VBM1 Task 2 Analyzing Coding and Billing Reimbursement
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1 VBM1 Task 2: Analyzing Coding and Billing Reimbursement Rebecca Rudd College of Health Professions, Western Governors University Diana Gardner May 14, 2023
2 VBM1 Task 2: Analyzing Coding and Billing Reimbursement A.1. MIPS: Goals Medicare’s Merit
-based Incentive Payment System (MIPS) streamlines previous incentive-based program into one platform. The prior programs for Physician Quality Reporting System (PQRS), value-based modifier program (VBM) and Promoting Interoperability (PI) that as previously known as Meaningful Use (MU) are the components of MIPS, along with new improvement activities. By using a certified electronic health record system, MIPS aligns payments to quality and cost-efficient care while driving improvement in health outcomes with an overall goal to reduce the cost of healthcare. According to Capella University (2018), MIPS goals are to improve quality of care, reduce disparities, engage patients and families, improve care coordination, and maintain privacy and security of patient health information. As we take a deeper dive into the goal of improving care coordination and public health, it is important to understand that the original meaningful use programs created a vision for the future of interoperability agnostic of electronic health record systems (EHR) that would also promote patient safety and reduce the cost of redundant healthcare services. Without interoperability and immediate access to pertinent health information, providers relayed upon paper records or verbal reports of information. Historical information was not readily accessible at point of care to assist with clinical decision making. The Cures Act provides regulations and standards that EHRs must contain to be certified. The regulations include the architecture of a unified coding system that is universal to all certified platforms. Incoming data that is codified can be clinically reconciled into another system. For example, a patient sought care out of state for an acute illness and is returning to their primary care provider (PCP) for follow-up care. The
3 PCP can receive a continuity of care document in an HL7 format that will provide diagnosis, problems, medications, allergies, lab results, and other pertinent information regarding the visit at point of care through a health information exchange network. This exchange of information promotes patient safety by providing an up-to-date medication list. It also impacts the cost of care by receiving testing results from the visit and reducing duplicate tests from being ordered. By electronically sharing continuity of care documentation between providers of service, there is increase care coordination for care services and supports a patient centered model of care approach to delivering healthcare services. Another goal is to increase patient and family engagement in healthcare. A key deliverable to the original incentive programs involved providing a patient portal for patient access to healthcare information. As the programs advanced so did the level of requirements to indicate patient engagement. Patient portals today offer many options for patients such a bill pay, reviewing test results, messages with physicians, appointment scheduling, and requesting refills. There continues to be identified hurdles to optimal adoption of the technology, including broadband internet availability in rural areas. One of the largest hurdles has been with the healthcare providers themselves. Concerns with provider burden to manage the incoming messages, along with hesitancy to release test results immediately upon availability have led to poor patient portal promotion within practices. As practices are encouraged to become patient centered medical homes, it is key that patients and their caregivers are informed and have input to healthcare decisions. By activity encouraging patient engagement, health outcomes will improve with shared decision making for healthcare. A.1.A. MIPS: Advantages and Disadvantages
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4 While the overall goal of the MIPS program is supporting the quadruple aim of healthcare, it also brings an array of advantages and disadvantages for those participating in the program. One of the advantages of the program is incentives for providers to participate in alternative payment models (APM). Providers who participate in APMs are promoting care management and transformation to improve quality of care and reduce healthcare costs. Care management promotion across the patient’s care team will improve patient safet
y by data sharing of key patient health information for informed clinical decision making and patient engagement for plan of care. Engaging patients in the plan of care will ensure they are provided necessary information and given the opportunity to develop realistic and obtainable goals related to chronic conditions or other health care decisions. Participation in an APM also allows providers to qualify for shared savings under the program. MIPS combined three existing incentive programs and added a new are of clinical improvement to the program. Having a single program is an advantage as the technology advances. While the initial programs engaged providers of care to adopt and implement electronic health record technology, MIPS builds upon the older programs and encourages a focus on clinical quality of care (Gruessner, 2015). There is a set of clinical quality metrics that providers submit performance data. Their performance on the measures is part of the calculation for scoring for the program. Reporting burden for some providers has been identified as a disadvantage of participation (Hughes, 2019). There is missing alignment amongst the regulatory bodies for a universal set of clinical quality metrics across programs (Gruessner, 2015). Expertise in data mining and integrity is necessary to ensure data accuracy for reporting. Some providers do not have this capacity or resource within their organization and will incur cost for securing third-
5 party assistance with reporting. Managing multiple measure sets can be overwhelming and redundant in some instances. Over the past several participation years, we have seen regulations change to address reporting burden such as reduced quality measure reporting periods from one year to ninety days for specific years. In addition to reporting requirements, providers must adjust workflows to ensure data collection is accurate based upon the National Quality Forum measure steward for the clinical measures selected. In many cases, this requires codified data be entered into the health record system which can lead to more clicks and less free texting into the patient’s chart. Another disadvantage of the MIPS program is that it is difficult to understand (Hughes, 2019). It is overwhelming to understand the calculations for each area of MIPS that is considered for scoring. Each year there are changes to the program, which requires providers to investigate key changes for participation and do a gap analysis to implement new requirements. Khuller et al. (2021) conducted interviews and found that MIPS participation has added increased administrative duties and burden. Staffing retention continues to be a struggle for many groups, and often staff turnover requires reorientation to the requirements of the program as the knowledge leaves the organization. Practices need to monitor performance throughout the year and take actions to improve concerning scores in each area to avoid scrambling at the end of year and lacking the ability to impact scores. A.2. VBPS: Goals The Value-Based Purchasing System (VBPS) related to hospital inpatient quality reporting developed by Medicare. Quality improvement driven by transparency of clinical care and cost is the overall goal of the program (Oachs & Watters, 2020). Medicare believes patients
6 can make better informed decisions regarding their healthcare when cost and quality of care is shared. A designated metric set is established annually for hospitals to submit reporting data. Medicare adjusts payments based upon performance and improvement for the measures. Hospitals are measured nosocomial infections, patient safety, consumer experience, cost of efficient care delivery, along with mortality rates. Each area is composed of two scores to indicate performance and if applicable improvement from prior reporting. A.2.A. VBPS: Advantages and Disadvantages VBPS programs strengthen the adoption of certified electronic health system technology which in return improves patient safety as an advantage of the program. Health records need to be accessible at point of care and provide key data that is universal across platforms for interpretation. Hospital systems using a certified electronic health record technology have the capability to receive and transmit continuity of care documents in relation to transitions of care. The patient level health data available promotes patient safety by sharing data such as known allergies, problem lists, active medication lists, and other pertinent information for clinical decision making. Another advantage of the program is the transparency that is shared by Medicare regarding the institution
’
s cost and quality of care for consumer use for informed decision making. Patient engagement in healthcare decisions leads to better health outcomes. Hospitals are financially rewarded for good performance, including patient experience. Under performing hospitals, may also see a reduction in patients seeking care at the institution based upon Medicare scoring which in return affects financial stability. Therefore, hospitals consider the
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7 metrics and reporting to be of high importance and strive to meet expectations to drive financial stability. Like MIPS, VBPS have the disadvantage of being difficult to understand. It can be overwhelming when researching the components of the program and understanding the ins and outs of participation. Some institutions may lack internal expertise for monitoring performance and reporting required by the program. Hiring of resources to manage the program leads to high overhead costs for operations. Another disadvantage is hospitals have the risk of still incurring a payment reduction even with improved performance but not to the extent of other peer institutions (Oachs & Watters, 2020). In addition, providers can be penalized for patient
’
s noncompliance with plan of care which impacts clinical quality metrics. Patient satisfaction scores are also impacted based upon the demographic patient composition, as well as the services the hospital provides to the patient population. Hospitals that serve those of in underserved areas could still score less than those in more populated areas, therefore showing less improvement leading to decreased payments. Many hospitals have voiced concerns that measures are applicable for a narrow patient base of health conditions and services, and often there are no measures to measure quality for all the types of problems and patients that are served. A.3. HIM Staff Role Health information management staff play important roles in both the MIPS and VBPS programs. A health information medical coder is a key role in assuring that services rendered are accurately captured with standardized code sets such as ICD-10 and Current Procedural Terminology (CPT) codes. The clinical quality metrics for the payment reform programs consistent of data sets that assists groups in understanding initial patient populations, denominator, exclusions, exceptions, and numerators. Medical coders have the expertise to
8 accurately monitor and advise on appropriate coding that is supported by care documentation in efforts to improve reporting accuracy. The health information data analyst will provide interpretation of reporting queries, along with providing in-depth analysis of areas of concern. This role should possess knowledge on the electronic health system that is in use with the ability of data mining. Without extensive knowledge of the database, there can be reporting errors and lack of data hygiene. Data analysts are tasked with providing measure reports at the desired frequency of the organization. They can also assist with data interpretation and identify trends and any areas of concern that need addressed. This role can also assist with patient satisfaction survey results for the VBPS and lead the data analysis of incoming results. When all results are received, they can prepare final graphs, charts, or other visual tools to share results. The health information manager is often the resource responsible for managing MIPS and VBPS programs for the organization or providers. They are instrumental in navigating the complexities of the programs and training staff on the requirements of participation. They are responsible for the overall management and security of patient health data. They play a role in selecting systems that are adopted by the participants of the programs and must understand how the data is stored along with interoperability of the systems. For example, participation in the MIPS program requires that a certified electronic health record system be utilized. The manager will need to ensure that patches or upgrades are implemented to maintain an ONC certified technology. Each organization has its own organizational chart and job titles. The above are just a sampling of typical health information management roles and the part they play in the MIPS and VBPS programs. Roles can cross over into quality, security, and other key disciplines based
9 upon the organization. Regardless, every role within the practice or hospital plays a part in program participation by ensuring data hygiene, improving clinical quality of care, delivering excellent customer service, and other key performance metrics that impact the program scores. B. Quality Improvement Organizations Medicare is vigilant in investigating and monitoring for recovery of improper payments. They utilize third-party recovery audit contractors for surveillance of the government programs. Recovery Audit Contractors (RACs) goal is to reduce improper payments and assist with actions to prevent improper payments in the future (Oachs & Watters, 2020). Reviews can occur at a system level or audit of patient
’
s medical records individually. Through activities auditors can detect improper payments that need correction and take actions to prevent from reoccurrence. These activities assist providers in avoiding submission of claims that do not comply with Medicare rules for payment. Centers for Medicare and Medicaid Services (CMS) can also lower incorrect payment error rates and improve compliance. In sustaining correct billing and payment programs, the programs are protected from future and current Medicare beneficiaries. Recovery auditors will offer to discuss findings with providers regarding improper payments as an educational opportunity to correct behavior for future claims. If there is agreement on the findings, the provider can agree to pay back funds, allow recoupment from future payments, or request a payment plan. In cases where there is disagreement of the findings, providers may file an appeal for further discussion and investigation. Auditing of payments is beneficial for the stability of the Medicare program. Implementation of a standardized audit process supports the overall goal of providing cost efficient care to beneficiaries. When areas of improper payment are identified, there is an opportunity to educate providers on the rules and regulations for claim submission and covered
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10 services. In addition, there is return of revenue to the program when improper over payments were made to providers. In some instances, improper underpayments can also be identified and corrected with accurate revenue income to the providers of service. Providers of services should implement an audit program internally to ensure accuracy in billing processes and correct any areas of concern. This type of internal checks and balances will assist the practice and provider in avoiding improper claims and associated risks of monies due to CMS with audits. C. HIPAA Transaction and Code Set Standards HIPAA Transactions and code sets bring standardization to electronic exchange of patient level health data and claim information. Standardized code sets allow vendor agnostic interoperability for data transmission and interpretation. In 1996, Congress passed the HIPAA act with the purpose of improving electronic interoperability for data sharing (Miscoe, 2010). In 2000, Department of Health and Human Services (HHS) released standards of transaction and code sets required under the HIPAA statute (Miscoe, 2010). At the time, all covered entities were required to use ICD-9 codes to report medical conditions and problems. In addition, HCPCS Level II, maintained by American Medical Association (AMA), were to be assigned to report physician and other health care rendered services. By requiring standardized coding, further data analysis for apples-to-apples comparisons became available for deeper dives into care being provided. This shift in coding also assisted in case reporting for various conditions and registries, such as cancer cases to a national database. Cost of care could be fully investigated among providers of service, along with evaluation of patient complexity levels for providers of service. By implementing standard code sets for claims, payers can establish reasonable and customary fees for procedural and supply codes. This also has allowed the expansion of bundled fee structured payments by having data readily accessible for similar services with the goal to
11 decrease the cost of healthcare by promoting evidence-based clinical quality of care services for conditions and procedures. Across the nation the reimbursement schedule is impacted by geographic location for the cost of care delivery as well as the resource who is providing the care. For example, a nurse practitioner could be assigned a lower reimbursement fee for the same code submitted by a medical doctor. This is related to amount of education and training differences between the two levels of providers. By using standardized code sets, the cost of care delivery becomes transparent between all levels of healthcare. Healthcare data in relation to claims and patient profiles allows the nation to trend and analyze specific patient populations. ICD-9 codes while the initial steppingstone into transparency, were not providing enough detail for full analysis. The adoption of ICD-10 codes in 2015, has enhanced health condition tracking, improved research opportunities, better clinical decision making, and improved accuracy in measuring patient outcomes. C.1. Impact on Coders As technology changed and new regulations were put in place, coding staff had a daunting task of learning and mastering the new requirements. This was also coming upon the heels of electronic health record (EHR) technology adoption across the country. Coders required orientation to the EHR system to understand where clinical data lived to support assigned codes. Some of the systems also contain coding capabilities based upon discrete data entry. This functionality required review of configuration settings and logic into automatic code assignment. Along with being introduced to coding sets for reimbursement, they also had to learn the changes as they impacted claim submission and revenue cycle management. Individual payers can define coding requirements that require in-depth knowledge of the rules before submitting a claim. For example, Medicare has a list of services that are not covered and would require the patient to
12 sign an advanced beneficiary notice (ABN) prior to the procedure with a cost estimate. A coder can keep front line staff informed of non-covered services, to promote patient decision making for care. A focus on continued education as code sets are updated is key to success. Coders will need to have the opportunity to learn new requirements for coding, new available codes, and any other updates as they become available. When considering a budget for the department, continuing education costs along with reference manual costs should be incorporated into annual budgets. Performance must also be evaluated to address any problematic areas that could impact the organizational financial stability. By building an efficient coding team, the organization reduces the risk of improper claim submission. D. Impact of EHR Meaningful Use programs for Medicare and Medicaid eligible providers and hospitals were established to provide incentive for adoption, implementation, and upgrade to certified electronic health record (EHR) technologies. The Medicaid program was managed by individual states, while Medicare program was managed by the Centers for Medicare and Medicaid Services (CMS). The programs had a set of core measures associated that applicants for the program must report scores. Providers were only permitted to select one of the programs for participation. The Recovery Act identified three components for Stage 1 including use of a certified electronic health record in a meaningful way, electronic data exchange, and reporting of clinical quality measures. Stage 2 requirements built upon the basics and increased the responsibility for using the system. Eligible providers and hospitals were quick to raise concerns as they found difficulty in meeting the measures. The cost of adoption for a certified system was a financial burden for smaller groups, because incentives were paid annually after meeting
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13 requirements. In addition, health record systems were trying to keep development up to date with changing technical specifications. Reporting was burdensome not only because of the complexity of the clinical quality measures, but many of the EHRs did not provide reporting capabilities. In 2016, members of a Senate IT Working Group signed legislation to reduce the burden of attesting to Meaningful Use (Rajaee, 2017). This legislation relaxed requirements for challenging metrics for eligible providers and hospitals. The reporting period requirements were changed from a 365-day period to any ninety consecutive day period for reporting. There was also an extension for applying for hardship exceptions for the 2017 reporting year (Rajaee, 2017). Providers in the Medicare program were increasingly concerned that failure to meet the strict requirements of the program would lead to negative payment adjustments upon the heels of the impending Medicare Access and CHIP Reauthorization Act of 2015, with talks that the program could be delayed. The country continued to see relaxing of initial reporting requirements for the next several years to reduce provider burden. Medicaid program participants found that many states followed CMS footsteps by reducing reporting periods. The Medicaid program did not have a clear plan for next steps once final payment year had passed. Even today, states are still in the midst of implementing payment reform programs. Meaningful Use incentive programs provided the movement to adopt systems with standardized requirements to promote interoperability. Since the beginning of the program, the country has seen a decrease in the number of certified electronic health records systems either due to the inability of the software to meet requirements, or via acquisition by other vendors. The thing that remains consistent is the governments intent to promote interoperability to drive patient safety and decrease the cost of the healthcare. The complexity of the programs continues to be difficult for many to navigate, however financial stability of the groups relies upon
14 participating when serving Medicare and Medicaid patient populations. CMS did hear the concerns and even for the 2023 reporting year, participants are attesting for any continuous 90-
day period. EHRs provide the transparency into clinical quality care and cost of services that was missing prior to adoption and implementation of the systems. E. Emerging Technology in Reimbursement Electronic eligibility for health insurance coverage is paving the way for a reduction in denied claims. Denied claims start at registration or the front desk. Improper entry of a patient
’
s health insurance coverage trickles into charges and claims for service. Staff are often multi-
tasking or with the recent COVID-19 pandemic, front office operations have limited staff availability. In the world of EHR technology, insurance verification can be obtained through an automated query prior to the date of service. Various EHR vendors offer this interface as part of their practice management software or have the capability to interface with third-party platforms to bring the results back into the patient
’
s chart. Prior to availability of this technology, front line staff for registration and billing relayed upon patients to provide accurate insurance information. There is always the risk of human error for data entry, along with patients supplying incorrect coverage information. Lengthy phone calls to insurance companies to verify billing information are not an effective use of staff resources. There have also been documented cases of identify fraud when presenting patients supply someone else
’
s insurance card for claims. From personal experience I have seen firsthand a patient presenting for care and providing an insurance card with their name that was not legit. In this case, several family members had the same name and some where undocumented individuals illegally in the United States. The insurance carrier contacted our office regarding a claim for irregular menses for a subscriber who had history of a hysterectomy. Upon investigation, it was
15 determined that three females in the household were using the same insurance subscriber details for claims. Having adopted an EHR recently, my practice implemented the use of cameras to obtain pictures of our patients to attach to their charts for ease of recognition. The cameras interfaced directly into the EHR and practice management systems. Organizations will need to check availability of existing technology in their certified electronic health record system. If available within existing platform, they could avoid additional expenses for technology. They can also elect to explore third party platforms that have the capability of interfacing with their EHR system to provide point-of-care information regarding findings of eligibility verification. This will allow front end and billing staff to address any failed verifications or other areas of concern prior to services being rendered. In addition, copay and deductible information can also be revealed prior to care delivery. In times of system outage, staff could resort to manual processes to verify coverage. Considerations when evaluating this technology will include cost, maintenance fees, any supplemental equipment needs, interface capability with billing system, upgrade frequency, and any manual processes that must be completed by staff. E.1. Future of Reimbursement Electronic eligibility checks performed within 24 hours of the date of service will reduce claim errors and denial rates. Patient can also supply subscriber information through a patient portal for the platform to obtain subscriber number for electronic verification. The COVID-19 pandemic introduced more technology for eligibility checks by promoting care entities to adopt check-in registration platforms either using a secure portal, web site, or text messaging. Patients can take pictures of insurance cards and transmit to the practice electronically. This has reduced the manual processes of staff to contact and enter billing information.
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16 Commercial and government payers will need to routinely have subscriber information available for electronic verification in real-time through a secured gateway for connection. Care entities will need to manage access to confidential information through the gateway for the automated queries, along with the availability of real-time query as needed. This level of transparency will have a positive impact on billing processes across the country, while reducing burden for staff and decreasing denial rates. In addition, this type of health technology is improving interoperability. F. Identity Fraud and Abuse Selecting an electronic practice management and electronic health record system that can manage ICD-10, current procedural terminology (CPT), and HCPCS codes allows organizations to divert fraudulent and abuse behaviors. The EHR which works with the practice management system can be codified to indicate appropriate codes when care is being rendered by providers or for supplies as they are administered. Often this leads to decreased burden of staff having to enter codes directly into the system, as they are auto generated based upon documentation for computer assisted coding. The charge master list will provide current codes and pricing information to populate for claims. The electronic system can be configured with coding regulations per payer to aid in claim accuracy. When staff and providers are using the system as intended, the technology will support claims with data documentation. This type of system will also decrease the risk of fraud and abuse situations, by identifying discrete documentation in the patient
’
s chart and automatically attaching acceptable codes. This lessens the opportunity for manual entry of coding that could be identified as up coding for higher claim amounts. The system will require configuration based upon workgroups for privileges within the technology. For example, a medical assistant should not be responsible for adding a diagnosis
17 code to a patient
’
s chart. This is the responsibility of the rendering provider. Rights will need to be based upon position and meet both state and federal requirements. By structuring rights by roles, the electronic system will control access to identified activities and areas of the system. By limiting access based upon roles, the system reduces the risk of abuse of improper documentation and coding. Another example for preventing fraud is to ensure configuration of the individual who is actively in the patient
’
s chart and providing care is indicated as the rendering provider for claims. Without this type of oversight, individual lines on a date of service for a single claim could be linked to incorrect end users of the EHR. Organizations must have a dedicated process in place to manage workgroups with new hires and resignations. The system will also require annual updates for new CPTs, HCPCS, and ICD-10 codes. Many EHRs allow the organization to import the new coding directly into the database. Organizations will need to manage the code sets to ensure that outdated codes are marked as expired. Security features of the system must include unique log in credentials for all end users. As technology continues to advance, the adoption of a second form of authentication is quickly becoming standard. By unique log in credentials, the system detects the end user and the workgroup they are assigned for allowing navigation and access of the EHR. Passwords should be a combination of letters, numbers and special characters that expire at a designated frequency. Once within the system, rights will drive how end users interact for coding activities. For example, a provider will enter an order for the administration of a vaccine with the appropriate CPT and ICD-10 code. A clinical support staff member will document within the patient
’
s chart the pertinent information for the injection and indicate the injection was administered triggering the CPT code for the vaccine and administrative fee be submitted for encounter. In this example,
18 the vaccine must be administered for the charge to go to the superbill. This type of linkage with the EHR ensures that sufficient documentation exists to support charges for the encounter. Remote access to the EHR system must be managed through a secure gateway such as a remote desktop application or virtual private network (VPN). Once a secure gateway has been verified, the end user would have dedicated unique credentials to log into the electronic health system. Once in the system, the same checks and balances would follow for workgroup assignments based upon roles. It is important for organizations to have a formal policy and procedure for remote access and guarantee only those staff who require this level of access are afforded the rights. Use of an electronic health record technology that embeds computer assisted coding into the framework, along with insurance eligibility verification is focusing on the benefits of interoperability. By allowing the EHR system to capture codes at point of care and transmit to practice management systems for billing, which is ensuring accurate insurance eligibility, the organization is reducing the risk of fraudulent billing activities and limiting the opportunity of abuse for claims with automatic coding based upon supporting documentation. Organizations who are optimally using the EHR for patient care will ensure codified information for items such as problem lists, active medication lists, allergies and diagnostic test results are compatible with HL7 standards for sharing patient health information for continuity of care electronically with other providers.
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19 References Capella University. (2018, November 29). What you need to know about the Merit-based Incentive Payment System (MIPS)
. Capella University. https://www.capella.edu/blog/health-sciences/understanding-the-merit-based-incentive-
payment-system-mips-
framework/#:~:text=MIPS%20aims%20to%20achieve%20the%20following%3A%201%
20Improve,Maintain%20privacy%20and%20security%20of%20patient%20health%20inf
ormation Centers for Medicare and Medicaid Services (CMS). (n.d.) Promoting Interoperability Programs
. CMS.gov. https://www.cms.gov/regulations-and-
guidance/legislation/ehrincentiveprograms Greussner, V. (2015, December 1). Challenges, Advantages of Merit-Based Incentive Payment System.
TechTarget, Inc. https://healthpayerintelligence.com/news/challenges-
advantages-of-merit-based-incentive-payment-system Hughes, M. (2019, February 18). The Pros and Cons of Opting into MIPS. WebPT. https://www.webpt.com/blog/the-pros-and-cons-of-opting-into-mips/ Khullar, D., Bond, A. M., Qian, Y., O'Donnell, E., Gans, D. N., & Casalino, L. P. (2021). Physician Practice Leaders' Perceptions of Medicare's Merit-Based Incentive Payment System (MIPS). Journal of general internal medicine
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3758. https://doi.org/10.1007/s11606-021-06758-w Miscoe, M. (2010, March 10). Accurate Reporting Depends on Coders Knowing Payers
’
Controlling Standards. AAPC. https://www.aapc.com/blog/26145-hipaa-the-
fundamental-coding-rule/
20 Oachs, P.K., & Watters, A.L. (2020). Health Information Management, Concepts, Principles, and Practice
(6th ed.). American Health Information Management Association (AHIMA). https://wgu.vitalsource.com/books/9781584267577 Rajaee, L. (2017, November 2017). What do Independent Physicians Need to Know About the Proposed EHR Regulatory Relief Act?. Elation. https://www.elationhealth.com/resources/blogs/what-do-independent-physicians-need-to-
know-about-the-proposed-ehr-regulatory-relief-act