An auditor told me, ‘it’s common sense’ when I questioned why she failed coders’ E/M levels.
Of course, we’re talking about the 2021 EM levels for office and other outpatient services.
Look, abstracting using the 2021 guidelines has temporarily slowed down production. That’s to be expected.
I’d rather have coders slow down, correctly interpret the documentation based upon the new guidelines, and code accurately. In my experience, when a new policy, procedure, or guideline is implemented, it’s a sure bet that OIG and/or CMS will perform audits the following year.
The auditor was the E/M guru (before the new guidelines), but she was not auditing based upon the new method of determining levels of Medical Decision-Making or time-based coding.
For the past few months, coders were encouraged to study the new guidelines and the new MDM table and practice coding a few notes each week based upon the January 1st changes. Companies and consultants have made a LOT of money hosting webinars.
And, she missed all of this? Yes, because she was still the E/M guru in her mind and the changes were just ‘common sense.’
She missed the change in coding based upon time for office/outpatient services. She didn’t know that levels can be coded based on whether or not providers document that counseling and/or coordination of care dominate the encounter.
She missed that Moderate complexity for Diagnostic Procedures Ordered is not Moderate complexity for the Amount and Complexity of Data to be Reviewed and Analyzed as of January 1st.
Among other critical changes, she also missed that documentation of Diagnosis or treatment significantly limited by social determinants of health translates to Moderate risk of morbidity from additional diagnostic testing or treatment.
So, it’s not just ‘common sense’; it’s the guidelines.