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Prepare for 2021 Coding Changes: Practice Checklist

by Dr. Susan Kressly, MD, FAAP

2021 Coding Changes: Practice Checklist

This checklist is intended for pediatric practices, to prepare for the upcoming changes to coding/documentation that will take effect on January 1, 2021. A printable PDF of this checklist can be found at the bottom of the page. 

September 2020

  • Designate a point person to lead this critical effort for the practice
  • Purchase a subscription to the AAP Coding Newsletter
  • Communicate with every provider and make them attest that they have watched this video
  • Share this AMA resource with all providers and hold a practice meeting to discuss
  • Agree on an office education plan and block out the appropriate time to implement

October 2020

  • Review provider workflow and identify where work related to a visit is not done on the date of the visit – which may impact time based coding
    • Example: Review records, chart prep, note finalization
  • Agree on adjustment of provider schedule to be more realistic about same-day review, chart prep, and documentation – and implement the effective date
    • Example: Effective 12/1, providers are expected to be in their seats to review their daily schedule and begin chart preparation 30 minutes prior to the first scheduled appointment; there will be catch-up time in the AM and PM sessions to facilitate timely documentation.
  • Discuss billing workflows with your billing team that have implications for note finalization and billing status
    • Note: If you are in the habit of marking notes “ready to bill” prior to midnight of the date of visit – that will make it difficult for you to incorporate time that is not captured before the provider leaves the office 
  • Create a plan for any change in billing workflows and confirm an effective date to implement that plan
  • Perform a review of E/M coding distribution trends per provider for 2019 and for the first 3 quarters of 2020 (likely not representative based on COVID-impacts) and share that data with your providers
  • Execute provider deep-dive education on Time Based Coding
  • Discuss with providers the impact of new time coding rules and potential impact to the bottom line

November 2020

  • Outline and finalize a plan for provider internal auditing and education program as part of a Continuous Quality Improvement Project
    • Note: Include time blocked through 2021 to implement
  • Agree on an internal auditing tool that practice will use for auditing purposes.
    • Note: AAP guidance forthcoming
  • Execute provider deep-dive education on Medical Decision Making (MDM) Coding
  • Discuss with providers the impact of new MDM coding rules and potential impact to the bottom line
  • Identify an internal process for appealing claim rejections based on payers non-adherence to new guidelines
  • Identify a team to handle any payer audits or requests for notes/documentation and create a step-by-step plan which includes roles and responsibilities and what to release
  • Identify any adjustments that will need to be made to templates (including removing “note bloat”) and identify a point person to do this work and when it should be done

December 2020

  • Educate your team on your EHR’s new features that support the coding changes
  • Require providers start documenting MDM in a way that will be supported in January
  • Review/audit provider notes for starting your QI project to educate and improve documentation/coding as part of an ongoing internal audit process
  • Have every provider sign a document stating they understand the changes that are coming, they take responsibility for choosing the most appropriate E/M level based on new coding guidelines, and they commit to a process of continuous improvement
    • Note: If they remain unsure, arrange for more training/education

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