The 2023 AMA documentation guidelines hit us on June 30th -and I’ve had a chance to read through them. I want to remind you that while we have the AMA changes, we don’t yet have the final rule from CMS. We don’t know how CMS is going to process all of these changes. As you’re reading these guideline changes, just remember, we know how these changes are going to appear in the AMA manual for 2023 (remember what happened with prolonged services). So, we need to understand we have the fundamental changes as they will happen, we have guideline changes as they will happen, but the interpretation by CMS may change, and that will come when the final rule comes. So, have you read through them yet? There are some interesting nuggets in there:
New Versus Established Patients — now, not much controversy there, but the thing that AMA has helped us to clarify so well is what happens when one provider is taking call for another provider. That’s actually in the guidelines now. It states that the on-call provider should bill for the patient as the status of the on-call provider. That’s going to get a little messy, though, isn’t it? There are going to be some hurdles that we must take notice of with these new guideline changes, but at least for us as auditors, compliance professionals, and coders alike, we have some guidance. We will need to figure out how to nuance those within our practices in our everyday world. Great guidance, though. Next thing:
Emergency Department — Big changes are coming for our ED providers, but are they really? I think what we get for the ED is clarity, right? Right now, in the emergency room, realistically (let’s just be honest, right?), the difference is a level 3, a level 4, a level 5. Yes, we have occasional level 2’s, but for most of the patients that come into the emergency room, the question becomes, is it a level 3? Is it a level 4? Is it a level 5? and in most of our emergency rooms (let’s just be honest with our emergency room providers), it’s, “is it a level 4 or is it a level 5?” In those instances, we’re taking the office 2021 guidelines and applying them in the emergency room, without time. Obviously, we can’t use time in the emergency room, so it’s MDM, so it is going to be a level 2 is straightforward, a Level 3 is low, a level 4 is moderate and high is a level 5. I think this actually clarifies the intent of a level three, a level four, and a level five in the emergency room space much more.
NAMAS will create some tools and some comparison charts like we did for the original documentation guideline changes to make it a little bit easier when you’re educating your physician, so look for those to come. Also, your initial and subsequent inpatients, I mean realistically, everything has now converted to 2021 changes.
The other thing you should look for is some improvement and adaptation of wording for the office-based, and they’ve also added a new category; Acute Uncomplicated Stable. I’m a little bit curious…I read it, and I’m still in a little bit of a quandary. I’m not sure why we need that category. There’s also a new category that was added to the risk category for inpatient status, so there are a lot of good nuggets there; give it a review.
NAMAS will have a webinar coming very soon, and also in the fall, will have a webinar series out for you. Look for those. But I really think, all-in-all, this is going to help our providers remember it’s “patients over paperwork”.
One last tip I can give you about creating education for your providers…I think one of the fails we did, (I’ll own this as well) was when we educated providers on the 2021 changes; we tried to make the changes comparable to the current. I think that’s where providers kept their existing templates and their existing documentation style. So, I think as we look at this implementation of changes, we really need to embrace these as changes and not merely as a crossover or a blend. That’s my challenge to you as you read through the 2023 documentation guideline changes.