Let’s have a conversation about the data column on MDM. Specifically, what I’d like to address is imaging services.
When a provider performs an x-ray while seeing a patient, and they are not going to bill a professional component of that test, how do we count that service? Is that service something we can count?
Many of us have turned to utilizing independent interpretation for those services. The provider is independently interpreting it. They’re visually looking at the images. They’re providing their interpretation of those images and then doing patient care. However, is it really independent interpretation? Isn’t it actually the interpretation that impacts patient care? Then, the professional component, which is sent to the radiology department, is subsequently a “quality control” review.
That’s what we’re beginning to see some audits on. You see, it’s always been the rule that overreads are quality control, and overreads, being quality control, are non-reimbursed services. The read that is actually paid by most carriers is the read that impacts patient care. Therefore, I thought I’d come to you today with a warning. It would be highly recommended NOT to count that read as independent interpretation. Could you argue it? Absolutely. What we can make an argument on, I consider to be defendability. However, what we know to be compliance and best efforts would consider this a very big gray area, as again, we are starting to see some of the carriers come back and say this was an overread. These services should have been reported and reimbursed on the actual read.
If you have specific questions on this topic or if you have any other topic you would like to see addressed, please contact me at namas@namas.co.
Your next steps:
- Watch Shannon discuss this topic on the NAMAS YouTube channel. Be sure to subscribe to get notified when new auditing and documentation tips drop!
- Contact NAMAS to discuss your organization’s coding and documentation practices.
- Read more blog posts to stay updated on the 2023 Revisions to the 2021 E&M Guidelines.
- Check out the agenda for the 15th Annual NAMAS Auditing & Compliance Conference and register to attend!
