In continuation of my posts about RAC auditors and other audit issues that EMR software can help or hurt, the following comment was sent to me by an EMR and HIPAA reader. Maybe all of you have heard of “The Impossible Day” but I found the concept interesting and it seems like EMR software could be well positioned to control this issue. Is this a major problem or only a problem for a few people that like to code too high?
The RAC audits are an interesting and mindful subject. Some practices have been getting into trouble with the “impossible day” which their EMR’s seem to help perpetuate. Some seem to end up with more documentation in files, but when RAC auditors do the math on how long the docs are supposed to be legitemately spending, its not adding up… Thereby “The Impossible Day” emerges.
I’ve asked some EMR vendors if there is some sort of a control feature with a warning on the total time based on visits/notes for a day. Most are not familiar with this. Just like anything else, if we hear more about it from the RAC audits, more will pay attention.
Great read here. I’ve decided to speak with our engineers about looking at this issue. Certainly, none of our clients have seen it yet with our EMR software, but I’m sure the day will come. Thanks for the idea!
I guess, I am still in the dark here. Would the physician have to be fraudulently documenting for this to happen? Or is it some glitch in the EMR system?
I’d say it’s a mixture of both. Basically the system could be designed in a way to help a doctor over code such that it would be impossible for them to accomplish what they’ve coded. The system could check and warn for this. However, at the end of the day, it’s the doctor’s responsibility to code for the work they did and they’ll likely get in trouble for over coding.
The interesting thing is that I’d guess that most doctors actually under code. I think this can be attributed to a number of factors, but fear of getting in trouble is one and no time to document everything they actually did is another.
Comment on billing:
The most common form of current procedural terminology (CPT) coding does not account for … the number of prescriptions written, the number of lab and other tests ordered and reviewed, nor management of cholesterol, thyroid, PSA, etc. test results. It does not account for following up on many specialists management when patients ask for more information about their care at the specialists’ offices. These are not in the coding elements. Most of what a primary doctor does is not in the cpt documentation elements. Yet this is the bulk of the work for primary doctors working in a large HMO like setting. So, billing based on time is a good and rational basis.
Gil Carter, MD, JD, FP
Ten Second Medical RecordTM