PAGE: 1 of 3 / REPLACES POLICY DATED:4/16/99, 8/1/00, 6/1/02, 3/1/04, 11/30/04 (HIM.COD.011), 3/6/06, RETIRED 11/3/09 (replaced by REGS.COD.017)
EFFECTIVE DATE: January 1, 2009 / REFERENCE NUMBER: REGS.COD.011
SCOPE: All Company-affiliated facilities including, but not limited to, hospitals and all Corporate Departments, Groups and Divisions, including, but not limited to, the following departments:
Facility Health Information Management DepartmentNursing
Corporate Regulatory Compliance Support Ancillary Departments
Case Management/Quality Resource Management Legal
National Agreements/Materials Management Finance
Ethics & Compliance Officers Service Centers
Administration
PURPOSE: To ensure that all ICD-9-CM and CPT coding reviews of medical records for outpatient and inpatient services and education related to such reviews performed by external vendors are compliant with official coding guidelines, Company coding policies, and other regulatory requirements.
POLICY: ICD-9-CM and CPT Coding reviews performed by external vendors will only be completed by vendors who have been certified to meet the quality and business practice standards outlined in this policy. Certification of vendors is the responsibility of the Corporate Regulatory Compliance Support Department. Contract negotiation is the responsibility of National Agreements. This policy does not apply to chargemaster reviews or coding/billing reviews for physician professional services.
PROCEDURE:
SECTION I:Requesting an External Coding Review
Any facility, Group, Division, ServiceCenteror Corporate Department requesting a retrospective external coding review must choose a vendor from the certified vendor list and follow the process outlined below.
1. The facility should notify a Regulatory Compliance SupportCoding Manager of the planned review so the need and scope of the review can be clarified/evaluated.
- The facility must select a vendor from the certified vendor list for coding reviews. (See the list of Certified External Vendors for Coding Reviews on the Company’s Intranet site at:
- Make arrangements for the review through the vendor contact person listed.
b. If the selected vendor cannot accommodate the request, select another vendor from the list.
c. If all certified vendors cannot accommodate the request, contact the Coding Vendor Project Coordinator.
4. The facility should notify a Regulatory Compliance Support Coding Manager of review dates including the exit conference.
5. Final reports must be submitted to the facility or other requester and copied to the Vendor Project Coordinator by the vendor as agreed upon with the Work Order/Provider Agreement within 30 days after the completion of an engagement.
6. The facility must keep the Work Order and all supporting documentation (e.g., record pull lists, review logs) to verify appropriate billing by the vendor.
7. Payment to a vendor for services rendered shall be handled by the accounts payable department of the facility, Market Division, Group, or Corporate Department requesting the services.
8. Unresolved concerns regarding the vendor should be communicated to the MaterialsManagementCustomerServiceCallCenter at 800-265-8422.
a. Unresolved concerns regarding coding recommendations will be forwarded to the Vendor Project Coordinator for resolution.
b. Unresolved concerns regarding contract issues will be handled by the National Agreements contact for resolution.
SECTION II:Request to Certify a Vendor
1. The Regulatory Compliance Support Department is responsible for approving all vendors and maintaining the certified vendor list. Any facility, Group, Division, Market, or Corporate Department wishing to use a vendor not on the certified vendor list to perform external coding reviews must perform the following procedure before making review engagement arrangements. In addition, vendors requesting to be added to the certified list must contact the Coding Vendor Project Coordinator. The facility, Group, Division, Market, or Corporate Department must submit a written request to the Vendor Project Coordinator stating the vendor name, address, contact person and the reason they are requesting to use the vendor.
2. Direct requests from vendors to become a certified vendor must be submitted in writing to the Vendor Project Coordinator. Direct requests will be considered during open bid periods only.
3. Upon successful completion of contract negotiations, the facility or other requester of a vendor review will be notified and a contract may be initiated.
4. Regulatory Compliance Support will update the Certified Vendor for Coding Reviews Policy and Procedure and all attachments as changes occur and communicate these changes throughout the Company following the policy and procedure revision process.
1/2009
ATTACHMENT A
PROVIDER AGREEMENT FOR CODING REVIEW SERVICES
HCA Management Services, LP
Services Agreement
Vendor ______
Date______
Vendor:
Provider:
1.The above named “Vendor” hereby agrees to provide to the above named “Provider,” an affiliate of HCA Management Services, LP (“HMS”), coding review services (“Services”) in accordance with the terms of the Business Office Services Agreement between Vendor and HMS dated ______, ___ (“Service Agreement”).
2.Vendor agrees to provide Services in accordance with the following schedule:
Services Commencement Date:
Services Conclusion Date
(i.e., date of exit conference):
Location:On Site at Provider______
Off Site on Vendor’s premises ______
Type of Review Services:Inpatient______
Outpatient______
Bill Status:Pre-bill______
Post-bill______
Sample Type:Random______
Focused______
Combination______
Review Frequency:Preliminary______
Concurrent______
Bi-monthly______
Quarterly______
Other______
Other Parameters (if applicable):
Are HCA Regulatory Compliance Support reporting tools &
template required?Yes______
No______
Estimated Sample Size:______
Final Report Delivery Date:______
Are review logs, worksheets, and
other papers to be included with
final report?Yes______
No______
3.Provider shall pay Vendor based on the total number of charts reviewed according to the fees set forth in Attachment A in the Services Agreement. Provider shall also pay the Vendor pre-approved expenses incurred in provide Services. All fees and expenses must be paid no later than sixty (60) days from the conclusion of the Services performed and delivery of the Final Report. Fees and approved expenses may be paid:
_____in a single lump sum, or
_____in installments according to the following schedule:
DateAmount
______
______
4. Report shall be sent to:______
______
______
Copy to:Coding Vendor Project Coordinator
Regulatory Compliance Support
One ParkPlaza
PO Box 550
Nashville, TN 37203
5.Invoices shall be sent to:
______
______
______
6.Key Person(s) include the following individuals:
______
______
______
7.Notices to Provider shall be sent to the following:
______
______
______
ATTN: ______
8.A copy of this completed Provider agreement in its entirety shall be sent to:
Coding Vendor Project Coordinator
Regulatory Compliance Support
One ParkPlaza
PO Box 550
Nashville, TN 37203
9.Anticipated Vendor Expenses:
ItemsAmount
______
______
______
______
10.All terms, conditions and fees in the Agreement, shall be applicable to this Provider Agreement and are incorporated by reference, and together constitute the entire understanding between the parties with respect to the subject matter hereof. This Agreement may not be modified except pursuant to an amendment expressly stating a purpose to amend the terms of this Agreement, and signed by authorized representatives of both parties hereto.
11.If this Provider Agreement is in effect when Provider is either sold to an unrelated third party or its shares of stock (or the shares of stock of its parent corporation) are spun off to shareholders of HCA Inc., this Provider Agreement and all rights and obligations of Provider and Vendor under this Provider Agreement shall continue to remain in effect in accordance with the terms and conditions herein.
12.This Agreement shall not be effective until signed by authorized representatives of both parties and fully executed copies of such are delivered to each party.
VENDOR / PROVIDERBy: / By:
Name: / Name:
Title: / Title:
Date: / Date:
Attachment to REGS.COD.011