You are receiving this bi-monthly newsletter as a current client, or as someone who requested more information, of Compliance Concepts, Inc. (CCI).

Table of Contents

1. Physician Advisor Services
2. Physician Signature Requirements - Reminder Notification
3. RAC Update
4. ComplianceLine: Support Ticket System
5. SanctionCheck: New Export Option

** Please let us know what you would like to see highlighted in future publications! **

It is often said that timing is everything in life, and this appears to be particularly true with respect to our newly expanded Physician Advisor review services, as the RACs are now poised to begin their long awaited medical necessity audits.

CCI is proud to announce our formal subcontractor arrangement with three prominent physicians with extensive, real-time Utilization Management experience. All three physicians (who are board certified and have each been in practice for over 25 years) currently maintain active practices, while also serving as Physician Advisors and in various medical staff leadership capacities. They have made their services available to CCI and to our clients over the past several months by assisting with admission/observation appropriateness reviews, kyphoplasty audits, and various medical necessity determinations. They have recently expanded their capabilities (which now include physicians specializing in emergency medicine, internal medicine, infectious disease, family practice, urology, interventional radiology, and pain management), and have formalized a contractual relationship with CCI.

We are delighted to be able to offer their expert Physician Advisor services to our existing and new clientele. Please contact CCI at 724-940-0077, to discuss any needs that you might have for our Physician Advisor review services.

Several of our clients are in the process of reviews focused on missing physician signatures, with inpatient services (progress notes and all orders – including “standing” order protocols) accounting for the preponderance of the missing signatures. The rendering physician indicated on the claim (item 24J of the CMS1500 or the electronic equivalent) must match the physician’s signature on the medical record. Remember these points from CMS, Highmark and Palmetto Medicare Services:

Signature's Purpose

Medicare requires the individual who ordered/provided services be clearly identified in the medical records. The signature for each entry must be legible, should include the practitioner’s first and last name and for clarification purposes, applicable credentials are recommended. The purpose of a rendering/treating/ordering practitioner’s signature in patients’ medical records, operative reports, orders, test findings, etc., is to demonstrate the Part B services have been accurately and fully documented, reviewed and authenticated. Furthermore, it confirms the provider has certified the medical necessity and reasonableness for the service(s) submitted to the Medicare program for payment consideration.

Acceptable "signatures" (Definitions of each can be viewed in the MedLearn Matters 6698):

• Handwritten Signature
• Signature Log
• Attestation

Additionally:

• CR 5971 (Transmittal #248 issued 3/28/08) prohibits the use of stamped signatures.
• A dictated note with only a physician name typed at the bottom is not acceptable. The note needs to be signed and dated or indicate “electronic signature on file” in order to validate the provider actually read and is attesting to the information documented in the medical record.
• The use of standing orders must be documented as an order in the patient’s medical record and authenticated by the practitioner responsible for the care of the patient.
  • The timing of such documentation should not be a barrier to effective emergency response, timely and necessary care, or other patient safety advances.
• For reference and exceptions, please refer to the "Medicare Program Integrity Manual," Pub. 100-08, Chapter 3, Section 3.4.1.1 B and MLN Matters article # MM 5971. They are accessible through the following two links:
  • www.cms.hhs.gov/manuals/downloads/pim83c03.pdf (PDF, 643 KB) Medicare Program Integrity Manual, Chapter 3, Section 3.4.1.1.
  • www.cms.hhs.gov/MLNMattersArticles/downloads/MM5971.pdf (PDF, 62 KB)
  • "Standing Orders” in Hospitals – Revisions to S&C Memoranda (dated October 24, 2008), 42 CFR §482.23(c)(2) and §482.24(c)(1)

For more information please visit CCI Consulting Services.

Medical necessity audits may begin soon! The process of seeking approval from the RAC Validation Contractors has already started with a small sample of medical records (10 or less) being requested by the RAC contractor.

The MSDRGs currently being requested include:

1. Chronic Obstructive Pulmonary Disease without CC/MCC= MSDRG 192.
2. Respiratory Signs and Symptoms without CC/MCC = MSDRG 179.
3. Cellulitis without MCC = MSDRG 603.

The RAC contractor will submit their findings from these sample reviews to the RAC Validation Contractor, who will in turn decide if this MSDRG warrants additional requests to the providers.

Contact CCI at 724-940-0077 or dwilson@ccius.com for assistance in your Case Management process!

As we continue to grow, we are constantly looking for ways to improve our customer service. As a result, you may now go to http://support.complianceconcepts.com and submit a trouble ticket that will alert us to any problems you may be having. We would still prefer that you contact us via telephone (1- 800-617-2111) or e-mail to discuss any call center profile changes or operator issues you may be having, but this newest alternative will allow you to document your concern and send it to us 24 hours a day, seven days a week.

Customer service is very important to us and we want you to be able to communicate with us, and us you, when it becomes necessary. If you have any suggestions as to how we can improve our service, please do not hesitate to contact us.

For more information please visit ComplianceLine or contact Steve Evans at sevans@ccius.com.

If you have ever tried to download your SanctionCheck results to a .PDF file, you may have experienced difficulties with batches that include a lot of data. We are aware of how difficult it is to work with .PDF files, whether they include individual certificates or summaries of the names searched; which is why we’ve added the “Export” feature to SanctionCheck.com.

The “Export” feature allows you to download results into an MS Excel spreadsheet in seconds, no matter how large the file. To use this option, while viewing the batch history click on “View All” and filter the results you want (certificates or summary), then click “export,” which is located between the “Print Summary” and “Print ERC Files.”

For more information contact Karan Robinson at krobinson@ccius.com or CCI Support at support@ccius.com.