Some of my colleagues claim that score sheets used by Medicare reviewers to evaluate the “diagnosis and management options” component of medical decision-making documentation define a new problem as one that is new to the examining physician. Are they correct?
Physicians at the 600-physician Marshfield Clinic, a regional 32-site multispecialty group based in Marshfield, Wis., use the definition you've described, and so do other physicians across the country.The documentation guidelines were beta-tested at Marshfield Clinic before HCFA released them in 1994, according to Catherine Fischer, reimbursement policy adviser for the group. As part of that process, Marshfield Clinic staff helped their regional Medicare carrier to develop an audit worksheet that included score sheets for the decision making portion of the documentation guidelines. The carrier medical director continued developing the worksheet after taking a post at HCFA, and a version was eventually distributed to carriers for use by auditors. HCFA acknowledges that its reviewers use score sheets.Fischer says it was Bart McCann, MD, former executive medical officer at HCFA, who offered the definition of a new problem that you mention. “His explanation makes complete sense,” Fischer says. “The decision making guidelines were designed to give physicians credit for the complexity of their thought processes. Giving a physician more credit for handling a problem he or she is seeing in a particular patient for the first time, even when that problem has been previously identified or diagnosed, is within the spirit of the guidelines.”But that definition never made it into the documentation guidelines, because the score sheets didn't. The score sheets that define a new problem as new to the examining physician are part of the Marshfield Clinic's audit worksheet, which is now used by physicians, professional coders, Medicare carrier staff and the Office of Inspector General to evaluate documentation, Fischer says. The worksheet is sold by the Medical Group Management Association (303-397-7888).Before you decide to follow your colleagues' lead, there are a couple more facts you should consider: A score sheet obtained from a carrier by FPM and used as a source for the FPM Pocket Guide to the Documentation Guidelines1 defines a new problem as a previously unidentified or undiagnosed problem.HCFA acknowledges that its reviewers use score sheets but says their use is neither encouraged nor prohibited.We suggest you ask your regional Medicare carrier's medical director how reviewers evaluate the complexity of decision making. If they use score sheets, ask how a new problem is defined for the purposes of scoring diagnosis or management options. If they don't use score sheets, make sure they're including diagnosis and management options and data reviewed in their assessments. The table included in the guidelines makes risk the most concrete of the three decision making components, but all three must be carefully evaluated to fairly approximate the physician thought process.