select the code to report the stage of CKD and V42.0 Organ or tissue replaced by transplant; kid-ney to report kidney transplant status. Per the ICD-9-CM guide-lines (I.C.17.f.2.a), “If the documentation is unclear as to whether the patient has a complication of the transplant, query the provider.”

Dialysis Coding Varies by LocationProper physician coding for dialysis services related to ESRD de-pends on place of service (POS).Inpatient ESRD services, including all evaluation and management (E/M) services related to the patient’s renal disease, are reported us-ing CPT® codes 90935-90937. According to CPT®, “Code 90935 is reported if only one evaluation of the patient is required related to that hemodialysis procedure. Code 90937 is reported when patient re-evaluation(s) is required during a hemodialysis procedure.”Outpatient ESRD services may be reported per month (defined by CPT® as 30 days), according to the patient’s age:

• Younger than 2 years of age – 90951-90953• 2-11 years of age – 90954-90956• 12-19 years of age – 90957-90959• 20 years of age or older – 90960-90962

These CPT® codes also account for the number of face-to-face phy-sician visits with the patient each month. For example, a 10-year-old patient who meets face to face with the physician two times in a month would be reported as 90955 End-stage renal disease (ESRD) related services monthly, for patients 2-11 years of age to include moni-toring for the adequacy of nutrition, assessment of growth and develop-ment, and counseling of parents; with 2-3 face-to-face physician visits

per month. If the same patient meets with the physician five times in the same month, the correct code would be 90954 End-stage renal disease (ESRD) related services monthly, for patients 2-11 years of age to include monitoring for the adequacy of nutrition, assessment of growth and development, and counseling of parents; with 4 or more face-to-face physician visits per month. Per CPT® guidelines, 90951-90962 may be reported only once per month, and “include establishment of a dialyzing cycle, outpatient evaluation and management of the dialysis visits, telephone calls, and patient management during the dialysis provided during a full month.”In-home ESRD services also are reported per month, according to patient age:

• Younger than 2 years of age – 90963• 2- 11 years of age – 90964• 12-19 years of age – 90965• 20 years of age or older – 90966

Partial Month Services Call for Different CodingIf the patient has had a complete assessment visit “and services are provided over a period of less than a month, 90951-90962 may be used according to the number of visits performed,” per CPT®. For instance, a 30-year-old patient receives face-to-face ESRD-related services, including a complete evaluation, on a single occasion. In this case, report 90962 End-stage renal disease (ESRD) related servic-es monthly, for patients 20 years of age and older; with 1 face-to-face phy-sician visit per month.By contrast, “per day” codes 90967-90970 describe ESRD services for less than a full month of service when provided to:

• Partial month outpatients, where there was one or more face-to-face visits without the complete assessment

• Partial month home dialysis patients • Transient patients• A patient hospitalized before a complete assessment was

furnished• Patients for whom dialysis was stopped due to recovery, death,

or kidney transplantPer day codes 90967-90970 also are age-specific:

• Younger than 2 years of age – 90967• 2-11 years of age – 90968• 12-19 years of age – 90969• 20 years of age or older – 90970

For example, a 15-year-old outpatient receives one day of ESRD-re-lated services for dialysis without a complete evaluation. There are no other encounters in the 30-day period. This service would be report-ed as 90969 End-stage renal disease (ESRD) related service for dialysis less than a full month of service, per day; for patients 12-19 years of age.

Feature


Feature

Patients with ESRD

(and other stages of

CKD) often suffer other

serious conditions …

Be careful to sequence

these conditions properly

when assigning ICD-9-CM

codes.

ESRD Services May Mix and MatchWhen circumstances warrant, you may combine ESRD-related service codes (e.g., if a home dialysis patient or outpatient dialysis patient is admitted for a time as an inpatient). In CPT® the American Medical Association (AMA) provides the following example: “Home ESRD-related services are initiated on July 1 for a 57-yr-old male. On July 11, he is admitted to the hospital as an inpatient and is discharged on July 27 … 90970 is reported for each day outside of inpatient hospitalization (30 days/month less 17 days/hospitalization = 13 days).” Hemo-dialysis procedures rendered during the hospitalization (July 11-27) are reported as appropri-ate using 90935-90937.

Medicare Facility Billing Relies on Composite PaymentsFacility charges for ESRD-related services provided to Medicare beneficiaries are paid based on a prospective payment system known as the basic case-mix adjusted composite payment system, which covers the costs of dialysis treatment and certain routine drugs, laboratory tests, and supplies furnished at home or in a facility. Other items and services (e.g., injectable drugs such as erythropoietin (EPO), non-routine laboratory tests) are not included in the compos-ite rate, and they are billed separately to Medicare. For more information, see the Centers for Medicare & Medicaid Services (CMS) website at www.cms.gov/ESRDPayment.

Michelle A. Green, MPS, RHIA, CPC, FAHIMA, is a State University of New York (SUNY) distinguished professor at Alfred State College, teaching coding and reimbursement courses since 1984. She is also a published author of Del-mar Cengage Learning’s textbooks: 3-2-1 Code It ! , Understanding Health Insurance, and Essentials of Health Informa-tion Management.

24 AAPC Coding Edge

Feature Expert

Chemodenervation Injections: Do Modifiers Apply?Reporting 64613 and 64614 to Medicare payers for single/unilat-eral injections isn’t entirely clear.

As of April 1, Medicare considers CPT® codes 64613 Chemode-nervation of muscle(s); neck muscle(s) (e.g., for spasmodic torti-collis, spasmodic dysphonia) and 64614 Chemodenervation of

muscle(s); extremity(s) and/or trunk muscle(s) (e.g., for dystonia, cere-bral palsy, multiple sclerosis) to be ineligible for a 150 percent pay-ment adjustment when reported with modifier 50 Bilateral proce-dure because “RVUs are already based on the procedures being per-formed as a bilateral procedure.” In Coding Edge’s coverage of this news (June 2011, page 8), we recommended appending modifier 52 Reduced services for Medicare carriers when either 64613 or 64614 is performed unilaterally.Several readers questioned our advice to append modifier 52 for sin-gle/unilateral injections, which led us to examine the issue more closely. As it turns out, how to report 64613 and 64614 to Medicare payers for single/unilateral injections isn’t entirely clear. For a better explanation, we turned to Marvel J. Hammer, RN, CPC, CCS-P, PCS, ACS-PM, CHCO, president of MJH Consulting.

Hammer writes:The initial bilateral indicator phrase “RVUs are already based on the procedure being performed as a bilateral procedure” could be inter-preted to mean that when a physician injects only one unilateral ex-tremity, the practice needs to append modifier 52 to indicate the re-duced services. The following Medicare frequently asked question (FAQ) supports this interpretation:Q: “Should modifier 52 (reduced services) be used for a procedure

that is defined as bilateral by the CPT®/HCPCS code when the provider was able to perform only one side of the procedure or service?

A: Yes. It is appropriate to use modifier 52 for reduced services on ‘bilateral’ procedures, unless the specific CPT®/HCPCS de-scription contains language indicating that the test, procedure, or service is ‘unilateral or bilateral.’ For CPT®/HCPCS codes that describe ‘unilateral or bilateral’ language in their respec-tive descriptions, use of the 52 modifier is not necessary since the test, procedure, or service can be performed and paid at the same rate for ‘unilateral or bilateral’ services rendered.”

Medicare’s “2” bilateral indicator also states, however, that the RVUs are based on a bilateral procedure because:a. the code descriptor specifically states that the procedure is bi-

lateral;b. the code descriptor states that the procedure may be performed

either unilaterally or bilaterally; orc. the procedure is usually performed as a bilateral procedure.


Note that the CPT® code descriptors for 64613 and 64614 use the singular/plural form (e.g., Chemodenervation of muscle(s); neck muscle(s) and Chemodenervation of muscle(s); extremity(s) and/or trunk muscle(s)), rather than stating “bilateral.” Because these codes are not exclusively defined as bilateral, it seems that modifier 52 would not be necessary for injection(s) at a unilateral neck or ex-tremity site. CPT® has consistently taken the stance that the chemodenervation codes should be reported with a maximum of 1 unit of service, rep-resenting all injections, whether for multiple injections in a single ex-tremity or multiple injections into multiple extremities. For exam-ple, the December 2008 CPT® Assistant instructs:“… To further clarify, the language of the descriptor code for 64614 allows for chemodenervation of muscles of single or multiple extrem-ities, as well as muscles of the trunk, if performed. This code should be reported only one time for chemodenervation of any of these ar-eas within a single session … as stated in the April 2001 issue of CPT® Assistant (Volume 11, Issue 4), codes 64612-64614 should be report-ed only one time per procedure, even if multiple injections are per-formed in sites along a single muscle or if several muscles of single or multiple extremities are injected.”I was able to find one Medicare contractor who has made changes to its local coverage determination (LCD), which agrees in part with the American Medical Association’s (AMA’s) recommendations. National Government Services (NGS) LCD Article A46164 states:CPT® code 64613 is described as “Chemodenervation of muscle(s);

neck muscle(s) (eg. for spasmodic torticollis, spasmodic dysphonia).” Only one (1) unit of service should be submitted for injections of the neck, no matter how many sites are injected.CPT® code 64614 is described as “Chemodenervation of muscle(s); extremity(s) and/or trunk muscle(s) (eg, for dystonia, cerebral pal-sy, multiple sclerosis). Only one (1) unit of service should be sub-mitted for injections of the trunk and/or extremities, no matter how many sites are injected.Interestingly, the Centers for Medicare & Medicaid Services (CMS) did not change the bilateral status indicator for 64612 Chemode-nervation of muscle(s); muscle(s) innervated by facial nerve as it did for 64613 and 64614 (although this still diverges from the AMA’s stance). The 2011 third quarter Medicare medically unlikely edit (MUE) valuations for these codes are: 64612 – 2 units, 64613 – 1 unit, and 64614 – 1 unit.In my opinion, the intention was not to have the reduced services modifier apply if only one side of the neck or one extremity is inject-ed; or, for that matter, if two extremities (e.g., right leg and right arm) are injected, but are not contralateral. Report a single unit of service, without modifiers, in every case. My recommendation is to check your Medicare LCDs and corre-sponding articles for current policies and upcoming revisions. Just to be on the safe side, check with your Medicare contractor for its stance on compliant reporting of chemodenervation injections into a sin-gle limb or single side of the neck. It really seems to be a gray area.

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26 AAPC Coding Edge

Professional

By Kristine Cuddy, CPC, CIMC

Cover Story

Don’t Overlook Care Plan OversightHome health and monthly care services deserve reimbursement, but will require you to report care plan oversight correctly.

Coding for care plan oversight (CPO) often is overlooked. This is a mistake: CPO services deserve reimbursement, and coding and doc-umentation requirements, although exacting, are worth the effort. Here are the guidelines you need to make the most of CPO billing.

Be Aware of CPO TypesThere are two types of CPO services: 1.) certification and recertifica-tion of home health agency (HHA) services; and 2.) monthly CPO.Certification and recertification of HHA services are reported with:

G0179 Physician re-certification for Medicare-covered home health services under a home health plan of care (patient not present), including contacts with home health agency and review of reports of patient status required by physicians to affirm the initial imple-mentation of the plan of care that meets patient’s needs, per re-certification period

G0180 Physician certification for Medicare-covered home health services under a home health plan of care (patient not present), including contacts with home health agency and review of reports of patient status required by physicians to affirm the initial implementation of the plan of care that meets patient’s needs, per certification period

These codes are reported when the physician receives the Centers for Medicare & Medicaid Services’ (CMS’) 485 form from the HHA, requesting approval for services to be provided over a 60-day peri-od. The physician reviews the HHA 485 form, makes any necessary changes, additions, and deletions, and signs off on the form. The completed 485 form is typically faxed back to the HHA by the phy-sician’s office. Remember to keep the 485 form on file (the best place to keep it is in the patient’s medical record).

Know CMS 485 Form RequirementsThe Medicare Claims Processing Manual, chapter 12, section 180, provides the following specific requirements regarding the CMS 485 form:

• Physician must sign CMS 485 form and do all of the following: ❏ Review initial or subsequent reports of patient status ❏ Review the patient’s responses to the OASIS assessment

instrument

❏ Contact the HHA to ascertain the initial implementation plan of care (faxing the signed 485 form suffices)

❏ Document in the patient’s record (keeping the 485 form in the record supports this)

The initial certification of HHA services for the first 60 days of home health care is reported with G0180. Subsequent certification of HHA services for each additional 60 days of home health care is reported using G0179.For example, Mrs. Smith has gone home after knee surgery. Dr. John is her primary care provider. Dr. John has seen Mrs. Smith for a face-to-face evaluation and management (E/M) during the last six months. Dr. John received a fax from a HHA requesting review and authorization of home health services for the first 60 days dur-ing Mrs. Smith’s recovery time. Dr. John reviews the hospital dis-charge records from the surgeon and any other relevant medical re-cords; reviews the CMS 485 HHA form that contains the modes of care, services, medications, etc.; makes any changes necessary; fills out any designated areas; signs the form; faxes it back to the HHA; and, files the form in Mrs. Smith’s medical record. Dr. John advises billing staff of the service and G0180 is billed to Mrs. Smith’s Medi-care carrier. The free text/additional information field of the CMS 1500 form should contain the beginning and end dates of certification/re-certification. This is documented by entering, for instance, “B = 01/01/2011 E = 03/01/2011.” The “To” and “From” dates of ser-vice on the CMS 1500 form should be the date the doctor signed the CMS 485 form.

Document Face-to-Face Encounter for Home Health Certification As required by the Affordable Care Act, CMS designated new re-quirements for home health certification via the 2011 Home Health Prospective Payment System final rule, as follows:

• Documentation regarding these face-to-face encounters must be present on certifications (on the CMS 485 form itself) for patients with starts of care on and after Jan. 1, 2011.

• As part of the certification form, or as an addendum to it, the physician must document when he or she, or allowed


Cover Story

non-physician practitioner (NPP) saw the patient, and document how the patient’s clinical condition as seen during that encounter supports the patient’s homebound status and need for skilled services.

• The face-to-face encounter must occur within the 90 days prior to the start of home health care, or within the 30 days after the start of care.

• In situations when a physician orders home health care for the patient based on a new condition that was not evident during a visit within the 90 days prior to start of care, the certifying physician or NPP must see the patient within 30 days after admission. Specifically: • If the certifying physician or NPP had not seen the

patient in the 90 days prior to the start of care, a visit within 30 days of start of care would be required.

• If a patient saw the certifying physician or NPP within the 90 days prior to start of care, another encounter is necessary if the patient’s condition had changed to the extent that accepted standards of practice would preclude the physician from ordering services without the physician or an NPP first examining the patient.

This means any 2011 certifications or recertifications your pro-vider has already signed and billed for must have a signed dat-ed addendum indicating the date they saw the patient and how their clinical condition supports skilled service in a homebound/hospice status.The remaining instructions may be found in MedLearn Mat-ters article SE1038 at: www.cms.gov/MLNMattersArticles/downloads/

SE1038.pdf.

Turn to G0181, G0182 for Monthly OversightMonthly CPO services are reported using:

G0181 Physician supervision of a patient receiving Medicare-covered services provided by a participating home health agency (patient not present) requiring complex and multidisciplinary

Certification / Recertification

Care Plan Oversight

28 AAPC Coding Edge

Cover Story

care modalities involving regular physician development and/or revision of care plans, review of subsequent reports of patient status, review of laboratory and other studies, communication (including telephone calls) with other health care professionals involved in the patient’s care, integration of new information into the medical treatment plan and/or adjustment of medical therapy, within a calendar month, 30 minutes or more

G0182 Physician supervision of a patient under a Medicare-approved hos-pice (patient not present) requiring complex and multidisciplinary care modalities involving regular physician development and/or revision of care plans, review of subsequent reports of patient status, review of laboratory and other studies, communication (including telephone calls) with other health care professionals involved in the patient’s care, integration of new information into the medical treatment plan and/or adjustment of medical therapy, within a calendar month, 30 minutes or more

These codes are reported when the physician provides month-long services that fall under CPO definitions, such as:

• Development of care• Revision to care plan• Review of patient reports

• Lab reviews• Diagnostic test reviews• Communication with other health care professionals• Integration of new information into treatment plan• Adjustment of medial therapy• Other (define)

G0181 is used to report monthly CPO services for HHA patients. This information is best documented on a spreadsheet, with rows la-beled as in the aforementioned bullets.G0182 is used to report monthly CPO services for hospice patients. Documentation should be completed the same as for G0181. The billing physician cannot be a hospice physician and attach modifi-er GV Attending physician not employed or paid under arrangement by patient’s hospice provider. The attending physician cannot be em-ployed by or paid under arrangement of the patient’s hospice provid-er. Implied in G0182 is the expectation that the physician has coor-dinated an aspect of the patient’s care with the hospice during the month for which CPO services were billed. For example, Dr. John continues as Mrs. Smith’s primary care pro-vider. During the next year, Dr. Smith is providing complex conti-

CARE PLAN OVERSIGHT LOG SHEET

Patient Name: Agency Name:

Date (month/day/year)

Total Time with

Patient

Development of Care

Revision to Care Plan

Review of Patient Reports

Lab Reviews

Diagnostic Test Reviews

Communication with Other Health Care Professionals

Integration of New Information into Treatment Plan

Adjustment of Medial Therapy

Other (Define)

Physician Signature: Total Time: Form must be signed by physician!

CPO LOG SHEET 11/20/98

A grid form such as this allows the physician to document his time for an entire month for each service he performs.

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Cover Story

CPO ChecklistBefore billing any CPO service, ensure that:

✓ The patient has received Medicare covered home health services

✓ The physician has devoted 30 minutes or more to supervision of the patient’s care in a given month

✓ The physician has furnished a service that was face to face with the patient at least once during the six-month period before the month for which CPO is first billed

✓ The physician does not have a significant financial or contractual relationship with the HHA or hospice

✓ The physician is the one and only attending physician to bill for CPO for the patient during a calendar month

✓ The physician documents in the patient’s medical record that the CPO services are unrelated to surgery (If billing for CPO services during a postoperative period)

✓ The physician has the provider number of the patient’s HHA

✓ The physician who bills CPO is the same physician who signed the CMS 485 form and personally furnished the services

✓ The physician is not billing Medicare end stage renal disease (ESRD) capitation payment and CPO for the same beneficiary during the same month

✓ It’s not a rural health clinic (RHC) (Certain Medicare carriers do not allow RHCs to bill CPO. If your physician practices in a RHC, verify prior to billing.)

The following services do not count as billable CPO services:

• Getting and/or filing the chart, dialing the phone, or time on hold (these activities do not require work or meaningfully contribute to the treatment plan of the illness/injury)

• Informal consultations with health professionals not involved in the patient’s care

• Initial interpretation or review of study results that were ordered during, or associated with, a face-to-face encounter

• Low intensity services included as part of other E/M services

• Preparation or processing of claims

• Staff time (e.g., time the nurse, nurse practitioner, physician’s assistant, clinical nurse specialist, or other staff spends getting or filing charts, calling HHAs or patients, etc.)

• Telephoning, or transmitting, prescriptions in to pharmacists (not considered a physician service and does not require a physician to perform)

• Travel time

nuity of care for Mrs. Smith (who is now receiving hospice care), re-quiring him to provide multiple non-face-to-face services (as indi-cated in the aforementioned bullets) where he is not providing cer-tification or recertification services during this time. Dr. John doc-uments his time on a grid form (such as the log sheet shown on the previous page) for an entire month for each service he performs. Af-

ter the month has ended, he signs and dates the grid form, files it into the patient chart, and advises his billing staff to report G0182.Normally, Medicare requires the provider number of the HHA agen-cy or hospice to be entered on the claim form. There is no place on the claim form for that number and providers are relieved of having to report it until further notice by CMS; however, the number must be kept as part of either the CMS 485 form for certifications and re-certifications, or as part of the patient’s monthly time-tracking doc-ument the physician uses.

Don’t Just Accept DenialsIf your physician bills Medicare for CPO and receives a denial stating that the patient was not seen face to face during the six months prior to billing CPO, there may be some valid reasons. Read further before writing off any charges. For example:

• The patient may have started receiving Medicare benefits during the prior six months, and there was no opportunity for a face-to-face service under Medicare, but there is a visit under another carrier:• According to WPS Medicare, “One of the requirements for

CPO services is that the physician providing the CPO had a face-to-face evaluation and management (E/M) services within the previous six months of beginning CPO. Since Medicare did not have the patient enrolled at the time of the previous visit, the Common Working File (CWF) will not contain evidence of the previous patient encounter. The claim denial is correct. The provider should request a redetermination providing documentation of the previous face-to-face encounter. Medicare can then allow the CPO when the service meets all the requirements.” (www.

wpsmedicare.com/part_b/resources/provider_types/careplan-

oversight-qanda.shtml)• The patient was previously enrolled in a Medicare Advantage

plan and had not yet had a face-to-face visit since going onto Medicare hospice coverage:• Also according to WPS Medicare, “One of the

requirements for CPO services is that the physician providing the CPO had a face-to-face evaluation and management (E/M) services within the previous six months of beginning CPO. Medicare Advantage entities do not report individual services into the Common Working File (CWF). A patient returns to Medicare fee-for-service upon electing hospice coverage. The claim denial is correct. The provider should request a redetermination providing documentation of the previous face-to-face encounter. Medicare can then allow the CPO when the service meets all the requirements.” (www.wpsmedicare.com/part_b/resources/

provider_types/careplan-oversight-qanda.shtml)

Kristine Cuddy, CPC, CIMC, has more than 20 year’s experience in the medical field. She is a compliance analyst for Michigan State University’s HealthTeam, and provides independent consulting services. She has served as president and sec-retary of her local AAPC chapter, is a member of WPS Medicare Part B Provider Outreach and Education Advisory Group, and is an instructor at Lansing Commu-nity College.

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32 AAPC Coding Edge

Added Edge

More Money, Educated, & Valuable

By G. John Verhovshek, MA, CPC

The results of the AAPC 2011 Salary Survey are in, and the news is good. With nearly 12,000 responses, the greatest number so far, it’s clear that salaries are climbing upward for coders, and coders who have invested in their education and professional development are reaping the greatest rewards. A growing demand for skilled cod-ers in a tough economic and health reimbursement environment is a testament to the value these professionals bring to employers.

Coders Take a Variety of Career PathsCoders have the luxury of taking a number of career paths, espe-cially now with health reform, electronic health records (EHRs), and ICD-10 entering the scene, so it’s no surprise they define them-selves in a variety of ways.As in years past, Chart A shows that the majority of respondents (38 percent) describe their job as “coder.” Other common job titles are “biller/collector” (9.3 percent), “charge entry” (7.5 percent), and “billing manager” (6.5 percent). Approximately 62 percent of respondents said they work primarily in physician-based coding; 10 percent are hospital coders; and 16 percent said they do both types of coding.Respondents work in every specialty, with the greatest number in family practice (10.3 percent) and internal medicine (5.7 percent). Others include emergency medicine (5.2 percent), general surgery (4.5 percent), and obstetrics/gynecology (4.3 percent)—rounding out the top five specialties.As for long-term career goals, about half (42.4 percent) said coding and billing is what they want to do long-term, as shown in Chart B. Just over 20 percent are looking forward to a career in auditing (This number has trended upward in recent years.); 12.3 percent want to be practice managers; and 9.5 percent cite compliance as the area in which respondents would most like to work.

Chart A: Which of the following best matches your current responsibility?

Chart B: Which of the following best represents your long-term career goal?

Members break the $40K barrier

Coder

Management

Other

Biller/Collector

Charge Entry

Auditor

Educator

Consultant

Claims Adjudicator

Clinical

38%

20%

12%

9%

8%

7%

2% 1%

Coding and Billing

Auditing

Management

Compliance

Other

Health Information Technology

Clinical

42.4%

20.4%

12.3%

9.5%

7.4%

6.6%1.6%


Added Edge

Coders Earn Their KeepThis year, we asked respondents to estimate if they saved their prac-tices or facilities annually through better documentation, more ac-curate coding, or improved billing procedures. Half estimate they saved their practices or facilities at least $10,000-$50,000 in the pre-vious year. One-third said they believe they saved $50,000 or more. Results indicate that hiring skilled, certified coders is a wise invest-ment for employers. Among the highest-earning responders (those earning $50,000 or more annually), greater than 90 percent said they saved their practices or facilities $50,000 or more annually.

What Do You Make?Overall results show that wages have risen in the past 12 months. As shown in Chart C, the average wage in 2011 for a Certified Profes-sional Coder (CPC®) was approximately $46,800 (up $1,400 from last year); and, for the first time since we’ve conducted a salary sur-vey, more than half of all respondents—including those without a CPC®—reported earnings of greater than $40,000 annually.

Almost 80 percent of respondents were CPCs®, and more than 55 percent said that certification was a requirement of their employ-ment (up from 52 percent last year). Approximately 25 percent of re-spondents hold certifications beyond the CPC® or CPC-A®.Individuals with advanced certifications earned more this past year on average. For example, those holding both a CPC® and Certified Professionals Coder-Hospital Outpatient (CPC-H®) certification earned over $54,700 annually (an increase of nearly $4,000 since 2010). Respondents with a Certified Professionals Coder-Instructor (CPC-I®) certification did even better, pulling in over $76,000 per year (up over $6,000 from last year).

Coders Tend to Be More EducatedSurvey respondents are better educated than the general U.S. pop-ulation. More than 88 percent of our respondents have had at least some college, and more than half have either taken technical training or have earned a college degree. Whereas only 55 percent of Amer-icans have had some college, according to 2010 U.S. Census data. Among all respondents, those with a bachelor’s degree out-earned those with only a high school diploma by a dramatic $10,000 per year ($41,802 vs. $51,825).More than half of the respondents (51.6 percent) said they have 10 years or more experience in their specialties; and more than 20 per-cent have 20 years or more experience. Roughly one-third of respon-dents (31 percent), however, have five years or fewer in their field.More than half of those with 20 years or more experience earned in excess of $50,000 per year. Slightly more than a quarter (27 percent) of respondents with 10 years experience earned $50,000 or more per year. Among those with five years experience, only 14 percent fell into this high-earning group. Wages are affected by other factors, as well:

• Coders in states with a higher cost of living were paid more than those in states with a lower cost of living. To cite one example, workers in California (with a cost of living index of over 150, where 100 is “average”) earned in excess of $57,700, while workers in Kentucky (with a cost of living index of 85) earned just under $37,500.

• Just over 45 percent of respondents work in urban areas, 36 percent work in suburban areas, and 18 percent work in rural areas. This mixture has been roughly consistent for the past several years. Among all respondents, urban workers earned approximately $47,500 on average, or approximately $2,000 dollars more per year than their suburban counterparts. Average pay in rural areas (where cost of living usually is lowest) was $40,300 annually.

• Only 5 percent of respondents worked fewer than 30 hours per week. The majority (58.2 percent) worked full-time (between 31 and 40 hours per week). More than one-third of respondents (37.1 percent) said they worked in excess of 40 hours per week.

Chart C: Average annual salary based on all respondents.

Answer Options Response

Less than $20,000 1%

$20,000-$25,000 4%

$25,001-$30,000 8%

$30,001-$35,000 15%

$35,001-$40,000 19%

$40,001-$45,000 14%

$45,001-$50,000 11%

$50,001-$55,000 8%

$55,001-$60,000 5%

$60,001-$65,000 4%

$65,001-$70,000 3%

$70,001-$75,000 2%

$75,001-$80,000 1%

$80,001-$85,000 1%

$85,001-$90,000 1%

$90,001-$100,000 1%

$100,001-$151,000+ 2%

34 AAPC Coding Edge

Added Edge

Not surprisingly, those working the longest hours also pulled in the larg-est paychecks: Just over 43 percent of respondents who worked in excess of 40 hours per week earned $50,000 or more, while fewer than 18 per-cent of those working 31-40 hours per week earned in excess of $50,000 per year.

• As shown in Chart D, coders continue to enjoy benefits that are becoming less common in other work sectors.

• As shown in Chart E on the next page, those working at a solo practice make less, on average, than those at small to medium provider groups. Only 101 survey respondents described themselves as “self-employed.” These high earners were among the most experienced and educated of all respondents.

Consolidation has become more common in health care in recent years, but the percentage of respondents working in solo practices, as well as in small, medium, and large group practices, has remained consistent. (For example, in both 2010 and 2011, 20.2 percent of respondents said they work in a large group practice.) Fewer than 20 percent of respon-dents said their practice has been involved in, or has considered, a merg-er or acquisition.

Chart D: Employer-provided benefits remain high.

Answer Options Response

Health insurance 92.7%

Dental insurance 80.2%

Vision insurance 64.9%

Disability insurance 61.3%

Life insurance 75.7%

Internal continuing education 35.5%

Paid continuing education 46.4%

Paid professional association dues 43.7%

Paid holidays 89.6%

Paid sick leave 82.0%

Paid vacation 91.9%

Retirement plan (401K, etc.) 84.2%

Tuition reimbursement 42.5%

Fitness program 19.6%

Gym reimbursement 9.5%

Other 3.6%

Pacific$53,334

Mountain$44,330

East North Central $42,434

New England $47,852

East South Central$39,830

South Atlantic$43,906

West South Central$43,919

Mid Atlantic$47,508

West North Central $41,848

Average Salaries by Region


Added Edge

Chart E: Average wage of respondents shows disparity among group size.

Solo practice $39,920

Small (2-10 providers) group $41,700

Medium (11-49 providers) group $41,200

Large (50+ providers group $44,900

Hospital (outpatient) $43,800

Hospital (inpatient) $47,700

Self-employed $69,150

Unemployment Lower than National AverageThe “Great Recession” officially ended June 2009, but the so-called “jobless recovery” has continued to affect hiring and employment. Unemployment in the United States has fluctuated around 9-10 percent for much of the past year. Coders are slightly less effected with an 8.7 percent unemployment rate, according to our survey. Of these, more than 75 percent said they are new to the business of med-ical billing, and are trying to get their first job.

Respondents who started a new job in the past 12 months said net-working (both within and outside AAPC) was the No. 1 way they found work—so be sure to attend local chapter meetings. You might just find your next job there! Job hunters should also check AAPC’s Medical Coding Jobs board (www.aapc.com/medical-coding-

jobs/), which posts thousands of positions nationwide.

G.J. Verhovshek, MA, CPC, is managing editor at AAPC.

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Timely Medicare Revalidation MayPrevent Deactivation or RevocationAct now to keep your billing privileges and avoid disruption of reimbursement.

Revalidation is the process by which the Centers for Medicare & Medicaid Services (CMS) requires a provider to certify her accura-cy or her existing enrollment information with Medicare. Comply-ing with revalidation requests within the specified time is necessary to avoid loss of billing privileges and disruption of Medicare reim-bursements.

Revalidate when RequestedMedicare requires revalidation every five years, but also may perform “off cycle” revalidations (including possible site visits). Off cycle re-validations may be triggered by:

• Random checks• Health care fraud problems• National initiatives• Complaints, or other reasons that cause CMS to question the

provider’s/supplier’s compliance with Medicare enrollment requirements

CMS is actively targeting for revalidation:• Providers who are not registered in the Medicare Provider

Enrollment, Chain, and Ownership System (PECOS) • Providers who have not updated their enrollment within the

last five years• Providers located in historically high-risk areas for Medicare

fraud• Providers who do not receive electronic funds transfer (EFT)

paymentsNote: Do not submit a revalidation application unless a Medicare contractor contacts you. Upon receipt of the notification, you must respond within 60 days of the request (see 42 Code of Federal Reg-ulations (CFR), chapter IV, §424.515 at http://edocket.access.gpo.gov/

cfr_2010/octqtr/pdf/42cfr424.515.pdf).

Certain Changes Require RevalidationCertain enrollment information changes, such as a change in prac-tice location or a change in the “special payments and correspon-dence” address on file with Medicare, may affect timely compli-ance with revalidation requests. Medicare sends its revalidation let-ters and other correspondence to the “special payment and corre-spondence address” on file with Medicare. If a correspondence is re-turned to Medicare marked “undeliverable,” or if a provider does not respond to Medicare’s request within the time specified in the no-tice, the provider’s billing privileges will be deactivated or revoked.

Deactivation vs. RevocationDeactivation of a provider’s Medicare billing privileges is distinct from revocation of Medicare enrollment and billing privileges. Deactivation is minor. Medicare may deactivate a provider’s Medi-care billing privileges if the provider does not report a change to the information supplied on the enrollment application within a spec-ified time. Significant changes include, but are not limited to:

• Ownership or control (report within 30 days)• Practice location (report within 30 days)• Billing services (report within 90 days)• “Special payments and correspondence” address (report

within 90 days)You can find a complete list of reportable changes at www.cms.gov/

By Delly E. Parham, AS, CPC

Professional


Featured Coder

MedicareProviderSupEnroll/Downloads/internet-basedPECOSFAQ.pdf (view “Q12”). Additional information can be found in CFR, §424.520(b) and §424.550(b) (search online to find “Code of Federal Regulations, Section 424”).A provider’s billing privileges will remain deactivated until he or she either:

• submits a new enrollment application (CMS 855); or • when deemed appropriate, at a minimum, recertifies that

the enrollment information currently on file with Medicare is correct. (The provider or supplier must meet all current Medicare requirements at the time of reactivation, and be prepared to submit a valid Medicare claim. Best practice is to contact your Medicare carrier for guidance.)

Claims for services from the date of deactivation to the date of reac-tivation may not be payable. Revocation is far more serious. Revocation occurs for noncompli-ance, misconduct, felonies, falsifying information, and other such conditions set forth in 42 CFR, §424.535 (http://edocket.access.gpo.

gov/cfr_2010/octqtr/pdf/42cfr424.535.pdf).Revocation has devastating consequences for providers. According to CFR §424.535(a)(6)(i):

• Medicare payments will be halted until the corrective action plan or request for reconsideration process is complete.

• The provider is barred from participating in the Medicare program from the effective date of the revocation until the end of the re-enrollment bar. What’s worse, a provider may not receive the notice until months later, unaware that he or she will be forced to forfeit income earned between the time the letter was mailed and when it was received.

• Any provider agreement in effect at the time of revocation is terminated effective with the date of revocation.

• The re-enrollment bar is a minimum of one year, but not greater than three years, depending on the severity of the basis for revocation. (The re-enrollment bar may be waived if a provider is revoked based on failure to submit an application fee, or a hardship exception is requested with an enrollment application upon revalidation.)

• A provider or organization may be placed on the “List of Excluded Individuals and Entities.” (This will affect contracting with other government programs.)

Challenging RevocationAfter receiving a revocation letter, a provider has 30 days to submit a corrective action plan and 60 days to submit a request for reconsider-ation. Providers should submit both documents at the same time be-cause the 60-day time frame for a request for reconsideration starts the day the revocation letter is dated.A corrective action plan includes:

• a signed letter explaining why revocation occurred, and what efforts will be used to meet compliance;

• a signed statement by the provider swearing to the accuracy of the supplied information; and

• a new CMS Form 855.If a corrective action plan is accepted, the revocation is rescinded and the provider’s billing rights are restored as of either the date the pro-vider became compliant or the revocation’s original effective date. There is no appeal for a denied corrective action plan.A reconsideration request may be done in some situations, such as when a provider changed location or Medicare did not update the provider’s address change in its system. A request for reconsideration contends that revocation was erroneous.

Prevent or Minimize Deactivation or RevocationMedicare requires all changes to your practice be reported within 30 or 90 days to keep your enrollment information current. Make sure to report these changes (see www.cms.gov/MedicarePro viderSupEnroll/

downloads/GettingStarted.pdf) within the specified time.To complete a revalidation application or to report a change, the pro-vider/supplier may use either the Internet-based PECOS or a tradi-tional paper application. Regardless of which method is used, the provider must complete the following:The applicable CMS-855 Enrollment Application form:

• 855B: Medicare Enrollment Application for Clinics, Group Practices, and Certain Other Suppliers;

• 855I: Medicare Enrollment Application for Physicians and Non-Physician Practitioners

• 855S: Medicare Enrollment Application for Durable Medical Equipment, Prosthetics; Orthotics, and Supplies (DMEPOS) Suppliers

Claims for services from the date of deactivation

to the date of reactivation may not be payable.

(continued on p. 42)

38 AAPC Coding Edge

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ApprenticesAaronNoel, CPC-AAbbiAnnSwitzer,CPC-A, CPC-H-AAgnieszkaAntosz-Avila, CPC-AAimeeLaRaeSager,CPC-A, CPC-H-AAimeeMckenzie, CPC-AAlessaBerdugo, CPC-AAlexanderLondon, CPC-AAlexandriaAskew, CPC-AAliceJones, CPC-AAliceMurphy, CPC-AAliciaShields, CPC-AAlisaMayo, CPC-AAllaKatsovsky, CPC-AAlyssaMarieYoung, CPC-H-AAmandaBalkevitch, CPC-AAmandaClaxton, CPC-AAmandaHardaway, CPC-AAmandaJuliano, CPC-AAmandaLeaThomas, CPC-AAmandaLittlefeatherFrances,CPC-A, CPC-H-AAmandaMarieDavenport, CPC-AAmandaMeeker, CPC-AAmandaNSisk, CPC-AAmandaRaeFuller,CPC-A, CPC-H-AAmandoCaiyod, CPC-AAmberNewton, CPC-AAmberNicoleGlidden, CPC-AAmelaArnautovic, CPC-AAmritaOjha, CPC-AAmyBraden, CPC-AAmyCherry, CPC-AAmyElizabethTroup, CPC-AAmyHradnansky, CPC-AAmyKlemsz, CPC-AAmyLynnDammerman, CPC-AAmyRenaeScott, CPC-AAmySandberg, CPC-AAmyTrecker, CPCAmyTwombly, CPC-AAmyWatson, CPC-AAmyZahorik, CPC-AAnaCarolinaBuchele, CPC-AAnandaMaidaGoldstein, CPC-AAndreaK.Davis, CPC-AAndreaRiccio, CPC-AAndreaRodriguez, CPC-AAndrettaDavis, CPC-H-AAndrewCarrick, CPC-AAneekaLambert, CPC-AAngelaAcra, CPC-AAngelaDavis, CPC-AAngelaFrost, CPC-AAAngelaMartin, CPC-AAngelaMitchell, CPC-AAngelaRedeker, CPC-AAngelaThrasher, CPC-AAngeliaKayKelley, CPC-AAngeloAllen, CPC-AAngieJoanou, CPC-AAngieShaffer, CPC-AAnginettaMoniqueMcDade, CPC-AAnitaGuerrero, CPC-H-AAnitaMCoffman, CPC-A

AnjaliKhatu, CPC-AAnnDriver, CPC-AAnnGaidos-Morgan, CPC-AAnnaEland, CPC-H-AAnnaMichelleSifton, CPC-AAnnamarieBunel, CPC-AAnneBallentine, CPC-AAnneBest, CPC-AAnneBrownMullendore, CPC-AAnneKegley, CPC-AAnneMiller, CPC-AAnne-MarieHarry, CPC-AAnnieAdkins, CPC-AAnntonettLeniseHarris, CPC-AAntonioVazquez, CPC-AAnzaAli, CPC-AAprilJeanMartin,CPC-A, CPC-H-AAprilLynnShinkie, CPC-AAprilStowers, CPC-AAraceliLinn, CPC-AArenSchneider, CPC-AArounmalyChanthavong-Urbanek, CPC-AAshleyBeckman, CPC-AAshleyBetancourt, CPC-AAshleyEAustin, CPC-AAshleyMGartner-Fajardo, CPC-AAshleyParnell, CPC-AAshontaSHargrove, CPC-AAtonyaCole, CPC-AAubreyLarsen, CPC-AAudreyDickens, CPC-AAyoOwoso, CPC-H-ABambiRichardson, CPC-ABarbAPrice, CPC-ABarbaraAWhitley, CPC-ABarbaraBarajas, CPC-ABarbaraBarnard, CPC-ABarbaraCisler, CPC-ABarbaraElaineJackson, CPC-ABarbaraGriffis, CPC-ABarbaraPencille, CPC-ABarbaraSessWeaver, CPC-ABarbaraTomoletz, CPC-ABeckiHaling, CPC-ABeckyDawnDalton, CPC-ABeckyHadden, CPC-ABeckyJoCaley, CPC-ABeckyLLorenz, CPC-ABeckyLynnPowell, CPC-ABeckyNeumann, CPC-ABeckyWork, CPC-ABerniceMaryHoose, CPC-ABethKedra, CPC-ABethMooney, CPC-ABethOzolins, CPC-ABethanyEvans, CPC-ABetsyBosques, CPC-ABettyDellemann, CPC-ABillieHamilton, CPC-ABillyJoeSherman, CPC-ABlancaQuintero, CPC-ABonnieLuong, CPC-ABrachaLKroll, CPC-ABrandiWallace, CPC-ABrandyScoggins, CPC-ABreaBeltran, CPC-ABrendaDevries, CPC-ABrendaKJohnson, CPC-ABrendaPhelan, CPC-ABrendaRahn, CPC-ABrendaRooney, CPC-ABrianA.Moore, CPC-ABriondaAshleyButler, CPC-ABritianyLynnGoggans, CPC-ABrittanyAmberDolce, CPC-ABrittneyWilliams, CPC-ABrittnyFConnell, CPC-ABrookeMattingly, CPC-ABruceStreukens, CPC-ABrucestanKirtisWorrell, CPC-ACaitlinGoulden, CPC-ACaitlynKeen, CPC-ACandyHenn, CPC-H-ACaraMiaWilliams, CPC-ACarlaBetts, CPC-A

CarlaHoskins, CPC-ACarmelaECoffey, CPC-ACarmenMullins, CPC-ACarolAnnRoss, CPC-ACarolNeumann, CPC-ACarolStorch, CPC-ACaroleStewart, CPC-ACarolynAllen, CPC-H-ACarolynGHeath, CPC-ACarolynLerum, CPC-ACarolynSinger, CPC-ACarrieAllen, CPC-ACarrieAnnConaway, CPC-ACarrieJaneYates, CPC-ACarrieLeeBrooks, CPC-ACarrieLeeBrooks, CPC-ACasandraAnnShuman, CPC-ACasieScruggs, CPC-ACassandraBurnett, CPC-ACatherineHill, CPC-ACatherineInzer, CPC-ACatherineRotramel, CPC-ACathyCloney, CPC-ACathyLacey, CPC-ACathyLynnOsbun, CPC-ACattenaFontenot, CPC-ACeasarTriaDatu, CPC-A,CPC-H-ACeceliaWaldo, CPC-ACelesteBrinker, CPC-ACeliDominguezCaballer, CPC-AChakaMonetCarthen, CPC-H-AChanelRomeroApodaca, CPC-AChariWheeler, CPC-ACharmaineNicolaSteele, CPC-AChasityYork, CPC-AChelseaHolliman, CPC-AChelseaTestement, CPC-ACherryPhillips, CPC-ACherylD.Verham, CPC-ACherylGlunt, CPC-ACherylHallahan, CPC-ACherylLSpencer, CPC-ACherylOdquist, CPC-AChikaRichins, CPC-AChristainClarke, CPC-AChristeneLPimple, CPC-AChristieJohnson, CPC-AChristieStaples, CPC-AChristinBuss, CPC-AChristinaApplin, CPC-AChristinaCiccanti, CPC-AChristinaEBoarts, CPC-AChristinaHerrera, CPC-AChristinaJohnson, CPC-AChristinaMJackson, CPC-AChristinaMullins, CPC-AChristinaMyers, CPC-AChristinaShake, CPC-AChristineDolan, CPC-AChristineElizabethBain, CPC-AChristineKlimonek, CPC-AChristineLeeShriner, CPC-AChristineMuhlestein, CPC-AChristineTennant, CPC-AChristopherLevel, CPC-AChristyHill, CPC-AChristyL.Avedisian, CPC-AChristyLeeYoutzy,CPC-A, CPC-H-AChrysaSweitzer, CPC-AChrystalNicoleLondon, CPC-ACindiDuran, CPC-ACindraCaldwell, CPC-ACindraHaynes, CPC-ACindyArroyo, CPC-ACindyJeanineFlameng, CPC-ACindyReneeDavis, CPC-ACindySturm, CPC-AClareceJones, CPC-AClaudiaHWilliams, CPC-AClaudiaMenta, CPC-H-ACleytaEggiman, CPC-AColeElu, CPC-H-AColetteMElam, CPC-AColetteM.Anderson, CPC-AColinSMessiah, CPC-A

ColleenAnnJohnson, CPC-AColleenJordan, CPC-AColleenMichelleHamilton, CPC-AColleenMorris, CPC-ACConnieFlores, CPC-AConnieLeBlanc, CPC-ACoreyMoore, CPC-ACorinaCarbajal, CPC-ACourtneyDelaineKendrick, CPC-ACourtneyMichelleRaper, CPC-ACraigBurris, CPC-ACraigJones, CPC-ACristinaHidalgo, CPC-ACrystalFrancesRamirez, CPC-ACrystalG.Islam, CPC-ACynthiaABerry, CPC-ACynthiaAGrota, CPC-ACynthiaCowan, CPC-ACynthiaGarcia, CPC-ACynthiaGregory, CPC-ACynthiaJGemma, CPC-ACynthiaJSturgell, CPC-ACynthiaKPowell, CPC-ACynthiaLPowell, CPC-ADaisyGraf, CPC-ADaisyJeanDavidson, CPC-ADanaAspray, CPC-ADanaMarieRepp, CPC-ADanaSeibers, CPC-ADanaStephenson, CPC-ADanetteL.McNulty, CPC-ADanielleFord, CPC-H-ADaniellePreviti, CPC-ADanyelleWinston, CPC-ADaphneHimes, CPC-H-ADarcieWheeler, CPC-ADarleneChauvette, CPC-ADarlenePeay, CPC-ADarrenCarangi, CPC-HDarrizetteDavis, CPC-ADarylRaven, CPC-ADavaMcNally, CPC-ADaveFrench, CPC-ADavidAbt, CPC-ADavidJakubuwski, CPC-ADavidSilver, CPC-ADawnEdwards, CPC-ADawnHobbs, CPC-ADawnPhister, CPC-ADawnaWilliams, CPC-ADeannaHagy, CPC-H-ADeannaLynnFrank, CPC-ADeAnneClark, CPC-ADebbieAnnMeade, CPC-ADebbieJames, CPC-ADebbieWodarczyk, CPC-ADebbieYoungberg, CPC-ADeborahChimenti, CPC-ADeborahDano, CPC-ADeborahElaineEthridge, CPC-ADeborahFortune, CPC-ADeborahKrenta, CPC-H-ADeborahSmallcomb, CPC-ADeborahZoeyMarshRamos, CPC-ADebraAnnVendetta, CPC-ADebraGeist, CPC-ADebraGraham, CPC-ADebraLynnFry, CPC-ADebraLynnWilmesherr, CPC-ADebraLynneDavis, CPC-A,CPC-H-ADebraRoth, CPC-ADebraSSimonis, CPC-ADebraTrail, CPC-ADebraWilkinson, CPC-ADeiaLourencoPizzagoni, CPC-ADeniseCronin, CPC-ADeniseGhioni, CPC-ADennisRRoll, CPC-ADestinyGibson, CPC-ADevaStarCoder, CPC-ADevinDenaMcLean, CPC-ADevinWazirMahamed, CPC-ADeVonneChapel, CPC-ADeZondriaDavenport, CPC-ADianaCarolThompson, CPC-A

Newly Credentialed Members

40 AAPC Coding Edge


DianaJMurphy, CPC-ADianaNeidlinger, CPC-ADianaPeters, CPC-ADianeCatania, CPC-ADianeDuncan, CPC-ADianeGailBassetti, CPC-ADianeHite, CPC-ADianeL.Lewis, CPC-ADianeSchmitt, CPC-ADoloresKilpatrick, CPC-ADominiqueJones, CPC-H-ADominiqueSIglesia, CPC-ADonVincentFernandez, CPC-ADonishaCollier, CPC-ADonnaFranco, CPC-ADorothyGore, CPC-ADorothyHaney, CPC-H-ADorothyRagan, CPC-ADwaylaMWalker, CPC-AEdwardJames, CPC-AElenaRMendez, CPC-AElesiaFlorenceHeard, CPC-AElisaBeatrizChao, CPC-AElizabethAlexander, CPC-AElizabethAnnWilliams, CPC-AElizabethAronson, CPC-AElizabethC.Fiebert, CPC-AElizabethGraham, CPC-AElizabethJKarver, CPC-AElizabethLeoraMarion, CPC-AElizabethMariePhelps, CPC-AElizabethSchrock, CPC-AElizabethSumma, CPC-AElizabethWright, CPC-AElizatbethMcCool, CPC-AElleDunbar, CPC-AEllenHines,CPC-A, CPC-H-AEllenSandifer, CPC-AElonieJackson, CPC-AEmilySWoolaver, CPC-AEricWillis, CPC-AEricaLynetteJones, CPC-AEricaNovak, CPC-AEricaShawnRubino, CPC-AErinAbernathy, CPC-AEstephanyRomero, CPC-AEstherAdepetu, CPC-AEugeniaGembutis, CPC-AEvelynMCzifra, CPC-AEvinGunter, CPC-AFernandoHurtado, CPC-AFrancesBishop, CPC-AFranciscaOrihuela, CPC-AFreddiePorter, CPC-AGaleAnnBenner, CPC-AGaryPounds, CPC-AGayleAnneParent, CPC-AGayleAsuncion, CPC-AGenevaBlasing, CPC-AGeniMarieKeiser, CPC-AGeorgeneScata, CPC-AGeorginaMarieHallDaniels, CPC-AGeriEdwards, CPC-AGinaHaw, CPC-AGindyWomack, CPC-AGiulianaAllumbaugh, CPC-AGladysLWilson, CPC-AGladysSanders, CPC-AGlenOrmanSeibert, CPC-AGoldieLevey, CPC-AGraceRussell, CPC-AGregBackus, CPC-AGregPalmer, CPC-H-AGregorySwitala, CPC-AGuyBaxman, CPC-AGwendolineNichols, CPC-AGwendolynParks, CPC-AHafawatiHamzah, CPC-AHalWatson, CPC-AHannaCho, CPC-AHannahPatrick, CPC-AHayleeHunsaker, CPC-AHeatherBoatright, CPC-A

HeatherCaldwell, CPC-AHeatherChitwood, CPC-AHeatherJenkins, CPC-AHeatherLynnMcCurdy, CPC-AHeatherMichelleCrowe, CPC-AHeatherSergeant, CPC-AHeatherW.Saunders, CPC-AHeidiNowe, CPC-AHelenaCarolRush, CPC-AHenrietteMercer, CPC-AHenryD’Silva, CPC-AHienTran, CPC-H-AHilaryPas, CPC-AHollyGayleDavis, CPC-AHollyMiller, CPC-AHollyReed, CPC-AHollySteck, CPC-AIanManson, CPC-AIlianaReyes, CPC-AIrinaSothern, CPC-AIshwaryaSankaran, CPC-H-AIsmaelRamirezMendez, CPC-AItzelMarianaPena, CPC-AJaclynForest, CPC-AJacquelineFCain, CPC-AJacquelineKester, CPC-AJacquelineMiller, CPC-AJacquelineNeidig, CPC-AJacquelinePianka, CPC-AJagodaMiljkovic, CPC-AJaimeLynnCamp, CPC-AJamesNormanHader, CPC-P-AJamieAcosta, CPC-AJamieGlass, CPC-AJamieJackson, CPC-AJamieJetton, CPC-AJamieReneeForrest-Breedlove, CPC-AJamieWaller, CPC-AJamie-CindaKelley, CPC-AJaneE.Wagner, CPC-AJanequaReneWilliams, CPC-AJanetBird, CPC-AJanetCase, CPC-AJanetLeeCain, CPC-AJanetteMaryelleBrock, CPC-AJaniceCarrollGarkovich, CPC-AJaniceKirk, CPC-AJaniceKuntzman, CPC-AJaniceLQuinn, CPC-AJaniceMarieGunsch, CPC-AJaritzaLopez, CPC-AJasmineJackson, CPC-AJasonEddinger, CPC-AJasonRobertPfeiffer, CPC-AJeanArlauckas, CPC-AJeanMarren,CPC-A, CPC-H-AJeanneA.Chapman, CPC-AJeanneParham, CPC-AJeanneStapleton, CPC-AJeannetteBrant, CPC-AJeannineLevesque, CPC-AJeannineRaciti, CPC-AJearleanJones, CPC-AJeneriaAmiama, CPC-AJenniferBertetto, CPC-AJenniferCarney, CPC-AJenniferDaniels, CPC-AJenniferDay-Barsness, CPC-AJenniferEdmisten, CPC-AJenniferHenderson, CPC-AJenniferLLicursi, CPC-AJenniferLMiller,CPC-A, CPC-H-AJenniferLewis, CPC-AJenniferLynneVanIngen, CPC-AJenniferMicheleBell, CPC-AJenniferMichelleCosta, CPC-AJenniferNeal, CPC-AJenniferPopadak, CPC-AJenniferRReeves, CPC-AJenniferRich, CPC-AJenniferRich, CPC-AJenniferSantos, CPC-AJenniferTHand, CPC-A

JenniferYoung, CPC-AJenniferZara, CPC-AJenoGuyMallari, CPC-AJereDonnaFerrell, CPC-AJessicaBlakeman, CPC-AJessicaBurrell, CPC-AJessicaDFifield, CPC-AJessicaDanielleConroy,CPC-A, CPC-H-AJessicaImber, CPC-AJessicaKing-Melvin, CPC-AJessicaLynnSuess, CPC-AJessicaNCampbell, CPC-AJessicaRKasch, CPC-AJessicaRoss, CPC-AJessicaShock, CPC-H-AJessicaTravis, CPC-AJessicaWebster, CPC-AJillABarth, CPC-AJillClark, CPC-H-AJillDuncan, CPC-AJillThomas, CPC-AJillianBazemore, CPC-AJoanBertsch,CPC-A, CPC-H-AJJoanLemaire, CPC-AJoanMcGovern, CPC-AJoanP.Langdon, CPC-AJoAnnBartlett, CPC-AJoAnnIvens, CPC-AJoannWiser, CPC-AJoannaMorrison, CPC-AJoannaSwiski, CPC-AJoannaYvetteCardwell, CPC-H-AJo-AnneBrown, CPC-AJodiAllen, CPC-H-AJodiMerritt, CPC-AJodieMurphy, CPC-AJodyMarieSundvold, CPC-AJohannaCamacho, CPC-AJohnLanier, CPC-AJohnMihelic, CPC-AJohnP.Tillman, CPC-AJohnRMcCarthy, CPC-AJohnathanLeonard, CPC-AJoniCortez, CPC-AJosephAnthonyPage, CPC-AJosephineWashington, CPC-AJoyceCastonguay, CPC-AJoyceE.Daugherty, CPC-AJudithSChisholm, CPC-AJudyGardner, CPC-AJudyThibeault, CPC-AJulieBoston, CPC-AJulieCoburn, CPC-AJulieGreen, CPC-AJulieKendallHughes, CPC-AJulieLeQuire, CPC-AJulieMassengill, CPC-AJulieMoll, CPC-AJulieO’lone, CPC-AJulieParks, CPC-AJulieRBarton, CPC-AJulieWigginton, CPC-AJulieAnnStyles, CPC-AJuneGwinn, CPC-AKaciL.Hoffman, CPC-AKalvinUlloa, CPC-AKaraAlexandriaEly, CPC-AKaraArzigian, CPC-AKarenDuncan, CPC-AKarenGruber, CPC-AKarenKier, CPC-AKarenLBillings, CPC-AKarenLGrice, CPC-AKarenOetjen, CPC-AKarenWalker, CPC-AKarenZimmermann, CPC-AKaridaPenrod, CPC-AKarinHill, CPC-AKarlaGale, CPC-AKarstenGäertner, CPC-AKarySmith, CPC-AKatharineStocke, CPC-AKatherineGaines, CPC-A

KatherineLKerr, CPC-AKatherineLeake, CPC-AKatherineLynnGarcia, CPC-AKatherineMMasten, CPC-AKatherineSchoonhoven,CPC-A, CPC-H-AKatherineTidabackMangold, CPC-AKatherineYork, CPC-AKathieKohout, CPC-AKathleenLawlor, CPC-AKathleenMartin-Berry, CPC-AKathleenShedlock, CPC-AKathleenShelleyHowe, CPC-AKathleenWilson, CPC-AKathyAllebach, CPC-AKathyBOakley, CPC-AKathyBlakeslee, CPC-AKathyBreedlove, CPC-AKathyBrunelli, CPC-AKathyCunningham, CPC-AKathySFribley, CPC-AKathyStadie, CPC-AKathyYancey, CPC-AKatieGarcia, CPC-AKatyaLuciaPena, CPC-AKavithaKarnam, CPC-AKaylaDuenas, CPC-AKaylaWright, CPC-AKeelyJHollen, CPC-AKeitaCAdkins, CPC-AKelleyCrawford, CPC-AKelleyLWest, CPC-AKelleyShort, CPC-AKellyColman, CPC-AKellyHorton, CPC-AKellyHuffman, CPC-AKellyLRobinson, CPC-AKellyPierce, CPC-AKellySavard, CPC-AKellyShake, CPC-AKellyWilson, CPC-AKellyannRysedorph, CPC-AKelseyDanielleWhitney, CPC-AKendellMortimer, CPC-AKennethMostJr, CPC-AKennethWord, CPC-AKeriAWambold, CPC-AKerrellTurner, CPC-HKerriFoster, CPC-AKerriSkaggs, CPC-AKevinCollins, CPC-H-AKevinLerch, CPC-AKevinMatheny, CPC-AKiaPandy, CPC-AKimberleeM.Green, CPC-AKimberleyBoyd, CPC-AKimberlyAnnSeery, CPC-AKimberlyBill, CPC-AKimberlyDautzenberg, CPC-AKimberlyDavis, CPC-AKimberlyDawnBrooks, CPC-AKimberlyFoote, CPC-AKimberlyLoranSapp, CPC-AKimberlyMichelleLandrum, CPC-AKimberlyReneeDoty, CPC-AKimberlyRogers, CPC-AKimberlySmith, CPC-A,CPC-H-AKirkAnthonyRodriguez, CPC-AKirstenCope, CPC-AKirstenTrimmer, CPC-AKishaRivers, CPC-AKrisStoeffler, CPC-AKristenA.Hasasneh-Polzner, CPC-AKristenBarnes, CPC-H-AKristenDuke, CPC-AKristenMayHuey, CPC-AKristenSchwarz, CPC-AKristiWatson, CPC-AKristinJenks, CPC-AKristinaM.Engle, CPC-AKristinaReilly, CPC-AKristineEckhardt, CPC-AKristyPage, CPC-AKrystalTait, CPC-A

KrystynaZakoscielny, CPC-AKseniaBrewster, CPC-AKylaHargraves, CPC-AKyleCole, CPC-ALahomaBrasfield, CPC-ALainePoole, CPC-ALakeshaNicoleHampton, CPC-ALanishaQuonetteClapper, CPC-ALarryDButler, CPC-ALashekaKatrinaMorris, CPC-ALatashaJohnson, CPC-ALatonnaSims, CPC-ALauraAxtell, CPC-P-ALauraBerry, CPC-ALauraBishop, CPC-H-ALauraChristensen, CPC-ALauraDeshazo, CPC-ALauraFrost, CPC-ALauraGeimann, CPC-ALauraRBlanton, CPC-ALauraRogers, CPC-ALauraSnyder, CPC-ALauraWolfe, CPC-ALaurenDyer, CPC-ALaurenKHardison, CPC-ALaurenSmith, CPC-ALaurieAnnBloom, CPC-H-ALaurieAnnSnyder, CPC-ALavilaWeckwerth, CPC-ALawrenceAdams, CPC-ALeahRaeEkstrom, CPC-ALeandraTufts, CPC-ALeannaHStupperich, CPC-ALeanneElliott-Sandblom, CPC-ALeilaniSevilla, CPC-ALeslieABertram,CPC-A, CPC-H-ALeslieGilchrest, CPC-ALeslieHathaway, CPC-ALeslieMartin, CPC-ALeslieMassiellRivera, CPC-ALeslieMillward, CPC-ALeslieScottEbbighausen, CPC-ALeslieThomas, CPC-ALetitiaDDickerson, CPC-ALigayaDolar, CPC-ALillianOczykowski, CPC-ALillianWashington, CPC-ALilyNLaGrass, CPC-ALindaJaramillo, CPC-ALindaL.Ambrose, CPC-ALindaLucas, CPC-ALindaRamirez, CPC-ALindaRichard, CPC-H-ALindaSueCrawford, CPC-ALindsayBorn, CPC-ALindsayBraden, CPC-ALindsaySchram, CPC-ALindsayWilson, CPC-ALindseyGerdes, CPC-ALindySchweitzberger, CPC-ALinnitaMLicano, CPC-ALisaBLevin, CPC-ALisaBoisvert, CPC-ALisaCarrington, CPC-ALisaDonovan, CPC-ALisaDozier, CPC-ALisaGlenn, CPC-ALisaGrantham, CPC-ALisaGura, CPC-ALisaHenley, CPC-ALisaKellenNelsen, CPC-ALisaLehman, CPC-ALisaLussier, CPC-ALisaMBristol, CPC-ALisaMcCabe, CPC-ALisaRobbins, CPC-ALisaRodriguez, CPC-ALisaStevens, CPC-ALisaTurbeville, CPC-ALizyThomas, CPC-ALoraClark, CPC-ALoreeAndersonEnglish, CPC-ALorellaJuneMurrow, CPC-A,CPC-H-A



LorettaLeanneMcGilvray, CPC-ALorettaMcClure, CPC-ALoriAlexander, CPC-ALoriBox, CPC-ALoriCook, CPC-ALoriHevia, CPC-ALoriJeanKing,CPC-A, CPC-H-ALoriMiller, CPC-ALoriSkrocki, CPC-ALorraineGarrison, CPC-ALuciaLemus, CPC-ALucyKim, CPC-ALucynaLewinski, CPC-ALuisVega, CPC-ALynellLackey, CPC-ALLynnCooper, CPC-ALynnMIannuzzi, CPC-AMadeleineNorton, CPC-AMadellynArcher, CPC-AMadisonJadeMassey, CPC-AMaggieMarquez, CPC-AMaikeAlford, CPC-AMalgorzataPacheco, CPC-AMan-ChienYu-Wang, CPC-H-AMMarandaGoldsmith, CPC-AMarciNablo, CPC-AMargueriteKHansford, CPC-AMariaBoyd, CPC-AMariaIsabelCampbell, CPC-AMariahWilt, CPC-AMarianCook,CPC-A, CPC-H-AMarianneHadinata, CPC-AMarianneParker,CPC-A, CPC-H-AMaribelBarrios, CPC-AMarieNapolitan, CPC-AMarilynArvelo, CPC-AMMarisaMorton, CPC-AMarissaSmith, CPC-AMarkARenzenbrink,CPC-A, CPC-H-AMarshaHayes, CPC-AMMarshaLaFountain, CPC-AMarshaZach, CPC-AMarthaIreneBajwa, CPC-AMarthaLittlewhirlwind, CPC-AMaryALipphardt, CPC-AMaryA.Wienhold, CPC-AMaryAnnSchultzki, CPC-AMaryBanovetz, CPC-AMaryBethPrintup, CPC-AMaryDuffy, CPC-AMaryDurrer, CPC-AMaryElizabethMoyer, CPC-AMaryFye, CPC-AMaryGemmaSims, CPC-AMaryHand, CPC-AMaryHoagland, CPC-H-AMaryJaneHenderson, CPC-AMaryLSaxon, CPC-AMaryNeuharth, CPC-AMarySavino, CPC-AMarySchmit, CPC-AMarySiefert, CPC-AMarybethMyers, CPC-AMaryellenWammock, CPC-AMateshiaWright, CPC-AMattSaxon, CPC-AMatthewDaoust, CPC-AMaureenWeygandt, CPC-AMaurineHamer, CPC-AMayDous, CPC-AMeganBrianaWithey, CPC-AMeganEUemura, CPC-AMeganMcCann, CPC-AMeganRichardson, CPC-AMeghanDoroha, CPC-AMeghanEliseRogers,CPC-A, CPC-H-AMeladieBrookins,CPC-A, CPC-H-AMelindaDosen, CPC-AMelindaMclane, CPC-AMelissaEJunkins, CPC-AMelissaGoodman, CPC-AMelissaJohnson, CPC-AMelissaMartinez, CPC-AMelissaMast, CPC-AMelissaReyes, CPC-AMelissaRodriguez, CPC-AMelissaRoseKeirns, CPC-AMelissaSuddreth, CPC-AMelissaUnderhill, CPC-AMelissaVanostrand, CPC-AMelodyCoyne, CPC-A

MeoshaLetrellAllen, CPC-AMerciaPowell, CPC-AMeredithFlynn, CPC-AMeredithTekin, CPC-AMeridithGerlach, CPC-AMerrileeLucas, CPC-AMeyaReid, CPC-AMianiKim, CPC-AMichaelMinnis, CPC-AMichaelSchwarz, CPC-AMicheleDreckmanJanssens, CPC-AMicheleFlandreauHoltzhouser, CPC-AMicheleLNickodemus, CPC-AMicheleL.Tussey, CPC-AMicheleLydiaDellipoali, CPC-AMicheleNolan, CPC-AMicheleVics, CPC-AMichelleAnderson, CPC-AMichelleCyr, CPC-AMichelleKawadaDanoff, CPC-AMichelleMcKay, CPC-AMichelleMiller, CPC-AMichelleRaymond, CPC-AMichelleSiems, CPC-AMichelleSolomon, CPC-AMichelleSpears, CPC-AMichelleWhalen, CPC-AMichelleWilliams, CPC-AMilenaMarinova, CPC-AMimilanieSHarris, CPC-AMistyDawnCaster, CPC-AMistyRoss, CPC-AMollyALittle, CPC-AMonaBirdwell, CPC-AMonicaGraceMedrano, CPC-AMonicaMelton, CPC-AMonicaWigen, CPC-AMonicaWilczak, CPC-AMylendeLiseski, CPC-H-AMyrnaRivera, CPC-ANanciMasulis, CPC-ANancyLBrown, CPC-ANancyLParks, CPC-ANancyLaMountain, CPC-ANancyPage, CPC-ANancySloan, CPC-ANancyWSmith, CPC-ANatalieBorokhovsky, CPC-ANatalieSalvatore, CPC-ANatalieZographos, CPC-ANatashaJosephineBanks, CPC-ANatashaLDill, CPC-ANathanThomasGant, CPC-ANereydaVelasquez, CPC-ANicholasWolf, CPC-ANicholeBatchelor, CPC-ANicolaHylton, CPC-ANicoleADailey, CPC-ANicoleAnnFink, CPCNicoleGavin, CPC-ANicoleHarris, CPC-ANicoleReidy, CPC-ANicoleWilson, CPC-ANicoleWyatt, CPC-ANinaReichley, CPC-ANoelleWinn, CPC-ANormaJCarey,CPC-A, CPC-H-AOlenkaCJimenez, CPC-AOlgaSereda, CPC-AOrlandoBatista, CPC-AOttoAviles, CPC-AOyunaBurnell, CPC-APairisHolt-Mason, CPC-APamDecell, CPC-H-APamelaAke, CPC-APamelaCantley, CPC-APamelaHensley, CPC-H-APamelaPalmer, CPC-APamelaYvonneBrown, CPC-APatoshaGreen, CPC-APatriceRaciti, CPC-APatriciaAnneFoley, CPC-APatriciaG.Terrell, CPC-APatriciaHernandez, CPC-APatriciaKayJulien, CPC-APatriciaLParker, CPC-APatriciaMarieCloney, CPC-APatriciaMeadows, CPC-APatriciaPadgett, CPC-APatriciaRobles, CPC-APatriciaSundel, CPC-A

PatsyHunnicutt, CPC-APattianneOpperman, CPC-APattyAddis, CPC-APaulaCawthon, CPC-APaulaWebb, CPC-APaulaWeiss, CPC-APaulaWoodward, CPC-APauletteKestner, CPC-APeggyHGrim, CPC-APeggyTurner, CPC-APennyBLakoff, CPC-APennyS.Bujanda, CPC-APerriEaston, CPC-APhillipRyanVillemure, CPC-APhillishaBrown, CPC-APollyClawson, CPC-AQuintoyaDanyelleSeawright, CPC-ARachaelTorgesonPrice, CPC-H-ARachelCLibby, CPC-ARachelGray, CPC-ARachelKayTracy, CPC-ARachelLynnStrzycki, CPC-ARachelMackay, CPC-ARachelMeyer, CPC-ARachelRue, CPC-ARaeanneSimons, CPC-ARanaeHensley, CPC-ARaquelMFooshee, CPC-ARashmiSahoo, CPC-ARebeccaAnderson, CPC-ARebeccaBrockman, CPC-ARebeccaConley, CPC-ARebeccaDeSantis, CPC-ARebeccaJOtwell, CPC-ARebeccaLavoie, CPC-ARebeccaSagovic, CPC-AReginaBrooks, CPC-AReginaLatoshiaFleming, CPC-AReginyaA.Ferguson, CPC-AReneeMSignore, CPC-AReneeWhite, CPC-H-ARhondaArnette, CPC-ARhondaBurton, CPC-ARhondaKelly, CPC-ARiaWiegmann, CPC-ARichardDavis, CPC-ARichardMorris, CPC-ARincyThomas, CPC-ARobbiNance, CPC-ARobertCole, CPC-PRobertHeistuman, CPC-ARobertaAnnAlbrecht, CPC-ARobertaLeBrun, CPC-ARobinSubramany, CPC-ARobinneThornton, CPC-ARobynLynnGross, CPC-ARochelCohen, CPC-ARoshaniPoudel, CPC-H-ARoxanneRuks, CPC-ARoySweet, CPC-ARoyanneCorzine, CPC-ARuthRiosTollinchi, CPC-ARyleeAnnJahns, CPC-ASabrinaMatos, CPC-ASamanthaMarieRodriguez, CPC-ASamanthaMoore, CPC-ASamuelWills, CPC-ASandraDziedzic, CPC-ASandraEnoch, CPC-ASandraHolt, CPC-ASandraLynnWolukis, CPC-ASandraMarieSzucs,CPC-A, CPC-H-ASaraElizabethGage, CPC-ASaraHansen, CPC-ASarahACreamean, CPC-ASarahJohnson, CPC-ASarahLPritchett, CPC-ASarahMundschau, CPC-ASarahStamper, CPC-ASarenaThomas, CPC-ASasikalaSrikanthan, CPC-ASavannahLynnKing, CPC-ASavannahSnow, CPC-AScottFarmer, CPC-ASeemaKarmarkar, CPC-ASethHerroldLancaster, CPC-AShainaKing, CPC-AShannaBrownell, CPC-AShannonAMayfield-Chapin, CPC-AShannonCaylorParker, CPC-AShannonMBlondell, CPC-A

ShanthalaMurthy, CPC-ASharonBergstrasser, CPC-ASharonHarrell, CPC-ASharonJohnson, CPC-HSharonVanessaNicholson, CPC-AShastaBridges, CPC-ASheenaJewell, CPC-ASheilaDenniseRivera, CPC-ASheilaTolentino, CPC-ASheliaWilliams, CPC-AShelleLandsberger, CPC-AShelleyMartin, CPC-AShelleySimpson, CPC-AShereePiatt, CPC-ASheriRoss, CPC-ASherifKamel, CPC-ASherisaPinkerman, CPC-ASherriMosier, CPC-ASherrieLBaxter, CPC-ASherryAnnPfeifle, CPC-ASherryBall, CPC-ASherryDianeOverstreet, CPC-ASherrySt.John, CPC-ASherrylFlorko, CPC-ASherylAnnRamirez, CPC-AShondalynMoniqueWilson, CPC-ASindyMarieBeauchamp, CPC-ASoniaWalter, CPC-AStaceyDBradshaw, CPC-AStaceyReneeSuper, CPC-AStaceyWalton, CPC-AStacieBenton, CPC-AStacyLHolland, CPC-AStacyStrock, CPC-AStefanieStreger, CPC-AStefanieStritt, CPC-AStephanieAskew, CPC-AStephanieCass, CPC-AStephanieDHerl, CPC-AStephanieDunahoo, CPC-AStephanieMajor, CPC-AStephanieMorgan, CPC-AStephanieRasberry, CPC-AStephanieSkidmore, CPC-AStephanieTietjen, CPC-ASteveJHack, CPC-AStevenSaul, CPC-ASueMKrysztopa,CPC-A, CPC-H-ASusanBianchi, CPC-ASusanMWeaver, CPC-ASusanPaul, CPC-ASusanSalutillo, CPC-H-ASusanSolomon, CPC-ASusanaMok, CPC-ASuyamMohideen, CPC-ASuzanneGraham, CPC-ASuzanneMSowa, CPC-ASvetlanaDayutova, CPC-ASwapnaRay, CPC-A,CPC-H-A,CPC-P-ASylviaStankiewicz, CPC-ATabithaLynn, CPC-ATabithaRomero, CPC-ATamaraAnnKing, CPC-ATambraMichelleAndre, CPC-ATammieBaker, CPC-ATammieGeneWitt, CPC-ATammyLighthall, CPC-H-ATammyLynnHarding, CPC-ATammyMoser, CPC-ATammyPIsaacs, CPC-ATammyRinehart, CPC-ATammySivic, CPC-ATanaErickson, CPC-ATanyaFayeEdwards, CPC-ATanyaMCurtland, CPC-ATaraGibson, CPC-ATaraLFore, CPC-ATaraLardieri, CPC-ATashaKing, CPC-ATekeyaAliciaBaker, CPC-ATeresaEnriquez, CPC-ATeresaLindsay, CPC-ATeresaMRutledge, CPC-ATeresaMShoop, CPC-ATeresitaJPeregrina, CPC-ATeriCronauer, CPC-ATeriJohnston, CPC-ATeriaEllis, CPC-ATerrahBooks, CPC-ATerriAlderson, CPC-ATerriJOlson, CPC-H-A

TheresaAguilar, CPC-ATheresaAnnWeaver, CPC-ATheresaBrown, CPC-ATheresaHoff, CPC-ATheresaLGoehring, CPC-ATheresaSmalls, CPC-AThereseShipman, CPC-ATheresitaChua, CPC-AThomasWoolford, CPC-ATiffaniSFunk, CPC-ATiffanyBarrick, CPC-ATiffanyTurner, CPC-ATimStelma, CPC-ATimothyJohnWhitcher, CPC-ATinaDumosch, CPC-ATinaFrideres, CPC-ATinaLaPradd, CPC-ATinaMarieJohnson, CPC-ATinaMarieKoewacich,CPC-A, CPC-H-ATinaMariePotter, CPC-ATonyaMorgan, CPC-ATraceyKocken, CPC-ATraceyMorehart, CPC-ATraceyPickett, CPC-ATraceyYoung, CPC-ATracieMitchell, CPC-ATracyWinstead, CPC-ATriciaMartin, CPC-ATriciaWade, CPC-ATrudieBlank, CPC-ATrudyAshley, CPC-ATrynetteThomas, CPC-ATyraTWashington, CPC-AValerieHassard, CPC-AVanessaRNittmann, CPC-AVangieKBecenti, CPC-A,CPC-H-AVeronicaCasias, CPC-AVeroniqueVanHoof, CPC-AVickiLynnGreer, CPC-AVickieAWilliams, CPC-AVictorVegaCruz, CPC-AVictoriaMoniqueGwathmey, CPC-AVikiMazzei, CPC-AVioletBarnes, CPC-AVirginiaTodd, CPC-AVirginiaWilliams, CPC-AVurondaHannah-Fisher, CPC-AWandaJunkins, CPC-AWandaLynnWoods, CPC-AWanedaPrince, CPC-AWendyArnold, CPC-AWendyCovarrubias, CPC-AWendyLeeByerley,CPC-A, CPC-H-AWendyLeeWilliams, CPC-AWendyPorter, CPC-AWendySchiltz, CPC-AWendyStrange, CPC-A WendySusanCammack, CPC-AWhitneyFriddle, CPC-AWilliamPeterAnganes, CPC-AWillieBeatriceJenkins, CPC-AWynonaShelton, CPC-AYamilaPereiro, CPC-AYolandaButler, CPC-AYolandaHenry, CPC-AYucolaArds, CPC-AYukoSteinbach, CPC-AYvonneMRockman, CPC-AZinaPalmer, CPC-A

SpecialtiesAmyLWolfgram,CPC, CPCOAmySBaker,CPC, CPMAAngelaLynnKruchten,CPC-H, CPMAAnitaMarieJoseph,CPC, CEDCAnnetteMarieAustin,CPC, CPMAAnnieRHughes,CPC, CPMABethCHungerford,CPC, CPC-H,CPMACamdenJannMcCullough-Duysen,CPC, CPMA,CPC-I,CEMCCandiceLynneIbarra,CPC, CPCO,CPC-ICatherineElizabethMarsch,CPC-A, CANPCChristinaSSkalka,CPC, CPMAChristineMJolitz,CPC, CFPCClarissaDDowrich,CPC, CPC-P,CPMACynthiaSTucker,CPC, CPMADawnMarieTamburrino,CPC, CUCDeborahBoudreau,CPC-A, CPMADebraAnnLaPorte,CPC, CGSCDeeKelly,CPC, CPMA,CPCD

42 AAPC Coding Edge

DeniseGiliberti,CPC, CANPCDianeSAscheman,CPC, CPCDDonnaBernardi,CPC, CEMCElaineMeyer, CUCElaineSGuppy,CPC, CPMA,CPC-IEricaCEnderle,CPC, CPMAEvanRosenberg,CPC, CPMAFredRuddeck,CPC, CPMAGabrielRafaelAponte,CPC, CPC-H,CPMA,CCCGingerMullenix, CPMAGinnaMarieGuido,CPC, CPMA,CIMCGloriaMRussell,CPC, CRHCGregoryCMilliger,CPC, CPC-H,CPCO,CPC-P,CPMA,CPC-I,CEMCHeatherOchoa,CPC, CPMAHeatherStefani,CPC, CPMAHelenACombs,CPC, CPC-H,CCVTCHenryAsemota,CIRCC, CPMAHollyAnnSpangler,CPC, CPMAJacquelineGarcia,CPC, CPMAJamieFellinger,CPC, CPMAJanellaFigueroaCasem,CPC, CPMAJenniferAsencio,CPC, CPMAJenniferDianeNojiri,CPC, CPC-H,CEMCJenniferEGunhus,CPC, CPMA,CPC-IJenniferJillErickson,CPC, CPMAJenniferMGauger,CPC, CEDCJennyLynnQuigley,CPC, CEMC,COBGCJennyferMassari,CPC, CGSCJessicaCBritton,CPC, CEMCJessicaLemert, CHONCJessicaTingLin,CPC, CPMA,CEMCJoanDolan,CPC, CPMA,CEMCJoanneMarieIngrasselino,CPC, CUCJoyceCasella, CHONC

JuliaCSchuler,CPC, COBGCJyotsnaMahindrakar, CGSCKarenTinoco,CPC, CPMAKatherineHudspeth,CPC, CPMAKatherineMFord,CPC, CPMAKathrynJElliott,CPC, CHONCKeishaLynneNelson,CPC, CIMCKellyABleichert,CPC, CPMAKenKobus,CPC, CPMAKerryLynnTerrien,CPC, CEMCKimSagely,CPC, CGSCKimberlyNicoleRuff,CPC, COBGCLashelDeniseChurch,CPC, CEMCLaurenHefner, CIMCLauriWilliams,CPC, CEMC,CUCLeeAnnMingus,CPC, CPEDCLillianJRuth,CPC, CPMALillianRuthLady,CPC, CPCOLindseyJoHarr,CPC, CPMA,CCCLisaStrickland,CPC, CPMA,CGSCLisaVickerson,CPC, CPC-H,CPMALisaZerrlaut, CPCDLorraineLemons, CEDCLynneMeyer-Reynolds, CHONCMarciaSMcInnis,CPC, CEMCMarcieEBarker,CPC, CPMAMarenMooney, CPRCMariaPhuongTran,CPC, CIRCCNancyEVirostek,CPC, CPMANancyLoguercio,CPC, CPMANancyMHall,CPC, CEMCOlusinboIbironkeFamure,CPC, CEMCPamelaJRourke,CPC, CEDCPamelaMatthews, CEMCPatriciaLWilson,CPC, CPMA

PattyMHobbs,CPC, CPMAPaulDonaldAragonesApusen,CPC, CIRCC,CPMAPaulaDenitrasSimpson,CPC, CPMAPennyEtter, CPMARickWeintraub, CEDCRomeoKAquino,CPC, CIRCC,CPMASabrinaMIsola,CPC, CEDC,CFPC,CGSCSamFord,CPC, CANPCSheriJones,CPC, CPMASofyaLLeytis,CPC, CHONCStefanieMottmiller,CASCCStephanieRBaxter,CPC, COSCSulakchanaSingh,CPC, CEDCTaiyaThompson, CEDCTammyLouiseBellamy,CPC, CEDCTaraEarl,CPC, CPCDTeresaLynnReeves,CPC, CEMCTerriLynnRadominski,CPC, CEDCTerriWinsor,CPC, CCCTesjaErickson,CPC, CPMA,COBGCTiffanyMorgan,CPC, CPMA,CEMCTiffanyRogers, CUCTraciWaltz, COBGCTriciaLClark,CPC, CFPC,COBGCTrishaLeavitt,CPC-A, CPMAWandaFayeHite,CPC, CPMAWendyDTrott,CPC, CPMAYamelSantana,CPC, CPC-H,CPMA

Magna Cum LaudeAlisonLJohnson, CPCAmandaFreeman, CPC-AAmandaLeaNelson, CPC-AAmySteele, CPCAndrewMontaruli, CPCCamilleLaabs, CPCCathyAshberry, CPCCeciliaESherman, CPC-ACherylAMuszynski,MD, CCA,CPCChristinaBecker, CPCCrystalJunkins, CPC-ACynthiaBarnes, CPC-ADariceMuniz, CPC-ADebbieMcNary, CPC-ADianePochobradsky, CPCElenaCase, CPC-AElyseBonner, CPC-AFarrenSkalitsky, CPC-AGailRineer, CPC-AHeatherLLamont, CPCIraidaCruz, CPC-AJaclynLeeGage, CPC-AJacquelineMorris, CPCJanaG.Jones, CPC-AJenniferRoberts, CPC-AJessicaRod, CPCJodiBrandon, CPCJonieKerns, CPCJoyelleConstantine, CPCKarenMoles, CPC-AKaturahMJones, CPCKimberlyLBowlin, CPCLeeBoyd, CPC-A

LindseyUrankar, CPC-ALoukeshaMarieRaye, CPC-AMarianneZito, CPC-AMaryAnnHaynes, CPCMary-LouiseBrown, CPCMelindaKayPrice, CPC-AMelindaMichelleOlejniczak, CPCMelissaLBeshirs, CPC-AMichelleA.Ward, CPCMichelleTernes, CPC-AMirandaFreesemann, CPC-AMistiMyrick, CPC-ANicoleABenson, CPCRichardHutchinson, CPC-ARichardKnighton, CPC-ARichardPeterson, CPCSarahMarks, CPC-HShandaNeedham, CPC-AShawnVarney, CPCSheriRudy, CPC-AShiaraMaher, CPCSibylMagiera, CPC-AStaceyM.Lancaster, CPC-ASueDancause, CPC-ASunitaRangwala, CPC-ASuzanneLMucha, CPC-ASuzanneMartin-Hand, CPCTammyFloore, CPC-ATawanaJohnson,CPC, CPC-H,CPC-PTeresaABuck, CPC-ATerriAnnWinger, CPCTraceyBell, CPC-AWandaAndujar, CPC-AWendyEMahone, CPCXiaojingShen, CPC


Medicare Revalidation (Cont’d from p. 37)

• CMS-588 Electronic Funds Transfer Authorization Agreement form• Certification and other supporting documentation requested by Medicare, such as

a copy of IRS CP-575These forms may be found at: www.cms.hhs.gov/MedicareProviderSupEnroll/.CMS says that 90 percent of applications and changes of information submitted through PECOS are processed within 45 days of receipt of the signed and dated Certification State-ment, versus 80 percent during the same time for paper applications (depending on the changes made to the application, processing can take over six months). To use PECOS, you must have your organization or individual National Provider Identifier (NPI). If you use PECOS to make any changes, complete enrollment revalidation, or report a change, and find that you need assistance with your user ID or password, you may contact the help desk at: www.cms.hhs.gov/MedicareProviderSupEnroll, or call 1-800-465-3203.

Verify EnrollmentProviders should verify their enrollment, or pending enrollment, in PECOS. To do this you will need to set up access to PECOS. For information on how to do this, go to the CMS website: www.cms.gov/MedicareProviderSupEnroll/Downloads/Instructionsforviewingpractitionerstatus.pdf. If you do not have an enrollment record, you should submit your enrollment application. Call your local carrier if you have questions or need instruction. For a direct toll-free number, go to the CMS website: www.cms.gov/MLNProducts/downloads/CallCenterTollNumDirectory.For more tips on how to enroll in PECOS, go to: www.cms.gov/MLNProducts/downloads/MedEnroll_

PECOS_PhysNonPhysFactSheet_ICN903764.pdf.

Delly E. Parham, AS, CPC, is a billing/managed-care consultant. For 12 years, she worked in billing and coding and oversaw a billing department. She is the president of AAPC’s Sarasota/Manatee, Fla. local chapter. She helped to re-write the Complete Coder for Dermatology for the dermatology practice, Inga Ellzey Practice Group, and writes billing articles for AAPC’s Billing Insider. Delly also assists in coordinating activities for Sunday school students.

Revocation is far more

serious … After receiving

a revocation letter, a

provider has 30 days

to submit a corrective

action plan and 60 days

to submit a request for

reconsideration.

CODINGC N

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44 AAPC Coding Edge

Capsule Endoscopy Coding, Made SimpleCorrectly coding this diagnostic service depends on what’s viewed.

By G.J. Verhovshek, MA, CPC

Capsule endoscopy is an alternative to traditional endoscopy that uses a tiny camera contained within a pill that the patient swallows to obtain images of the interior of the digestive tract (for instance, to diagnose polyps or the source of bleeding). Unlike colonoscopy or esophagogastroduodenoscopy (EGD), however, capsule endoscopy is purely diagnostic. The best known capsule endoscopy devices are marketed under the name PillCam™.Coding for capsule endoscopy depends on which structures the phy-sician wishes to view.

• For imaging of the esophagus only, using a PillCam ESO or similar Food and Drug Administration (FDA)-approved device, the correct CPT® code is 91111 Gastrointestinal tract imaging, intraluminal [e.g., capsule endoscopy], esophagus with physician interpretation and report. In this application, the camera may transmit up to 15 diagnostic images per second as it travels down the esophagus.

• For imaging of the gastrointestinal (GI) tract from the esophagus to the ileum, using a PillCam SB or similar FDA-approved device, you should assign CPT® 91110 Gastrointestinal tract imaging, intraluminal (e.g., capsule

endoscopy), esophagus through ileum, with physician interpretation and report. Over the course of approximately eight hours, the capsule moves through the digestive tract, transmitting pictures on average every two seconds. This type of capsule endoscopy allows for imaging of the small bowel, which is not possible with colonoscopy or EGD. Visualization of the colon is not reported separately with 91110, according to CPT® instructions.

Do not report 91111 in addition to 91110. As a more extensive pro-cedure, 91110 includes 91111, per CPT® instructions and National Correct Coding Initiative (NCCI) bundling edits.

Modifiers May Be Necessary for Unusual CircumstancesReporting capsule endoscopy is usually straightforward, but some-times there are circumstances that call for a modifier. For example, according to CPT®, when reporting 91110, modifier 52 Reduced services is required when the entire distance from the esoph-agus to the ileum is not visualized. For instance, the physician may place the capsule endoscopically, so the esophagus and stomach are not imaged. Or, the camera may become obscured by food when it reaches the stomach, and no further images are recovered. In either case, it would be appropriate to report 91110-52.If images are not recovered due to technical problems (such as the camera being obscured by food in the stomach, as in the above exam-ple), the physician may wish to repeat the study to gather necessary images. In such cases, it is wise to contact the payer for reauthoriza-tion of the procedure. In some cases, payers will allow you to report the failed procedure as 91110-53 Discontinued procedure. Note: Some payers consider capsule study of the esophagus (91111) to be experimental and not a covered procedure. Speak with your payer for coverage details.

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Note also: CPT® codes 91110 and 91111 include both technical and professional components. Often, the hospital or endoscopy suite will purchase the capsule (which is used only once) and the neces-sary equipment to receive and view the images it captures. When this occurs, the physician who interprets the images may claim only the professional portion of the service (e.g., 91110-26 Profes-sional component). If the physician supplies the capsule and relat-ed equipment, you may report the global service with no modifi-ers appended.

G.J. Verhovshek, MA, CPC, is managing editor at AAPC.

Featured Coder

Call on 0242T for Pressure MeasurementsWireless capsules, similar (but not identical) to those used for capsule endoscopy, may be used to measure GI tract transit times and/or pressure to evaluate patients with sus-pected gastroparesis, slow transit constipation, unexplained diarrhea, or functional constipation that may be due to GI tract mobility issues. To report such studies, turn to Cate-gory III code 0242T Gastrointestinal tract transit and pressure measurement, stomach through colon, wireless capsule, with interpretation and report.

Do not report 0242T in addition to 91020 Gastric motility (manometric) studies or 91022 Duodenal motility (manomet-ric) study. Codes 91020 and 91022 “are inappropriate for identifying the study of motility of the small intestine distal to the duodenum or the colon or serial examination of this nature performed in conjunction with gastric and/or duode-nal motility,” according to the American Medical Assoica-tion’s CPT® Changes 2011: An Insider’s View.

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46 AAPC Coding Edge

Clinical trials are an end stage in the lengthy research process of finding better ways to pre-vent, diagnose and treat disease. Like all health care services, however, clinical trials (ICD-9-CM code V70.7 Examination of participant in clinical trial or ICD-10-CM code Z00.6 En-counter for examination for normal comparison and control in clinical research program) have come under increased scrutiny for billing errors and fraud. It’s times like these when organi-zations should enhance their risk management strategy to include coverage analysis that ad-dresses appropriate billing for research.

Clinical Trails Aren’t Immune to Payer ScrutinyAs financial pressures increase, there is greater effort to root out fraud and waste by scrutiniz-ing claims and payments for all health care services. The Obama administration’s 2010 Af-fordable Care Act dedicated approximately $1.5 billion to fighting health care fraud. In Jan-uary 2011, the U.S. Department of Health & Human Services (HHS) announced that, as a result of efforts to prevent and recapture dollars lost to fraud or waste, the federal government recovered over $4 billion. The announcement also outlined additional regulations for fight-ing health care fraud that increase data sharing across government agencies, expand overpay-ment recovery efforts, and broaden oversight of private insurance abuses. These new regulations could have a significant impact on how the Affordable Care Act is used to substantiate fraud allegations for items or services rendered in clinical trials. Accord-ing to findings presented at the 2010 conference of the Region IV National Council of Uni-versity Research Administrators, the organizations that have already paid out settlements re-lated to CT billing errors include:

• Spectranetics: $5 million settlement over false Medicare claims• New York University Medical Center: $15.5 million for inflated research grant costs• University of Alabama: $3.4 million for double billing• Palm Beach Imaging: $7 million for anti-kickback

Clinical Trials Under Scrutiny

Coding Compass

By Duwayne Barrett, MBA, RPSGT, CPC-P

Keep safe by using coverage analysis as a good risk manage-ment strategy.


• Scripps Memorial Hospital: $29 million for violation of the False Claims Act

Avoid Five Specific ErrorsLeaders in organizations performing or moving towards performing clinical trials should be acutely aware of the types of red flags govern-ment regulators are looking for. An effective risk management strat-egy will evaluate an organization’s vulnerability for conspicuous re-search billing errors, such as:

• Double billing – billing the research participant’s insurer for services covered by the study sponsor

• Upcoding – assigning a diagnosis code that does not match the recorded medical documentation to obtain participants; for example reporting ICD-9-CM diagnosis code 410.00 Acute myocardial infarction of anterolateral wall episode of care unspecified for heart attack (ICD-10-CM, I21.09 ST elevation (STEMI) myocardial infarction involving other coronary artery of anterior wall) when ICD-9-CM diagnosis code 413.0 Angina decubitus for angina (ICD-10-CM, I20.8 Other forms of angina pectoris) was actually documented

• Billing for items or services that are not clinically necessary and for research purposes only

• Billing for items or services that were outlined as free in the participant’s informed consent document

• Billing for items or services performed as part of a nonqualifying trial

Research often occurs with routine care encounters, which adds to the potential for research billing errors. Your goal is to ensure items or services for routine care or research are billed to the appropriate payer, and in compliance with applicable regulations.

Take Four Steps Towards Research Billing SuccessA good starting point for developing strategies to prevent clinical tri-al billing errors is detailed in “Risk Management in Health Care In-stitutions: A Strategic Approach,” by Florence Kavaler, MD, MPH, and Allen D. Spiegel, Ph.D., MPH. Focus on this four-step risk man-agement strategy before committing to a clinical trial agreement and while developing coverage analysis techniques:Risk identification involves collecting data about similar types of trials that could uncover liabilities to the patient or institution.Risk analysis entails assessing the collected data to develop a tai-lored plan that eliminates or limits the impact of substantial liability.Risk control and treatment is the most common step for risk man-

agement. Control and treatment is an institution’s response of imple-menting techniques to limit liability when incidents occur.Risk financing is a comprehensive and retrospective review of the expenses required for the previous steps as well as funding losses as-sociated with addressing potential incidents.

Cover Yourself with Coverage AnalysisCoverage analysis is a standardized method of reviewing and detail-ing the trial protocol to identify the responsible payer for each item or service to be appropriately billed. This is similar to using national or local coverage determinations (NCDs or LCDs) for routine clin-ical services.A complete research billing coverage analysis:1. Outlines the participant’s financial liability, to be further ex-

plained in the informed consent document, so that all parties avoid incurring unexpected costs before agreeing to participate.

2. Identifies the qualifying research items and procedures.3. Supports the billing staff in identifying the responsible payers

or restrictions during the entirety of the trial to prevent False Claims Act violations.

Example Case StudiesTo demonstrate how coverage analysis works, let’s review two fic-tional scenarios. After reading through a scenario, ask yourself:

• Who would be listed on the coverage analysis as the responsible payer for the service or item provided to the participants during the course of the clinical trial?

• What services or items should the coverage analysis clearly outline as standard of care or research related?

• How could your billing staff use the coverage analysis information to avoid research billing errors during the entirety of the clinical trial?

Scenario 1: A private durable medical equipment (DME) compa-ny specializing in sleep medicine devices contacts your accredited sleep lab facility about sponsoring a clinical trial. They want to test a new version of their continuous positive airway pressure (CPAP) machine. As the sponsor, the DME company is willing to have an informed consent that states the CPAP and study-related items or services rendered during the course of the trial are covered by the DME company; however, the DME company only wants to pay a reimbursement rate of 70 percent of your facility’s charge costs. In addition, the study will only enroll a participant after screening via a recent standard of care sleep study (CPT® 95810 Polysomnogra-phy; sleep staging with 4 or more additional parameters of sleep, attend-

Coding Compass

Your goal is to ensure items or services for routine care or research are billed

to the appropriate payer, and in compliance with applicable regulations.

48 AAPC Coding Edge

Coding Compass

ed by a technologist) that led to a diagnosis of obstructive sleep apnea (ICD-9-CM 327.23 Obstructive sleep apnea (adult)(pediatric); ICD-10 G47.33 Obstructive sleep apnea (adult) (pediatric)).Scenario 2: A cardiologist in your hospital wants to apply for a fed-eral grant to study cardiac blood flow in teenage patients that pres-ent to the emergency department (ED) with symptoms of acute em-bolism/deep vein thrombosis (ICD-9 453.40 Acute venous embolism and thrombosis of unspecified deep vessels of lower extremity; ICD-10 I82.409 Acute embolism and thrombosis of unspecified deep veins of un-specified lower extremity). The total grant funding offered is $50,000 for an estimated 10 patients. Your institution’s internal review board (IRB) gives approval to obtain initial study data by piggybacking off of the standard of care records acquired from the ED encounter. If, however, the patient is admitted, the study protocol requires phle-botomy every six hours, numerous lab tests, and physical exams that would not be done for medical necessity and not covered as standard of care during the inpatient stay.Protecting your institution from criminal or civil litigation due to al-legations of fraud or abuse is an important risk management goal. It

is also important to consider the patient’s rights. For example:• In scenario 1, appropriate coverage analysis techniques would

show the DME company as the responsible payer for the follow-up sleep study, according to specifics in the informed consent. As necessary for charge auditing or invoicing, your billing staff should refer to a billing plan grid (see grid above) that clearly shows the disposition of charges generated during each research encounter for the entirety of the study.

• For scenario 2, the coverage analysis should create techniques that identify all the research specific tests, quantities, and budget caps during the inpatient stay. Again, the billing staff should use a billing plan grid with clear payer designations for research charges, broken down by six hour intervals.

• Keep in mind that for both scenarios coverage analysis gives an indicator of the fiscal viability or potential loss your institution may incur. Just as your IRB or medical director reviews proposed study protocols for clinical efficacy, your billing team needs to do a monetary review.

Using coverage analysis techniques is a good risk management strat-egy for preventing common research billing errors, avoiding exces-sive fines due to fraud allegations, and keeping your institution on track to do the right thing.

Duwayne Barrett, MBA, RPSGT, CPC-P, has worked as a sleep technologist and billing staff member for industry and federally sponsored clinical trials since 2002. He is the director of patient access at Mercy Suburban Hospital in Norris-town, Pa. Learn more about research billing or global health care infrastructure by following Duwayne on Twitter @DbeBARRETT.

CT Coverage Analysis Resources• National Coverage Determination for Routine Costs in Clinical Trials (310.1)—CMS coverage da-

tabase (www.cms.gov)

• Current year CPT® and HCPCS Level II books

• MediRegs (Check to see if your organization has a subscription.)

• Medicare administrative contractor (MAC) sites (e.g., www.highmarkmedicareservices.com/in dex.html)

• Your institution’s revenue cycle department

To discuss this article or topic, go to: www.aapc.com

Sample billing grid

50 AAPC Coding Edge

MinutewithaMember

Tiffany Speer, CPC-AMedical Record Technician, Pennsylvania

■ Tell us a little bit about your career—how you got into cod-ing, what you’ve done during your cod ing career, what you’re doing now, etc.I first became interest-ed in coding at a young age when my mother continually received bills from physician

offices and hospitals for me due to insurance carrier denials. Almost every time, it was because symptoms were used instead of diagnoses, the wrong code was chosen for the diagnosis, or the claim was not coded to the highest level of specificity. It was very frustrating for my mother to repeatedly call physician offices or hospitals to straight-en out erroneous bills.After graduating from high school, I went on to attend Lincoln Technical Institute. I graduated in 2008 with a diploma in medi-cal coding and billing and was awarded a certificate of achievement in recognition of outstanding academic excellence. After my class-mates had gone for their credential and failed, I decided to obtain ex-perience before testing for any certifications. Unfortunately, I was turned down for any coding/billing positions due to lack of experi-ence and certifications. The advice the employers gave me was to go back to school for my associate degree in health information tech-nology (HIT). I enrolled at Lehigh Carbon Community College for HIT in 2009. While working on my degree, I also obtained a diplo-ma in health care coding. I was elected to Who’s Who Among Stu-dents in American Universities & Colleges® in 2011. My instructor, Patricia Nesfeder, MS, RHIT, CPHQ, encouraged me to take my certification exam because I was ready. Sure enough, last Feb. 19, I became a Certified Professional Coder - Apprentice (CPC-A®).What is your involvement with your local AAPC chapter?Before I started working as a medical record technician for a 13-phy-sician gastroenterolgy office, I attended the local Allentown, Pa. chapter meetings. Now, I stay in contact with the president of the chapter, Diana Torres, CPC, to obtain information from the meet-ings. I have offered my help with anatomy and physiology in the past, and would like to help with ICD-10 by giving my perspective

as a new coder.What AAPC benefits do you like the most?The available resources benefit me the most. I enjoy reading and learning from Coding Edge magazine and newsletters like Edge-Blast, ICD-10 Connect, and BillingInsider. AAPC is also a great tool for networking with other coders. What has been your biggest challenge as a coder? My biggest challenge as a CPC-A® has been obtaining experience. I have asked experienced coders and billers how they learned third-party billing, payer rules, etc., and I always get the standard answer “You learn by doing it.” That is what I am trying to do! But most em-ployers require at least three years of experience before they’ll even consider hiring someone for a coding position. How are you preparing for ICD-10?I’m excited for the upcoming changes that ICD-10 will bring. ICD-10 allows coders to really dive into the medical record. The informa-tion that can be abstracted from the record will become a more pow-erful tool for researchers and teachers of medicine. Although some say it is still too early to fully train for ICD-10, I have been strength-ening my anatomy and pathophysiology (A&P) knowledge. I read ICD-10 Connect and other published articles, and I am also reading Understanding Health Insurance – A Guide to Billing and Reimburse-ment by Michelle A. Green, MPS, RHIA, CPC, FAHIMA, and Jo Ann C. Rowell (AAPC-approved), which has a chapter for ICD-10-CM and ICD-10-PCS describing the constructional layout for both. It may be too early for learning the guidelines and buying draft cod-ing books, but I think it is essential to strengthen other areas now. If you could do any other job, what would it be?Besides obtaining a coding position, I would like to work in clinical outcomes, which is driven by codes, or some other kind of medical abstraction position or billing. How do you spend your spare time? Tell us about your hobbies, fami-ly, etc. I work on my brother’s 1977 Cobra II Mustang, attend car shows, and volunteer at Camp Compass Academy (www.campcompass.org). Camp Compass is a non-profit program for urban, disadvantaged teenagers. Children need social guidance and good role models to help them become independent, successful adults. As a Camp Com-pass graduate, I’m living proof the program works!

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