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Using the Health Information Supply Chain (HISC SM ) Process to Improve Documentation and Avoid Denials Dr. Harry Feliciano Senior Medical Director & Kathy Merrill President, Agilency January 30, 2017

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Page 1: Using the Health Information Supply SM) Process to Improve ... · functions and can see the process from patient presentation to payment.” • “This is the first opportunity we’ve

Using the Health Information Supply Chain (HISCSM) Process to Improve Documentation and Avoid Denials

Dr. Harry FelicianoSenior Medical Director &

Kathy MerrillPresident, AgilencyJanuary 30, 2017

Page 2: Using the Health Information Supply SM) Process to Improve ... · functions and can see the process from patient presentation to payment.” • “This is the first opportunity we’ve

• The HISCSM Approach

• HISCSM for Hospice and Palliative Care

• The Organizational Process Improvement Coaching Project (OPICP)

• Flow, timing & accuracy of work to document hospice claim

• Qs & As

Presentation Outline

1/30/2017 2

Page 3: Using the Health Information Supply SM) Process to Improve ... · functions and can see the process from patient presentation to payment.” • “This is the first opportunity we’ve

• Uses a new unit of analysis for healthcare process improvement and quality management

• Being analyzed by Palmetto GBA, process engineers and Medicare providers in JM

The HISCSM Approach

1/30/2017 3

Page 4: Using the Health Information Supply SM) Process to Improve ... · functions and can see the process from patient presentation to payment.” • “This is the first opportunity we’ve

• Medicare providers contribute to the Health Information Supply Chain (HISC)

• Coders, billers, and payers are downstream recipients of their health care records

• Records containing insufficient information are ineffective and produce inefficiency

• Denied payments

• Delayed payments

Rationale for the HISCSM Approach

1/30/2017 4

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• Medicare providers' documentation must support both clinical and administrative tasks:

– Capturing the unique attributes of individual patients

– Communicating the individual needs of patients

– Informing clinicians’ decisions

– Informing claims payment decisions

– Informing improvements in both provider and payer

• Policies

• Procedures

Rationale for the HISCSM Approach

551/30/2017

Page 6: Using the Health Information Supply SM) Process to Improve ... · functions and can see the process from patient presentation to payment.” • “This is the first opportunity we’ve

• Goal: Align hospice payment/resource utilization

• Two Routine Home Care (RHC) payment rates

• < 60 days

• > 60 days

• Service Intensity Add-on (SIA)

• Additional payments for RN or social work services provided “during last 7 days of the beneficiary’s life”

CMS Hospice Payment Reform

1/30/2017 6

Page 7: Using the Health Information Supply SM) Process to Improve ... · functions and can see the process from patient presentation to payment.” • “This is the first opportunity we’ve

• Hospice-related metrics include:

• Hospice diagnosis reporting – number and categories

• Lengths of stay (LOS)

• Live discharges at or around day 61 of hospice care

• Spending for Parts A, B, & D during hospice election

CMS Monitoring Medicare Utilization

1/30/2017 7

Page 8: Using the Health Information Supply SM) Process to Improve ... · functions and can see the process from patient presentation to payment.” • “This is the first opportunity we’ve

• Alzheimer’s was #1 hospice principal diagnosis

• Replaced Debility unspecified

• Average LOS higher for certain principal diagnoses

• Alzheimer’s disease

• Non-Alzheimer’s Dementia

• Parkinson’s disease

• Principal diagnosis is of potential relevance to future case mix systems for hospice (CMS-1652-P)

https://www.federalregister.gov/articles/2016/04/28/2016-09631/medicare-program-fy-2017-hospice-wage-index-and-payment-rate-update-and-hospice-quality-reporting

FY 2015 Principal Diagnosis

1/30/2017 8

Page 9: Using the Health Information Supply SM) Process to Improve ... · functions and can see the process from patient presentation to payment.” • “This is the first opportunity we’ve

• Established Policy: The principal diagnosis reported on the claim should be the diagnosis most contributory to the terminal prognosis.

• As of October 1, 2014 “Debility” (799.3, 780.79/R53.81) and “adult failure to thrive” (783.7/R62.7) are not to be used as principal hospice diagnoses on the hospice claim form

Invalid Principal Diagnoses Codes

1/30/2017 9

Page 10: Using the Health Information Supply SM) Process to Improve ... · functions and can see the process from patient presentation to payment.” • “This is the first opportunity we’ve

• Several dementia ICD-9-CM/ICD-10-CM codes have principal diagnosis code sequencing rules.

• Most of these dementia codes are found under Chapter 5 of ICD-9-CM/ICD-10-CM classification, “Mental, Behavioral, and Neurodevelopmental Disorders” and are typically manifestations from an underlying physiological condition.

• Example: ICD-9-CM 304.8 , Other persistent mental disorder due to condition classified elsewhere (ICD-10-CM = F06.0)

Additional Invalid Principal ICD Codes

1/30/2017 10

Page 11: Using the Health Information Supply SM) Process to Improve ... · functions and can see the process from patient presentation to payment.” • “This is the first opportunity we’ve

• Who does it?

• What do they do?

• When do they do it?

• Where do they record it?

• How do you communicate it?

Selection of Principal Diagnosis

1/30/2017 11

Page 12: Using the Health Information Supply SM) Process to Improve ... · functions and can see the process from patient presentation to payment.” • “This is the first opportunity we’ve

• Partners in ExcellenceSM

• The Hospice Organizational Process Improvement Coaching Project (OPICP) is a collaboration among:

• Palmetto GBA

• JM hospice providers wanting to improve their process flow

• Process engineers - Agilency

The Hospice OPICP

1/30/2017 12

Page 13: Using the Health Information Supply SM) Process to Improve ... · functions and can see the process from patient presentation to payment.” • “This is the first opportunity we’ve

• Goal: To improve the effectiveness and efficiency of the Hospice & Palliative Care health information supply chain.

• Objectives: To understand current organizational process flows and how hospice organizations select and represent the concepts of “terminal illness” and “related conditions” in their records.

The Hospice OPICP

1/30/2017 13

Page 14: Using the Health Information Supply SM) Process to Improve ... · functions and can see the process from patient presentation to payment.” • “This is the first opportunity we’ve

Methodology

DESIGN

•Define business requirements•Map the process from patient referral to claim processed•Identify Critical to Quality (CTQ) customer & process elements

MEASURE

•Identify measures for evaluating process performance•Implement a data collection plan •Identify process baseline capability•Collect data on process defects & variation

ANALYZE

•Analyze process flow•Identify critical path; value/non-value added steps•Identify sources of errors & variation•Validate root causes

IMPROVE

•Generate solutions & select options to pilot•Prioritize deployment of solutions•Implement solution within 60 days•Collect data to verify improvement

CONTROL

•Institute a dashboard/scorecard process•Create feedback loops •Document standard operating procedures•Continuously improve

1/30/2017 14

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1/30/2017 15

Page 16: Using the Health Information Supply SM) Process to Improve ... · functions and can see the process from patient presentation to payment.” • “This is the first opportunity we’ve

• A flowchart is a picture of the separate steps of a process in sequential order.

• Elements that may be included are:

• Sequence of actions

• Inputs and outputs

• Decisions that must be made

• People/departments who become involved

• Time involved at each step and/or some other process measurements

A Place for Process Flow Charts

1/30/2017 16

Page 17: Using the Health Information Supply SM) Process to Improve ... · functions and can see the process from patient presentation to payment.” • “This is the first opportunity we’ve

Sample Hospice Process Flow “Current State”

171/30/2017

Page 18: Using the Health Information Supply SM) Process to Improve ... · functions and can see the process from patient presentation to payment.” • “This is the first opportunity we’ve

• Capture the steps of the process currently performed

• Discover process flow barriers, such as:

• Unclear hand-offs

• Errors prone activities

• Duplication/redundancy

• Vague patient assessment

Baseline Process Flow & Analysis

1/30/2017 18

Page 19: Using the Health Information Supply SM) Process to Improve ... · functions and can see the process from patient presentation to payment.” • “This is the first opportunity we’ve

Barriers are Needles in a Haystack

1/30/2017 19

Page 20: Using the Health Information Supply SM) Process to Improve ... · functions and can see the process from patient presentation to payment.” • “This is the first opportunity we’ve

Hospice Barrier Examples

Staffing

Patient Staffing Ratio

Weekend staffing minimal

Long admissions

Call volume

Referral staff role

Data Collection/Entry

Rework

Timely submission

Accuracy of information

Waiting for physician input/signature

Paper versus technology

Billing

Incorrect patient information

Confusing payer criteria for claim

submission

Inadequate clinical documentation

Payer response time

Age of documentation

Admissions

Response time

Travel time

Difficulty obtaining medications

Timely & accurate physician input

1/30/2017 20

Page 21: Using the Health Information Supply SM) Process to Improve ... · functions and can see the process from patient presentation to payment.” • “This is the first opportunity we’ve

• Identify Barrier Root Cause

• 5 Whys

• Fishbone Diagram

• Pareto Analysis

• Modified Affinity Analysis

• Hand Off Analysis

• Flow Diagraming

• Isolate ‘Myths’ for elimination

• Attack fixed procedural steps that are outdated or not

applicable

• Make workplace and problems visible

• Define new plays to drive efficiency & effectiveness

Create Future State

1/30/2017 21

Page 22: Using the Health Information Supply SM) Process to Improve ... · functions and can see the process from patient presentation to payment.” • “This is the first opportunity we’ve

Define the Plays

Page 23: Using the Health Information Supply SM) Process to Improve ... · functions and can see the process from patient presentation to payment.” • “This is the first opportunity we’ve

Referral

Assisted Living- Gather info/order

- Contact doc for

med rec

- Call family-consult

Initial Referral Types: phone calls/Email/Walk-in

Refe

rrals

Adm

issio

ns

On c

all

Nurs

eS

ecre

tary

Site R

evenue

Coord

inato

r

Medic

al

Record

s

Referral

Dr. Office- MD office fax

order

- Call family to

set up eval

Referral

Hospital- Pull from referral &

order

- Schedule

consult/eval for

D/C work more

w/social worker

- Identify attending.

Referral

Nursing Home- Gather info/order

- Call family/consult

- Work more with social

worker

Admissions

Face to

Face; determine need;

schedule

Codin

g

Clin

ical

Sta

ff

Referral

Family- Contact doc

for order

/H&P

- Set up

appointment

for call

ITEnter referrals

& leads. Use

pending

reason to

differentiate.

ITAC enters patient

data at referral

ITVerify patient

insurance

information,

coverage, benefit

period

ITEnter insurance

information &

billing sequence

Admitting

NurseCompletes

admission

assessment

Admitting/

On call RNConsult with

physician to

determine Dx

Admitting/

On call RNReports

admissions to

Clinical Staff

2 3

4 56 7

9

1

8

17

18

19

21

22

26

27

28

HISCSM Generated Future State Hospice Flow

= Improvement InitiativesCritical Path

IT

10

AdmissionsBuild chart in

binder as

Admissions

gathers

paperwork

ITEnter Dx + 2nd Dx

Reven

ue C

ycle

sta

rts h

ere

AdmissionsAdmit patient

into Hospice

Pre Admit Triage – obtains patient

info , verify ins; tee-up

family what is needed;

schedule legals

1120

PCM/IDGDiagnosis list

PCSCompile

documents

for Clinical

Staff

PCSFax Med list

to Pharmacy

PCSEnter admissions to

roster; enter

admission to RN;

MSW; Chaplain; HA

schedules

ITWeekly recurring

charge generator to

Revenue Coordinator

ITDiagnoses List in GL with

ability to evaluate &

document relatedness…

13

1416

15 17

23

24

25

30

31

32

ITVisiting Entry: CM;

Hospice Aid;

M&W; SC

30

Medical RecordsCompiles chart; checks for

compliance; Face Sheet

12

SCR/ACFax clinical & other

documents to

Attending

ITData entry of HIM

information; enter

disciplines

SCR/ACTechnical review of

consents & clinical

documentation

ITEntering ongoing LOC

changes; Enter Location

changes; Enter BP events

231/30/2017

Page 24: Using the Health Information Supply SM) Process to Improve ... · functions and can see the process from patient presentation to payment.” • “This is the first opportunity we’ve

• “This is the first time we’ve looked across all functions and can see the process from patient presentation to payment.”

• “This is the first opportunity we’ve ever had to bring the whole team together and look at the big picture.

• “We’ve been working really hard to get it right. Now we know what “it” is and what to work on.”

Testimonials to OPICP Collaboration

1/30/2017 24

Page 25: Using the Health Information Supply SM) Process to Improve ... · functions and can see the process from patient presentation to payment.” • “This is the first opportunity we’ve

• The process varies among hospices

• This variation can contribute to errors and waste

• Rework increases costs for both payers and providers

• Incorrect selection of hospice principal diagnosis will impact financial performance in a case mix system

• Preventing the errors is our goal

Selection of Principal Diagnosis

1/30/2017 25

Page 26: Using the Health Information Supply SM) Process to Improve ... · functions and can see the process from patient presentation to payment.” • “This is the first opportunity we’ve

• Communicating biopsychosocial concepts in support of hospice and palliative care, requires a knowledge of payer design requirements (eligibility and coverage standards) and your organizational workflow

Framing the problem

1/30/2017 26

Page 27: Using the Health Information Supply SM) Process to Improve ... · functions and can see the process from patient presentation to payment.” • “This is the first opportunity we’ve

• When considering the initial certification of terminal illness do you have the necessary information to make decisions related to:

• Principal diagnosis

• Related diagnoses

• Current subjective and objective medical findings

• Current medication and treatment orders and

• Unrelated conditions

How is your organization doing?

1/30/2017 27

Page 28: Using the Health Information Supply SM) Process to Improve ... · functions and can see the process from patient presentation to payment.” • “This is the first opportunity we’ve

• What’s in it for us?

• More efficient operations

• Happy customers

• CMS

• Providers

• Beneficiaries

• Decrease overall waste in our healthcare system

Getting it Right the First Time

28281/30/2017

Page 29: Using the Health Information Supply SM) Process to Improve ... · functions and can see the process from patient presentation to payment.” • “This is the first opportunity we’ve

• Is important to both providers and payers

• Will inform CMS payment reform activities

• A pre-requisite for communicating the concepts of “terminal illness” and “related conditions”

An Accurate Principal Diagnosis

1/30/2017 29

Page 30: Using the Health Information Supply SM) Process to Improve ... · functions and can see the process from patient presentation to payment.” • “This is the first opportunity we’ve

Referral

Assisted Living- Gather info/order

- Contact doc for

med rec

- Call family-consult

Initial Referral Types: phone calls/Email/Walk-in

Refe

rrals

Adm

issio

ns

On c

all

Nurs

eS

ecre

tary

Site R

evenue

Coord

inato

r

Medic

al

Record

s

Referral

Dr. Office- MD office fax

order

- Call family to

set up eval

Referral

Hospital- Pull from referral &

order

- Schedule

consult/eval for

D/C work more

w/social worker

- Identify attending.

Referral

Nursing Home- Gather info/order

- Call family/consult

- Work more with social

worker

Admissions

Face to

Face; determine need;

schedule

Codin

g

Clin

ical

Sta

ff

Referral

Family- Contact doc

for order

/H&P

- Set up

appointment

for call

ITEnter referrals

& leads. Use

pending

reason to

differentiate.

ITAC enters patient

data at referral

ITVerify patient

insurance

information,

coverage, benefit

period

ITEnter insurance

information &

billing sequence

Admitting

NurseCompletes

admission

assessment

Admitting/

On call RNConsult with

physician to

determine Dx

Admitting/

On call RNReports

admissions to

Clinical Staff

2 3

4 56 7

9

1

8

17

18

19

21

22

26

27

28

HISCSM Generated Future State Hospice Flow

= Improvement InitiativesCritical Path

IT

10

AdmissionsBuild chart in

binder as

Admissions

gathers

paperwork

ITEnter Dx + 2nd Dx

Reven

ue C

ycle

sta

rts h

ere

AdmissionsAdmit patient

into Hospice

Pre Admit Triage – obtains patient

info , verify ins; tee-up

family what is needed;

schedule legals

1120

PCM/IDGDiagnosis list

PCSCompile

documents

for Clinical

Staff

PCSFax Med list

to Pharmacy

PCSEnter admissions to

roster; enter

admission to RN;

MSW; Chaplain; HA

schedules

ITWeekly recurring

charge generator to

Revenue Coordinator

ITDiagnoses List in GL with

ability to evaluate &

document relatedness…

13

1416

15 17

23

24

25

30

31

32

ITVisiting Entry: CM;

Hospice Aid;

M&W; SC

30

Medical RecordsCompiles chart; checks for

compliance; Face Sheet

12

SCR/ACFax clinical & other

documents to

Attending

ITData entry of HIM

information; enter

disciplines

SCR/ACTechnical review of

consents & clinical

documentation

ITEntering ongoing LOC

changes; Enter Location

changes; Enter BP events

301/30/2017

Page 31: Using the Health Information Supply SM) Process to Improve ... · functions and can see the process from patient presentation to payment.” • “This is the first opportunity we’ve

• In addition to accurate substantive clinical documentation is the administrative process flow to effectively & efficiently collect & organize documentation for claim submission.

• Linking together clinical & administrative tasks will reduce the waste driving up the cost of the episode. Costs include rework, response time, ‘hunting’ & waiting, for example.

Connecting the dots

1/30/2017 31

Page 32: Using the Health Information Supply SM) Process to Improve ... · functions and can see the process from patient presentation to payment.” • “This is the first opportunity we’ve

Referral

Assisted Living- Gather info/order

- Contact doc for

med rec

- Call family-consult

Initial Referral Types: phone calls/Email/Walk-in

Refe

rrals

Adm

issio

ns

On c

all

Nurs

eS

ecre

tary

Site R

evenue

Coord

inato

r

Medic

al

Record

s

Referral

Dr. Office- MD office fax

order

- Call family to

set up eval

Referral

Hospital- Pull from referral &

order

- Schedule

consult/eval for

D/C work more

w/social worker

- Identify attending.

Referral

Nursing Home- Gather info/order

- Call family/consult

- Work more with social

worker

Admissions

Face to

Face; determine need;

schedule

Codin

g

Clin

ical

Sta

ff

Referral

Family- Contact doc

for order

/H&P

- Set up

appointment

for call

ITEnter referrals

& leads. Use

pending

reason to

differentiate.

ITAC enters patient

data at referral

ITVerify patient

insurance

information,

coverage, benefit

period

ITEnter insurance

information &

billing sequence

Admitting

NurseCompletes

admission

assessment

Admitting/

On call RNConsult with

physician to

determine Dx

Admitting/

On call RNReports

admissions to

Clinical Staff

2 3

4 56 7

9

1

8

17

18

19

21

22

26

27

28

HISCSM Generated Future State Hospice Flow

= Improvement InitiativesCritical Path

IT

10

AdmissionsBuild chart in

binder as

Admissions

gathers

paperwork

ITEnter Dx + 2nd Dx

Reven

ue C

ycle

sta

rts h

ere

AdmissionsAdmit patient

into Hospice

Pre Admit Triage – obtains patient

info , verify ins; tee-up

family what is needed;

schedule legals

1120

PCM/IDGDiagnosis list

PCSCompile

documents

for Clinical

Staff

PCSFax Med list

to Pharmacy

PCSEnter admissions to

roster; enter

admission to RN;

MSW; Chaplain; HA

schedules

ITWeekly recurring

charge generator to

Revenue Coordinator

ITDiagnoses List in GL with

ability to evaluate &

document relatedness…

13

1416

15 17

23

24

25

30

31

32

ITVisiting Entry: CM;

Hospice Aid;

M&W; SC

30

Medical RecordsCompiles chart; checks for

compliance; Face Sheet

12

SCR/ACFax clinical & other

documents to

Attending

ITData entry of HIM

information; enter

disciplines

SCR/ACTechnical review of

consents & clinical

documentation

ITEntering ongoing LOC

changes; Enter Location

changes; Enter BP events

32

Resource Utilization

relative to > 60 day

episode payments

1/30/2017

Page 33: Using the Health Information Supply SM) Process to Improve ... · functions and can see the process from patient presentation to payment.” • “This is the first opportunity we’ve

• January 1, 2016 RHC rate (Days 1-60) $186.84

• January 1, 2016 RHC rate (Days 61+) $146.83

Resource Allocation vs Payment

1/30/2017 33

Page 34: Using the Health Information Supply SM) Process to Improve ... · functions and can see the process from patient presentation to payment.” • “This is the first opportunity we’ve

• Optimizing process flow by understanding the HISCSM

approach provides the ability to separate direct versus burden (overhead) costs.

• Standardizing direct resource tasks to reduce variation drives out waste & improves process flow. This provides clinicians the ability to do more with their time.

• Comprehending waste in burden or overhead leverages the indirect resources to improve capacity – example, less rework in billing increases the number of claims handled the first time shortening the cycle time to submit a claim from date of referral.

Resource Cost Relative to Process Flow

1/30/2017 34

Page 35: Using the Health Information Supply SM) Process to Improve ... · functions and can see the process from patient presentation to payment.” • “This is the first opportunity we’ve

• Palmetto GBA has established #MedicareHISC

• https://twitter.com/hashtag/medicarehisc

• Can be used on-line to search and follow the discussion regarding the Medicare health information supply chain

• Search term = #MedicareHISC

Using the #MedicareHISC hashtag

1/30/2017 35

Page 36: Using the Health Information Supply SM) Process to Improve ... · functions and can see the process from patient presentation to payment.” • “This is the first opportunity we’ve

Harry Feliciano, MD, MPH

Attn: Medical Affairs, AG-275

Palmetto GBA

PO Box 100238

Columbia, SC 30202-3238

[email protected]

Qs & As

1/30/2017 36

Kathy Merrill, MBA, Lean, WOSB

Agilency

705 Pearl Beach

Coldwater, MI 49036

[email protected]