At the end of July, the GPSC sent out updated information about the GPSC fee codes. In particular, there were some changes to the documentation requirements for billing these fees. For example, you must now record and submit start and end times for the MH planning fee, which has always required a minimum of 30 minutes.
This information prompted concerns among some physicians, who felt the changes to some of documentation requirements increased their administrative burden.
The changes clarify documentation requirements in response to the Ministry of Health’s Billing Integrity Program in order to protect GPs in the case of a potential audit. Because the fee codes have always referred to time spent on patient care and planning, if a GP doesn’t include evidence of time spent, they may be vulnerable in an audit. It was recommended that there be more detail in the fee descriptions and notes, to ensure that this documentation expectation was clear. There were no changes to the intent of the GPSC fees; and there were no substantive changes to the medical service requirements of the fees. One change in service requirement is that for the 14052 Hypertension CDM you no longer have to give the patient their flow sheet.
That said, we have heard your concerns and will continue to address these issues at the GPSC. We will be in touch with any updates.
Meanwhile, we encourage all physicians to take part in the Visioning consultation, which will inform the future direction of the GPSC including in the areas of incentive fees. To participate go to www.gpscvisioning.ca.
Regards,
Dr Shelley Ross
Doctors of BC Co-chair, GPSC
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The key updates, effective August 1, are detailed as follows:
1. Documentation Requirements
All incentives that are condition specific require clear confirmed diagnoses documented in the patient chart.
Care plans clearly documented either within the body of the chart visit or on separate template with note that the plan has been shared with the patient/medical representative. All planning fees have an outline of elements that are expected to be included in the documentation (see GPSC Billing Guide and Payment Schedule for details).
2. Time Requirements
All incentives other than the complex care fees 14033 and 14075 that have a minimum face-to-face time requirement must have start and end times documented both in the patient chart and in the fee submitted through MSP. Note that EMR open/close of chart time is not adequate as the chart may be open before the patient is seen as well as after to complete documentation or even just after the visit to document the service provided.
i. G14043 Mental Health Fee
Minimum requirement of face-to-face time is 30 minutes. Visit fee on same day only payable in addition if total time exceeds 39 minutes; counselling fee on same day only payable in addition if total time exceeds 49 minutes (and preamble requirements for counseling are fulfilled). Must state start and end times of the total service (planning plus any additional visit/counseling).
ii. G14044/45/46/47/48 Mental Health Management Fees (Counseling equivalent)
Minimum requirement of face-to-face counseling is 20 minutes. Claim must include Start and End times of the actual counseling service. Note that MSP age differential counseling fees (00120 series) will also require start and end times both in the patient chart and in claim submitted to MSP but an effective date has not yet been confirmed. See preamble to fees for definition of counseling as this is applicable to both the MSP Counseling fees and the GPSC Mental Health Management as they are counseling equivalent.
iii. G14063 Palliative Planning Fee
Minimum requirement of face-to-face time is 30 minutes in addition to visit time same day. Claim must state start and end times of the service.
Both Complex Care fees (G14033 & G14075) require a minimum of 30 minutes for the planning component, with the majority of that time face-to-face. Time spent for the required same day visit fee is not included in the planning time. Document total time spent and total face to face time.
Example:
Physician spends 10 minutes reviewing chart to ensure all relevant information is available for the planning session with the patient. Patient seen for 5 minutes to review current labs/status, then 20 minutes face-to-face discussing future expectations, progression of condition, patient goals and Advance Care Plan wishes including resuscitation status. In addition to the details of the each component of the visit (including the plan as per 1. B above) chart includes the following documentation:
Complex Care Planning visit – total time 35 minutes: Face-to-face 25 minutes.
3. Condition-Based Payments (Chronic Disease Management) G14050/G14250, G14051/G14251, G14052/G14252, G14053/G14253
Patient Self-Management: While initially the GPSC agreed the specific sharing of the Hypertension Flowsheet and the COPD Action Plan were reasonable tools to support self-management, the specific requirement for these has been replaced by a general requirement across all CDMs to use patient self-management support tools but without specifying any single one. It is expected that as part of good management, a discussion with the patient will determine what type of support is best for the individual patient, and the outcome of this discussion will be included in the chart documentation.
Patient self-management can be defined as the decisions and behaviors that patients with chronic illness engage in that affect their health. Self-management support is the help given to patients with chronic conditions that enables them to manage their heath on a day to day basis. An important part of this support is the provision of tools by the family physician that can enable patients to make appropriate choices and sustain healthy behaviors. There are a variety of tools publically available (e.g. health diaries/passports, etc.) to help build the skills and confidence patients need to improve management of their chronic conditions and potentially improve outcomes. Documentation in the patient chart of the provision of patient self-management supports as part of the patient’s chronic disease management is expected.
12 Month Care Requirement: The Condition-based incentives are payable in recognition of work that has been done and are not payable in advance – in other words, they are to be billed after provision of one full year of care. To confirm an ongoing doctor-patient relationship, there must be at least 2-visits (office; prenatal; home; long term care; only one of which can be a GPSC Telephone Visit or Group Medical Visit) provided/billed on each qualifying patient in the 12 months prior to billing the CDM incentive. Visits provided by a locum for the MRP GP are included; however, an electronic note indicating this must be submitted with the claim.For the new CDM incentives for physicians who bill encounter records while working under salary, service contract or sessional arrangement, post-audit will be performed within 2 years and recoveries made if encounter records were not submitted for the required visits.
When a GP accepts a new patient into his/her practice, these incentives are not billable until after a full 12 months of care. The only exception to this is when a new GP takes over the full practice of another GP who is leaving the practice (retiring, moving, etc.) and who has been providing guideline-informed care to patients with eligible chronic conditions. Under this circumstance only, the CDM fee is billable on its anniversary date provided the new GP has continued to provide guideline informed care for these patient(s). To demonstrate continuity, if some of the required visits have been provided by the previous GP, an electronic note indicating continuity of care over the full 12 months is required at the time of the initial submission of the CDM fee by the new GP.
GPs in APP practices: The requirement of 2 visits in 12 months has been a challenge to confirm for GPs who are working under alternate payment as they do not submit visit fees to MSP. As such, GPSC has developed a mirror set of Condition-based Incentive codes to be used when billing for CDM incentives if the required two visits were billed as an encounter record while working under salary, service contract or sessional arrangement. Post-audit will be performed within 2 years and recoveries made if encounter records were not submitted for the required visits.
i. G14250 Incentive for Full Service General Practitioner (who bill encounter record visits) - annual chronic care incentive (diabetes mellitus) .................. 125.00
ii. G14251 Incentive for Full Service General Practitioner (who bill encounter record visits) - annual chronic care incentive (heart failure)........................... 125.00
iii. G14252 Incentive for Full Service General Practitioner (who bill encounter record visits) - annual chronic care incentive (hypertension) ........................... 50.00
iv. G14253 Incentive for Full Service General Practitioner (who bill encounter record visits) - annual chronic care incentive (Chronic Obstructive Pulmonary Disease COPD)..................... 125.00
*Note that the new CDM fee items for GPs who submit encounter records for their visits are effective retroactive to January 1,2015. Please hold submission of claims until after August 4, 2015. For claims that are over 90 days from initial submission/rejection, you may use submission code “A”.
4. G14063 Removes Eligibility for other GPSC Incentives
Other than Mental Health Incentives, all other GPSC incentives (Complex Care, Prevention, CDMs) are no longer payable once G14063, the Palliative Planning Incentive, has been billed and paid as patient has been changed from active management of chronic disease to palliative management. While this process has always been in place, it is now clearly outlined in the incentive notes for all affected codes.
Conferencing and Telephone Management continue to be available after G14063 has been submitted and paid.
For questions or comments, please email gpsc.billing@doctorsofbc.ca.