| MRC
BREAKTHROUGH Click
here to view actual fax broadcast version (requires
)
On
behalf of Ontario’s Family Physicians,
the COFP has maintained ongoing contact with the Chair
of the Medical Review Committee (MRC), Dr. Barnett
Giblon, to pursue positive changes to
the MRC process. The
unfortunate, but necessary process must remain in the
hands of physicians.
The criteria to target and judge “victims” need to
be fair and unambiguous, the identifying process should be
carried out in a more timely fashion, and the penalty/collection
process should be made reasonable and flexible.
With
regards to clarifying the MRC judging process, we are pleased
that Dr. Giblon agrees with us that family physicians
should be aware of the criteria the MRC uses when performing
an audit. With
his permission, the COFP is giving you the “scorecard”
that is used to judge the A003A general assessment code.
This will also be placed within our website: www.cofp.com.
Your
COFP Executive urges you to read this very carefully.
COFP
MRC RECOMMENDATIONS:
Here
are several of our recommendations to help make the MRC process
fair:
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The
selection process criteria should be defined and published.
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The
MOHLTC should be restricted to MRC audits going back no
more than two years,
unless fraud is suspected. Currently, the MRC strikes
for periods that go back several years. In this
day and age of computer analysis, this is unacceptable.
As soon as OHIP computers identify an alleged billing
irregularity, the potential “victim” should be promptly
notified. |
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There
should be an early simple intervention process to resolve
alleged “billing irregularities”.
The MOHLTC claims that the MRC goal is to help us avoid
submitting inappropriate claims.
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Expedited
audit recovery should be limited to $20,000.
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Payment
schedules should be negotiable.
The interest portion of the penalty should begin
when the payback starts, and should be waived if
payment is made within one year.
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MOHLTC
should not publish any names except for cases of outright
fraud. |
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The
College of Physicians and Surgeons of Ontario (CPSO) should
consider publishing anonymous MRC case summaries similar
to the CPSO Dialogue’s Discipline Committee Decisions.
(This would be an educational column that would provide
a pertinent summary of the case to allow physicians to
learn how to stay within appropriate guidelines with respect
to billing. The recent OHIP Bulletin 4383 did not provide
any educational material to help “prevent the submission
of inappropriate claims.”)
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Doug
Mark MD, President Allan Studniberg MD CCFP, Interim Vice President
and
the
Executive
Committee, Coalition of Family Physicians of Ontario
MUCH
MORE WORK REMAINS TO BE DONE:
The COFP will continue to strive for changes. The MRC process
must be reformed to make it fair. We need your support to help
us continue working on your behalf.
Please
feel free to send us any other suggestions for improving the
MRC.
For
more on the MRC, please visit COFP’s Web Site (www.cofp.com)
and see our Op Ed from the July 30, 2002 issue of the
Medical Post (“Time to Review the Medical
Review Committee”).
WE
CANNOT DO THIS WITHOUT YOUR SUPPORT:
In order to do this, we need as many Family Physicians as
possible to get on board and join our colleagues as
members of COFP.
If
you’d like to help us in our fight for a
fairer and more transparent MRC process, please complete
the attached Membership/Pledge Form and return
by fax now to 416-412-7297.
We would urge you
to become a member (if you haven’t already done so)
of our Association, and make an additional
donation towards our Political
Action Campaign. Even if you do not choose to become
a member at this time, I’d urge you to consider
supporting the Coalition’s Political Action, Lobbying and
Advocacy Activities by making
a donation of $250, $500 or $1,000.
Together,
we really can make a difference.
TO
MEMBERSHIP PAGE
GENERAL
ASSESSMENT (A003) & ANNUAL HEALTH EXAM ADULT/ADOLESCENT
(A003) & ANNUAL HEALTH EXAM CHILD (K017)
The
General Manager of the Ontario Health Insurance Plan refers
to the Medical Review Committee services billed for General
Assessment (A003), Annual Health Exam Adult/Adolescent (A003)
and Annual Health Exam Child (K017) for adjudication.
The
General Manager requests the Medical Review Committee to conduct
a review of the provision of the insured service and determine
whether the service was rendered, whether it was medically
necessary, whether it was misrepresented in its billing and
whether or not the service was provided in accordance to standard
and/or if it was in accordance with the Regulations and the
Schedule of Benefits.
The
April 1, 2002 Schedule of Benefits, General Preamble, page
xi - xii defines General Assessment (A003) as:
“a.
General Assessment: a service provided, somewhere other
than the patient’s home and requires a full history (the elements
of which must include a history of the presenting complaint,
family medical history, past medical history, social history,
and a functional inquiry into all body parts and systems)
and an examination of all body parts and systems, and may
include a detailed examination of one or more parts or systems.”
Further
information pertaining to Annual Health Exams Adult/Child
(A003/K017) is found in the Schedule’s General Preamble, on
page xvii.
“w.
Annual Health or Annual Physical Examination: is
a general assessment as it pertains to an individual after
the second birthday who presents and reveals no apparent physical
or mental illness, including instruction to the patient or
patient’s representative(s) regarding health care.”
Appendix
‘B’ of the Schedule of Benefits identifies record keeping
requirements for each patient assessment. On the date of each professional encounter with the patient,
the record of the assessment of the patient shall include
the history obtained, the particulars of each medical examination
and a note of any investigations ordered and the results of
the investigations.
In addition, an indication of each treatment prescribed
or administered along with a record of professional advice
given and particulars of any referrals made, are necessary.
(Refer to Part v, Ontario Regulation 114/94, Amended
to Ontario Regulation 77/98).
The
Medical Review Committee has developed a scoring tool to use
when interviewing a physician and reviewing his/her records
pertaining to General Assessments (A003) and Annual Health
Exams (A003/K017). This
scoring tool will assist the Committee in scoring the documentation
of a record and determine whether all the expected elements
of documentation are recorded.
It will also assist the Committee in identifying specific
documentation inadequacies in order to effectively address
them to the physician.
This form utilizes the SOAP format, as suggested in
the College of Physicians and Surgeons of Ontario’s publication
“A Guide to Current Medical Record-Keeping Practices”.
The
Medical Review Committee, in reviewing charts and interviewing
the physician, would need to determine that the service accurately
represented what was billed.
Once the Committee has determined that a general assessment
was the appropriate service code billed, the documentation
of the record is assessed.
The
Committee may find a repetitive pattern of major deficiencies
in the record where the services provided do not meet all
the elements required by the Fee Schedule.
In this instance, the Committee may reduce the payment
to a lesser fee code.
If
the Committee finds there are varying degrees of inadequacy
in the record keeping and some elements of documentation are
missing, but most of the elements are present and a general
assessment was done, then depending on the degree to which
the documentation is found to be repetitively deficient, the
Committee may proportionally reduce the fee paid to the physician
and recommend that a repayment to the General Manager of OHIP
be recovered from the physician.
A
perfectly documented chart entry is not always present.
This tool reflects a compromise position as to the
minimum documentation required in recording a general assessment
and annual health exam codes. The Committee expects to find at least the minimal scores in
each subsection in order to find the record satisfactory for
documentation.
The
Medical Review Committee trusts that in distributing this
form to the profession, they are openly showing the profession
how the MRC functions.
It is believed that publishing this scoring tool will
help all practitioners have a better understanding of the
documentation requirements for these fee codes.
GENERAL ASSESSMENT
(A003) and ANNUAL HEALTH EXAM ADULT/ADOLESCENT (A003)ANNUAL
HEALTH EXAM/CHILD (K017)
An ideal chart would contain all of this information,
but the committee feels that not all charts will be perfect,
hence the required minimum scores. These minimums must be
present in each category.
If scores are not met the service will be found to
be deficient in documentation and payment will be reduced
by a percentage proportional to the deficiency.
*This form assists the committee in recording its concerns
with documentation.
(We apologise for the
small error in the faxed version of this table in the Functional
Enquiry Score box - one extra score line was included)
(To
view only this actual A003 Scorecard, click here) (requires
)
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A003: NAME
K017
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Record
#
Service Date:
|
Inspection
/ Interview
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| Documentation Components
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Score
|
Notes
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HISTORY
Chief Complaint
History of Present
Illness
History of Past Health
Social History
Family History
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0
1
0
1
0
1
0
1
0
1
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Annual Health Exam only the last
three.
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Total :
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4/5
To be acceptable expect to find at least 4/5.
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FUNCTIONAL
ENQUIRY
Detail
and focus for CC
Behaviour:
smoke,alcohol,drugs, exercise
General:
energy, sleep, appetite, diet
Head
and Neck
Chest
CVS
GI
GU
CNS/Emotional
MSK/Skin
|
0
1
0
1
0
1
0
1
0
1
0
1
0
1
0
1
0
1
0
1
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Development, milestones
in paediatrics.
Should be age and
sex specific.
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Total :
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6/10
If less, not acceptable. |
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PHYSICAL EXAMINATION
Detailed
Re: Chief Complaint
Ht/Wt
+ other Vitals
Head
and Neck
Chest
CVS,
BP, Pulse
GI
GU/Breast
CNS/Psych
MSK/Skin
Age/Sex/Specific
for AHE
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0
1
0
1
0
1
0
1
0
1
0
1
0
1
0
1
0
1
0
1
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Annual Health Exam
Should Be Age/Sex Specific (AHE)
Tick marks are only
acceptable if pertinent negative findings are described.
Positive findings should be detailed.
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Total:
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6/10
or more to be acceptable. |
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DIAGNOSIS &
PLAN
Provisional Diagnosis
Follow Up /Referral
Plan
Investigations ordered
are noted
Details of Advice
given
Rx Drug Dosage and
Duration
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0
1
0
1
0
1
0
1
0
1
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Total: |
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4/5
If less not acceptable. |
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Grand Total Score |
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20/30 is
acceptable if minimums are met in each category
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