Noridian has started sending out letters to notify hospitals of post-payment review of outpatient HBOT charged records from 2018 (G0277).
See below for the pitfalls of writing the usual HBOT note. If you do not order the HBOT for that day, you will likely not get paid. It also requires documentation of daily progress. The problem with “daily progress” is that there is usually no progress to observe daily. It’s possible the “effect” could be that they “tolerated procedure.” The key take home is that for every treatment day that they request, it appears that the whole chart needs to go with the request.
I get scoffed at when I recommend writing daily orders, but there it is in writing.
As usual, Medicare tees it up. CMS put out this article on Documentation Requirements for HBO on Feb 08, 2019: so it has actually been in place for months.
| Check | Brief Description |
| Legible handwritten physician and/or clinician signatures Signature logs and Signature Attestation Statements [PDF] should be submitted when physician and/or clinician signatures are illegible | |
| Valid electronic physician and/or clinician signatures If an electronic health record is used, the Electronic Order Signature Process Form [PDF] should be submitted to verify provider's Electronic Ordering System is secure | |
| Physician or Non-Physician Practitioner (NPP) order for date of service, if applicable Supporting how many HBO treatments are ordered | |
| Initial HBO evaluation/consultation by the physician or NPP | |
| Documentation supporting HBO covered condition(s) for National Coverage Determination (NCD) for Hyperbaric Oxygen Therapy (20.29) This is not an all-inclusive list For treatment of soft tissue radionecrosis and osteoradionecrosis-documentation of history of radiation therapy including date and site of radiation and conventional treatment patient is receiving adjunctive to HBO For treatment of compromised skin graft-documentation supporting when graft occurred For chronic refractory osteomyelitis-radiographic evidence and/or bone cultures confirming a definitive diagnosis of osteomyelitis, documentation of conventional medical management to which patient did not respond and documentation of conventional surgical management to which patient did not respond | |
| Progress notes HBO clinic/progress notes Clinic/hospital/progress notes prior to starting HBO, if applicable Support of the initial wound/condition etiology Support of prior history of treatment for the condition/wound(s), if applicable | |
| HBO Treatment plan Atmospheric pressures Rest/Air breaks Frequency and number of dives Blood glucose monitoring, if applicable Wound assessments, if applicable Evaluation of progress | |
| HBO dive logs/treatment records Documentation should include minutes completed during HBO treatment Documentation should support when blood glucose measurements are taken and the results, if applicable | |
| Wound treatment records or wound flow sheets supporting measurable signs of healing Wound measurements, if applicable Subjective findings regarding wound, if applicable | |
| Diabetic wound(s) required documentation: Wagner grade classification (must be Wagner grade III of higher) with diagnostic testing to support Wagner grade; Patient has type 1 or type 2 diabetes and has lower extremity wound due to diabetes; Documentation supporting prior failed treatment using standard wound care; Documentation supporting there were no measureable signs of healing for at least 30 consecutive days of treatment when using standard wound therapy; Evaluation of wound at least every 30 days during administration of HBO therapy that supports evidence of measurable signs of healing | |
| Standard diabetic wound care therapy documentation required prior to starting HBO: Assessment of patient's vascular status and correction of problems, if applicable Support of optimization of nutritional status Support of optimization of glucose control Support of debridement of the devitalized tissue Support of the wound care management that includes maintenance of a clean, moist bed of granulated tissue with appropriate moist dressing Support of appropriate off-loading Support of treatment to resolve infection | |
| Evaluation and Management (E&M) documentation, if billed on same date of service under medical review | |
| Itemization of services |
So this is just an extension of what they started earlier in the year. I missed the earlier documentation requirement, but it pretty much follows the TPE and PRIOR AUTH requirements, but is now much more defined.
01-020 Outpatient Hyperbaric Oxygen Therapy (HBO) Notification of Medical Review
Noridian Healthcare Solutions, LLC, as the Supplemental Medical Review Contractor (SMRC) for the CMS, is conducting post-payment review of claims for Medicare Part B of A, Hyperbaric Oxygen (HBO) Therapy billed on dates of service from January 1, 2018, through December 31, 2018. This notification includes the reasons for the review, documentation that will be requested in the Additional Documentation Request (ADR) letter, and resources providers/suppliers may wish to consult when submitting claims.
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- History and physical, at a minimum should include prior medical and/or surgical interventions and previous HBOtreatments
- Physician or Non-Physician Practitioner (NPP) order for date of service
- Diagnosis related to the provision of HBOtherapy and all related services to include onset date of diagnosis
- Initial evaluation and re-evaluations
- Progress/attendance records for each visit billed
- Description of physical findings
- Types of treatment(s) provided
- Number of treatment(s) provided
- Effect of treatment received
- Assessment of any progress made
- Treatment time to support units billed
- Documentation of the procedure (logs) including ascent time, descent time and pressurization level. There should be a treatment plan identifying timeline and treatment goals.
- Valid electronic physician and/or clinician signatures
- If an electronic health record is used, the Electronic Order Signature Process Form should be submitted to verify provider’s Electronic Ordering System is secure
Dr. Fife is a world renowned wound care physician dedicated to improving patient outcomes through quality driven care. Please visit my blog at CarolineFifeMD.com and my Youtube channel at https://www.youtube.com/c/carolinefifemd/videos
