Wiki 2021 E/M Updates- Medical Necessity

NicoleSprecher

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I have a question regarding the new 2021 E/M guidelines. I am coding and also performing audits by using the Namas audit tool. After all the webinars and workshops I did to prepare for the 2021 change I was never made aware of that there are steps within the audit to validate the medical necessity and not to only use the MDM to select level of service.
Wondering if anyone could advise on this? Do you also use a medical necessity formula that could trump the MDM?
Any advice would be great! Thank you so much!
 
My advice regarding medical necessity has always been that this is something that is outside the scope of a coder's training and incorporating medical necessity into a coding process should only be done with great care and with the participation of a provider or trained clinician in your organization.

Coders are trained to assign codes based on documentation, and when it comes to using medical necessity as a criteria, you are basically authorizing coders to 'override' documentation - in other words, to disregard certain components of the documentation and being not a necessary part of the patient's care and therefore not eligible to be counted toward the code assignment. In the hands of a coder without clinical training, this becomes a very subjective exercise leading to coder's making decisions such as 'this patient doesn't seem very sick'. But coders are not trained in medical standards of care and can't know what particular symptoms or conditions require a provider to do a more thorough exam or spend more time ruling out potential issues, which is why it's so important to always do this under the guidance of someone with the appropriate training. Medical necessity is an important consideration and documentation does need to support the necessity of what is billed, but in my experience, when coders start making independent decisions about medical necessity and t down-code services without their providers' involvement, this can cost a practice significant revenue loss and also eventually lead to an unpleasant confrontation with providers.
 
There are some tools you can use (NAMAS has one) that illustrate medical necessity based on the nature of the presenting problem, but the steps that the provider takes in his/her treatment of the problem is based on their clinical expertise. No auditor should question that, unless the documentation doesn't illustrate any plan of care at all.

The 2021 guidelines have been developed to place the E&M level of service choice in the hands of providers....without the bullet-counting, the MDM remains under the authority of the physician. Auditors can make suggestions with regards to time, documentaiton of data, and explaining the table of risk, but I have always maintained that it is way outside the scope of an auditor to question the provider on the medical necessity of the care provided. That is their call.

The changes in 2021 have moved provider responsiblity for LOS selection right to the front row.
 
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