Overcome ACP problems with some simple measures
As per a new OIG report, Medicare’s Advance Care Planning (ACP) experienced a bumpy ride during the pandemic. Basic mistakes by the providers are the primary reason behind them.
The ACP service has been payable since 2016 through a 30-minute code 99497 and an add-on code 99498. It was observed that between the years 2020 and 2021, code 99497 grew by 10% (after the fall in 2019) whereas the use of 99498 went down.
Documentation errors
OIG discovered that the reason behind the problem is simple ignorance of ACP billing by the providers. Some cited error types were:
Failure to distinguish the time spent: Many providers documented the ACP service but did not distinguish between time spent face-to-face with the beneficiary and time spent on concurrent services.
Discussion not documented: As per OIG findings, in several cases, the code was billed properly, but providers did not document the medical records that an ACP discussion occurred.
Reasons for multiple sessions were not included: CMS’s FAQs section specified that “when the service is billed multiple times for a given beneficiary, we would expect to see a documented change in the beneficiary’s health status and/or wishes regarding his or her end-of-life care.”
OIG found an instance where a provider attached a separate ACP charge to 26 claims for a patient’s follow-up or medication refills with no documentation or reason.
Three ways to get more ACP
Educate and support patients: Healthcare providers should play a pivotal role in educating and supporting patients in ACP by asking the right questions about the goals of care, sharing information about various post-acute care options, and opening the door for patients and their families.
Get expert advice: If providers do not feel confident about approaching the subject with patients, they should seek guidance from post-acute care partners that are experts in the space.
Review the rules: The OIG suggests providers read the CMS FAQs and the related MLN Fact Sheet regularly to know the nitty-gritty of ACP. The more they know, the more comfortable they are with the process.
At present, a broad range of qualified health personnel can perform ACP services, but only physicians and other providers working within their state scope of practice can bill for it directly. But there’s a movement afoot in Congress to expand Non-Physician Practitioner (NPP) eligibility at the federal level.
