Denial Letter Processes with Participation from Health Services Advisory Group (HSAG) Presented by Service Denial Standardization Team – Main Service Denial Standardization Team – Medi-Cal Appeals & Grievances Team Colleen Anderson, LVN, BS Melony Davis, BA Jennifer del Villar, CHC Novella R. Quesada, RN, BSN, PHN Get to know your presenters Colleen Anderson, LVN, BS 1 Write a clear and simple understandable denial reason Correctly cite source of UR Criteria Use of appropriate denial rational Use of correct template for service denied Refer to ICE Medicare Advantage Pre-Service Denial Reason Matrix (Revised 10/15/10) NOTE: Links were updated as well [a guideline not a regulation] Clear and concise rationale Correct Criteria Clinical info 5 Lack of clinical reasoning Heavy in medical jargon Criteria or guidelines are not identified Blended decisions Poor syntax Inadequate editing or proof reading 6 2 Denial Reason Easy for member to understand (avoid abbreviations and acronyms) CMS states reading level of member materials shall be at 8th grade reading level or lower http://www.cms.gov/Regulations-andGuidance/Guidance/Manuals/Downloads/com109c02.pdf UR Criteria source Refer to clinical information Cite Medicare Guidelines [Medicare Criteria Trumps All Others] ◦ Health Plan Criteria/Guidelines ◦ Provider Group committee approved Criteria/Guidelines ◦ National Coverage Determinations (NCD) ◦ Local Coverage Determinations (LCD) Other Criteria ◦ Milliman Care Guidelines ◦ InterQual Best Practices 3 A service or item, or supply for which Medicare reimbursement is not available Hearing aids Personal care or custodial care Non-medical services Alternative medicine Miscellaneous (Non Medicare and non-plan covered) Page 31, Reason # 58* According to Medicare guidelines [Specify benefit] are not a Medicare covered benefit and is excluded from coverage under your health plan. Please refer to the Health Plan’s Member materials for benefit guidelines. * Refers to ICE Medicare Advantage Pre-Service Denial Reason Matrix Medical Necessity vs. No Medical Necessity Service that is reasonable or necessary, or services or supplies that: - are proper and needed for the diagnosis or treatment of a medical condition - are provided for the diagnosis, direct care, and treatment of a medical condition - meet the standards of good medical practice - are not mainly for the convenience of a member or doctor 12 4 No Medical Necessity Page 32, Reason # 61 The service requested was reviewed by our physician reviewer. According to [name of guideline and its description used to make the decision]. The medical documentation received does not support the need for this service because [insert specific patient information]. It was determined that there was no medical necessity for this request. Readability Calculate the average sentence length (ASL) = number of words per sentence How to calculate readability level Flesch Kinkaid Calculate the average number of of syllables per word (ASW) FK formula: (0.39 X ASL) + (11.8 x ASW) – 15.59 = Readability level 15 5 Microsoft 2003 1 Click on the "Tools" menu, then click "Options" and click on the "Spelling & Grammar" tab. 2 Check the "Check grammar with spelling" box. 3 Check the "Show readability statistics" box, then click "OK." 4 Click the "Spelling and Grammar" icon, which looks like the letters "ABC" with a check mark. Microsoft Word checks the spelling and grammar, then displays the readability statistics. 16 Click “Microsoft Office” Logo Click “Proofing” Click “show readability statistics” Click “Ok” 17 Based on National Coverage Determination for Cardiac Rehab (21.10), you do not meet the Medicare criteria. The guidelines required to meet medical necessity is that rehab needs to be within 12 months of a qualifying cardiac event. Based on your medical records received, there is no documentation of a qualifying event within the last 12 months; therefore your request is denied. For further treatment please schedule an appointment with your PCP Dr. XXX at XXX to discuss alternative options. Readability Level: 11.7 6 Based on National Coverage Determination for Cardiac Rehabilitation (rehab), you do not meet the Medicare criteria. The guidelines say medically necessary cardiac (heart) rehab needs to start within 12 months of certain heart problems. We reviewed your medical records and you did not have a heart problem that meets the criteria. Therefore, this request is denied. Please contact your PCP, Dr. PPP at XXX-XXX-XXXX to schedule an appointment to discuss other options. Readability Level: 7.8 Medicare guidelines for acupuncture state that the use of acupuncture may be appropriate as a second or third line treatment for a patient not responding to conventional management or not tolerating medication or experiencing recurrent pain. Based on the submitted medical information, our Medical Director cannot determine what treatments you have already tried and failed. Acupuncture may be considered if you have tried other treatments and they have not been effective. You may contact your PCP, Dr. XXX to discuss care alternatives. Readability Level: 13.7 Medicare guidelines for acupuncture say it can be used only if other treatments are not working. Patients must first try other methods such as medication or therapy. Your medical records do not say what treatments did not work for you. Our medical director has denied your request for acupuncture. Please call your doctor, Dr. X, to discuss treatment options. Readability Level: 7.8 7 Novella R. Quesada, RN, BSN, PHN Identify when to deny service if not covered by Medicare Determine if a denial letter is required Identify difference in Turn-Around-Time (TAT) Identify when to use Informational Letter 23 http://www.dhcs.ca.gov/services/medical/Pages/MediBen_Svcs.aspx http://www.medicaid.gov/ 8 PMG responsible for Medicare and Health Plan responsible for Medi-Cal If not covered by Medicare verify Medi-Cal coverage If not covered by Medicare but covered by Medi-Cal forward authorization request to HP for Medi-Cal authorization. Do not use Informational letter – Medi-Cal coverage is not a carve out. **Remember TAT for Medicare is 14 days, Medi-Cal is 5 business days.** 25 Services not covered by Medicare that Medi-Cal does cover Shower rail Hearing aid Incontinent supplies Shower chairs B/P cuff Compression stockings Medicare covers for weeping wounds only Medi-cal covers for diabetics and lymphadema Non-Emergency Medical Transportation Medicare covers from home to dialysis – ambulance only Medi-Cal covers for specific non-emergency services 26 Clear and Concise Denial Rationale ◦ Understandable to members ◦ Reading Level 6th grade or lower [Medi-Cal] 8th grade or lower [Commercial] ◦ Clear and Concise explanation of the reasons for decisions ◦ Refer to name and source of the benefit provision, guideline, protocol or other similar criterion on which the denial decision is based on Milliman Care Guidelines for MRI of the knee Interqual Criteia for Physical Therapy XXX Medical Policy for Gastric Bypass American Society of Gastroenterology guideline for follow-up Colonoscopy, etc. 27 9 The treatment is determined not to be medically necessary or does not meet UM criteria Not enough medical information was received to determine if requested service is medically necessary ◦ You must refer to the service requested and cite the criteria not met based on the information provided The treatment is not a covered benefit The proposed length of stay does not meet our UM criteria Specify name and source of criteria Specific to member’s condition Clear, concise and simplified Refer to ICE Medi-Cal Denial Matrix 29 Notice of Action(NOA) Templates & Attachments & Attachments Notice •Denial Of •Modify Action(NOA) •Delay •Terminate •Your Rights In addition •State Fair to NOA Hearing Request Form •Language Assistance Form 30 10 31 Informal pend during decision timeframe ◦ Phone calls, e-mails, messages for clarification and additional information by fax ◦ Only contact with provider ◦ Does not delay decision Formal pend before time runs out ◦ ◦ ◦ ◦ ◦ Use layperson language Be specific to member and provider Details, details, details Avoid extra effort/time/touches Ex: Consult report from Dr. X; Lab reports from 1/12 32 All examples can be applied to both Commercial and Medi-Cal/Medicaid 11 DenialRational– Sample1 Reviewofyourmedicalinformationindicatesthatyouhavenot mettheclinicalcriteriaforCTofthesinuses.PerXXXGuidelines forCTscanofthesinuses:ChronicSinusitis/Rhinosinusitis 2 *SINUSITIS/ RHINOSINUSITIS *Definedassignsandsymptoms ofsinusitis thatlastfor12weeksorlonger*Imagingusedto corroboratethediagnosisand/orinvestigateforunderlying causesofchronicsinusitis*Clinicians shouldassesspatients withchronicsinusitis/rhinosinusitis forfactorsthatmodify management,suchas,immunocompromised states,ciliary dyskineallergic rhinitis,cysticfibrosissia andanatomic variationsCOMMONDIAGNOSTICINDICATIONSFORSINUSCT: *NASALAIRWAYOBSTRUCTIONREFRACTORYTOMEDICAL THERAPY.Thisdeterminationwasmadebaseduponourreview ofyourhealthconditioninrelationtoXXXCriteriaforCTofthe Sinusesmedicalnecessitycriteriaorguidelines.Foradditional informationandyourfuturehealthcareneeds,pleasecontact yourPrimaryCarePhysician. 34 Reading level at 23.4 Heavy on Medical Jargon Confusing to the member Unclear why request is being denied 35 We cannot approve your request for a CT scan of your sinuses. Based on the records we received, this scan is not medically necessary for you. A CT scan is medically necessary for sinusitis (swelling of the sinuses) when symptoms have not gotten better after 3 to 4 weeks of treatment, when symptoms last more than 12 weeks, or when you have sinusitis more than 3 times a year. Your records do not show that you have had any of these problems. We based this decision on the XXX Guideline for Computed Tomography (CT) Paranasal Sinus and Maxillofacial Area. FK6.0 36 12 XXX guidelines for botox injection indicate are only used to treat blepharospasm, facial nerve, hereditary spastic parapherisis, idiopathic torsion dystonia, cerebral palsy, multiple sclerosis, neuromyletis optica, organic writer’s cramp, orifacial dyskinesia, schilder’s disease, spastic hemiplegia, spasticity related to stroke, spinal cord injury, or traumatic brain injury, symptomatic torsion dystonia or other forms of upper motor neuron spasticity. Based on the medical information provided, you have been diagnosed with fibromyalgia (chronic pain) which does not meet XXX HMO’s criteria, therefore the service has been denied. 37 Corrected Rationale Denial We cannot approve your request for Botox injection. This treatment is not medically indicated for your condition of chronic pain (pain that last for a long time) caused by fibromyalgia. Based on XXX criteria for Botox Injection, Botox is not indicated to treat fibromyalgia. Botox is for certain nerve diseases that you do not have. For more information and your future healthcare needs, please contact your PCP. FK5.4 38 ICE Denial letters Commercial http://www.iceforhealth.org/library.asp?sf=&scid=702#scid702 Medicare http://www.iceforhealth.org/library.asp?sf=&scid=2431#scid2431 Medi-Cal http://www.iceforhealth.org/library.asp?sf=&cid=305#cid305 39 13 40 FAQ for this session will be posted at http://www.iceforhealth.org/viewfaqsall.asp Pending items requiring regulatory or accrediting body input may be posted at a later date. ICE SDS – Main meets 1st Wednesday of even months (Feb, Apr, Jun, Aug, Oct, Dec.) from 1:00 – 3:00 pm. Medi-Cal Team meets the 2nd Thursday from 2:003:00 p.m. (team on hiatus at this time) Appeals & Grievance Team – Meets every quarter Please join a team to receive broadcasts 41 To contact the leads of this ICE Team - Access the Teams page on the web site via the following link; http://www.iceforhealth.org/teamactivities.asp 14 Expedited Determinations Cheryl Cook, RN Project Director, Beneficiary and Family Centered Care Health Services Advisory Group of California, Inc. (HSAG) Objectives Determine when it is appropriate to give the Notice of Medicare Non-Coverage (NOMNC). Explain the reconsideration process and how the process affects the provider and the patient. Explain the barriers to effective delivery of the NOMNC. Demonstrate how to complete the generic NOMNC with all the documentation required by CMS. 2 11/20/2012 Impact on Beneficiaries and Providers Beneficiaries Gives notice of impending discharge Protects the rights of Medicare beneficiaries Establishes financial liability Providers CMS audits the process Invalid notices cost money, waste time, and can confuse patients 11/20/2012 3 Health Services Advisory Group –1– Expedited Determination Process Overview The provider or the Medicare Advantage (MA) plan issues the NOMNC. The beneficiary or representative calls to initiate an appeal review. HSAG requests the medical record. The record is reviewed by a California physician. All involved parties are notified of the decision. 4 11/20/2012 Responsibilities of the Provider The NOMNC is issued when ALL skilled services are no longer required. Even if the beneficiary agrees with the discharge, ISSUE the notice! 5 11/20/2012 When the NOMNC is Not Required Admission to higher level of care Unsafe environment – (such as unsafe neighborhood with home health) Patient moves out of the area Patient signs up for hospice Patient exhausts their benefits 11/20/2012 6 Health Services Advisory Group –2– QIO Availability QIO accepts patient requests for an appeal reviews 24 hours/a day, 7 days/a week, 365 days/a year. After business hours, voicemail system is in place. QIO performs reviews every day of the year, including holidays. 7 11/20/2012 Obtaining the Notices www.cms.gov/BNI 8 11/20/2012 NOMNC 11/20/2012 9 Health Services Advisory Group –3– Validating the Notice HSAG is required to validate the NOMNC when the appeal is requested The following may invalidate the NOMNC – – – – Expired form (outdated) Wrong time frames Wrong dates Wrong QIO phone number 10 11/20/2012 Timing Requirements Providers – Skilled nursing facility (SNF): Notice issued two days prior to planned discharge – Hospice: Hospice issued second to the last visit – Home Health (HH) / Comprehensive Outpatient Rehabilitation Facility (CORF): Notice issued on the next to the last visit 11 11/20/2012 Time Frames Medicare beneficiaries/members have until 12 p.m. (local time) the day before the effective date to request a timely appeal. – MA member requests received after that time will be referred back to health plan. The QIO will request medical information from providers/health plans. Providers/health plans are required to send requested medical information to the QIO by COB on the day of request. – HSAG will make several attempts to obtain medical information before reaching a final decision. The QIO will make a decision within one day after receipt of all medical information. – HSAG has met/exceeded CMS’ review timeliness threshold (≥ 95%). 11/20/2012 12 Health Services Advisory Group –4– Reconsiderations For Fee-for-Service (FFS) beneficiaries, Maximus completes the second review. For MA beneficiaries, HSAG completes the second review. – When HSAG does the second review, a physician not involved with the original decision reviews the chart. If the reconsideration is unfavorable to the beneficiary, they can appeal to the Administrative Law Judge (ALJ). 13 11/20/2012 Issues Related to Delivery Patient won’t sign NOMNC Patient is unable to make decisions/ speak for himself/herself – Need to speak with patient’s representative • Legal types (e.g., Power of Attorney, Healthcare surrogate, etc.) • State law definition (e.g.,Next of kin, etc.) Representative delays – Will not answer/return calls – Gives excuses 14 11/20/2012 Tips for Success Develop internal process, stick to it Educate all staff members regarding appeal process – Staff needs to know who/what HSAG is – Staff needs to be familiar with notices, where to find notices – Staff needs to know they can send PHI to HSAG Use current version of NOMNC – Obtain from www.cms.gov/bni 11/20/2012 15 Health Services Advisory Group –5– Tips for Success (cont.) Copy of NOMNC – Beneficiary – Medical record Ensure HSAG has your organization’s appeal contact information Submit requested information as quickly as possible to HSAG – By COB on day of request – HSAG will make courtesy calls to providers Consistent, concise documentation found in medical record 11/20/2012 – Inconsistent documents do not provide clear picture 16 Tips for Success (cont.) Discharge plan – Next steps for patient – Poor planning – one of the common drivers for readmissions 17 11/20/2012 Common Drivers for Readmissions Lack of standard discharge processes Lack of engagement or activation of patients and families Patients call 911 or return to emergency departments instead of accessing a different type of medical service Ineffective or unreliable sharing of relevant clinical information Patients did not understand/did not correctly take medications 11/20/2012 18 Health Services Advisory Group –6– Common Elements of Safe and Effective Care Transitions Medication reconciliation occurs. Patients and caregivers are involved and prepared. Person-centered care plans are communicated in a timely manner across settings. The sending provider maintains responsibility for the patient’s care until the receiving clinician/ location confirms the transfer and assumes responsibility. 19 Medicare FFS Readmission Data April 2011 to March 2012 California All‐Cause 30‐Day Readmission Rates Setting Discharged To Number of Discharges Number of % of 30‐Day 30‐Day Discharges Readmits to Readmit Readmitted another Rate within 30 Days hospital Home 392,005 Skilled Nursing Facility 176,345 67,985 40,139 17.3% 22.8% 26.1% 26.4% Home Health Agency Hospice Other All 25,553 582 10,897 145,156 20.6% 3.7% 20.5% 19.1% 21.8% 35.9% 41.0% 26.6% 123,903 15,771 53,076 761,100 20 11/20/2012 Medicare FFS Readmission Data April 2011 to March 2012 Number of Days from Discharge to Readmission Setting Discharged To Home Skilled Nursing Facility Home Health Agency Hospice Other All 11/20/2012 Number of 1‐7 8‐14 Days Readmissions Days 67,985 36.1% 24.7% 15‐21 22‐30 Days Days 19.4% 19.8% 40,139 32.5% 26.2% 20.5% 20.9% 25,553 36.0% 26.2% 19.4% 18.5% 582 10,897 145,156 43.0% 23.7% 38.6% 22.1% 35.3% 25.2% 17.2% 16.2% 17.9% 21.4% 19.6% 20.0% 21 Health Services Advisory Group –7– Conclusion Beneficiary has right to request review of pending discharge/termination of skilled services. NOMNC is the form to use. Poor discharge planning can lead to readmissions. 22 11/20/2012 Contact Information Cheryl Cook, RN Project Director, Beneficiary and Family Centered Care 813-865-3545 Jennifer Wieckowski, MSG Program Director, Care Transitions 818-427-4378 Medicare Quality Improvement Organizations convene providers, practitioners, and patients to build and share knowledge, spread best practices, and achieve rapid, wide-scale improvements in patient care, increases in population health, and decreases in healthcare costs for all Americans. www.hsag.com 11/20/2012 This material was prepared by Health Services Advisory Group of California, Inc., the Medicare Quality Improvement Organization for California, under contract with the Centers for Medicare & Medicaid Services (CMS), an agency of the U.S. Department of Health and Human Services. The contents presented do not necessarily reflect CMS policy. Publication No. CA-10SOW-7.2-092412-01, FL-10SOW-2012FS3T10-11-342 23 Health Services Advisory Group –8–
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