Coding Compliance Strategies in the COVID-19 Era

Thoughtware Alert Published: Nov 05, 2020
Healthcare worker wearing mask and providing care

Are you remaining compliant through the turbulent changes of the COVID-19 pandemic?

During the COVID-19 pandemic, many rules, regulations, and guidelines changed. Along with those changes, the disease process was not understood—and still today, we’re learning more about the COVID-19 virus. The Coronavirus Aid, Relief, and Economic Security Act (CARES Act) offers relief, including a 20 percent add-on payment to the diagnosis-related group (DRG) rate for COVID-19 patients.  

Effective September 1, 2020, CMS updated the billing requirements to include that inpatient COVID-19 encounters document positive viral test results. This update challenges the requirements for increased DRG reimbursement under the CARES Act. Claims that cannot support a COVID-19 diagnosis with a positive laboratory test within 14 days of an admission may be subject to post-payment audit and potential payment recoupment. 

On September 9, 2020, the Office of Inspector General announced it will audit Medicare discharges that qualified for a 20 percent add-on payment. The expected issuance date is 2022.  

With cash flow at a historic low for many hospitals and the cost of caring for these critically ill patients continuing to rise, the documentation, coding, and reporting of COVID-19 encounters must be accurate and correct.

What should you do?

  • Analyze hospital-specific data:
    • Identify potential claims that fall under the COVID-19 regulatory guidance
    • Identify possible reporting practices that may be problematic
    • Create a perpetually updated document to monitor COVID-19 case processes
  • Assess documentation for support of the COVID-19 diagnosis:
    • Use the “ICD-10-CM Official Coding and Reporting Guidelines,” Chapter 1: Certain Infectious and Parasitic Diseases (A00-B99), U07.1, which can be found here
    • Develop coding policies, queries, and examples of accurate coding for COVID-19 encounters
    • Identify current denials and identify possible appeal claims
  • Track COVID-19 cases through the entire process:
    • Define and establish COVID-19 coding workflows and queues
    • Develop reports to track claims through the CDI, coding, billing, and reporting process
    • Track results
    • Identify process improvement opportunities
    • Implement changes quickly

BKD Can Help

Along with documentation, coding, and reporting of COVID-19 encounters, a facility should be able to demonstrate strong compliance efforts. BKD’s coding compliance team can assist you in completing concurrent and retroactive documentation and coding assessments of COVID-19 encounters to help you demonstrate strong compliance practices. 

For more information, reach out to your BKD Trusted Advisor™ or submit the Contact Us form below.

This information is only valid as of the date of this publication and is subject to change. The content was presented for illustrative purposes and your information only. Applying this information to your situation requires careful consideration of facts, circumstances, and timing of requirements. Consult your BKD advisor or legal counsel to apply to your unique situation and circumstances.

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