Documentation Processes

In previous columns, I have discussed the dangers of slipping into a reactive management style as a response to the ever-increasing challenges facing the durable medical equipment industry; and more importantly, the need to adopt a proactive management style in regard to billing and collection processes. But, billing and collections processes are only part of the reimbursement puzzle. A disciplined weekly management review of denial rates, progress toward monthly collection targets and the amount of receivables past 60 days can serve as an early warning system for 
potential problems, but it will do little to prevent them in the first place. It is a truism of this industry that the fate of a claim and whether or not it is 
ultimately paid often rises and falls based on the documentation processes that came first. Given that, a proactive documentation process is required as well. Audits and additional documentation requests are coming to DME providers from a multitude of payers at this point, and a patient that is deemed by a physician to need a DME item or medical supply is no assurance the provider will be paid. Payment now hinges on whether the medical record proves, to the satisfaction of the payer, that the patient’s condition meets rigorous medical necessity rules and is compliant with a host of technical requirements. Legible signatures, documented physician encounters and follow-up visits in specific time frames, precise wording in progress notes, delivery tracking that proves what was shipped and when it was received—the list of required components of a medical record goes on and on, and varies wildly by product. In the end, these lists are far too long and detailed for your often harried staff members to remember. Consequently, product documentation checklists are essential and should be used throughout the intake and documentation process. As a DME provider, you may feel pressure to deliver products before you obtain various key components of the medical record that are needed to secure payment. In the end, the risk versus benefit is up to the management of the company. It is management that should oversee the development of the checklists as well as mandate, on a product-specific basis, which documentation components must be obtained prior to delivery. Dividing the checklist into sections such as “prior to delivery,” “at delivery” and “prior to releasing to bill” will make it easy for staff to follow your management decisions. Some components of documentation need to be obtained long after the initial referral and delivery, such as recertification CMNs, PAP compliance reports, expiring authorizations and renewal prescriptions. Obviously, you will want to make use of your software system features to expire documents correctly or stop recurring claims when new documents are required. This will allow your staff members to run reports that provide information on what documents need to be renewed or newly obtained. A proactive manager will set acceptable time frames for running and working these reports and will run their own reports to understand if the mandated time frames are being followed. If documentation requests fall behind, action should be taken sooner rather than later. But no action can be taken by management if they are not aware of the problem. Any provider that has ever been audited by a payer understands the importance of key phrases in medical records that are required to prove the patient has a medical need for the products ordered. But no matter how diligently your staff works to obtain documents, patient chart notes are not useful to the DME provider if they don’t include these key phrases. Health care providers creating the progress note often do not know the requirements, and may not feel that they have the time to read 20 pages of an LCD to figure it all out. Consequently, the DME provider must educate the referring provider 
regarding documentation requirements. A proactive manager will work with the company’s billing team to develop key phrase cheat sheets that are product 
specific and ensure they are distributed to as many current referral sources as 
possible. Keeping the phrasing examples as simple as possible is key to getting your referral sources to adopt them in their charting habits.