Risk Adjustment Phase-In Nears Completion
In 1998, the Centers for
Medicare & Medicaid Services (CMS) began implementing a new
reimbursement model for Medicare+Choice organizations (now known
as Medicare Advantage). This change, called risk adjustment, signaled
a shift from demographic-based reimbursement to reimbursement based
on the health status of the individual. Ultimately, health plans
will be reimbursed less for healthy beneficiaries and more for those
who are sick.
The original risk adjustment model was based on the
submission of inpatient claims. Beginning with 2004 payments, CMS
began a gradual phase-in of the Hierarchy Condition Category (HCC)
model, which is based on diagnosis codes for inpatient, outpatient
and physician claims. Now, the completion of the phase-in schedule
is right around the corner; the implementation will be complete
in the next two years.
Currently, payments for 2005 are being phased in at
a 50/50 rate, with 50 percent of the payment amount based on the
demographic rate and 50 percent at the risk adjustment rate. Beginning
with the January 2006 payment, risk adjustment will account for
75 percent of the Medicare reimbursement. For the January 2007 payment
and all payments thereafter, risk adjustment will be 100 percent
of the Medicare reimbursement.
This means the proper use of ICD-9-CM codes is more
important than ever. Humana’s Medicare reimbursements from
CMS and physicians’ reimbursement from Humana depend on the
proper submission of Medicare encounters/claims. In addition to
proper reimbursement, accurate recording of health-related data
augments further possibilities for education and clinical care research.
Remember that it is critical to code to the highest
level of specificity and to record all diagnoses in the medical
record. Also, the diagnosis code(s) must be supported in the medical
record and documented according to Medicare guidelines. CMS is performing
audits on data submitted.
Proper documentation also means informing Humana of
any overreporting that may have occurred. If you identify any overreporting
of diagnosis codes, it is important to report this data to Humana
so that the data in Humana’s systems and CMS’ systems
can be corrected.
Humana has a number of resources available to help
physicians understand and implement the HCC coding model. For more
information, visit the Humana Web site at www.humana.com.
On the home page, click on “Providers,” then click on
“Provider Resource Center.” Then choose “Health
Plans and Products” from the left side of the page. Scroll
down and click on the “Medicare Advantage” link. Enter
your ZIP code, and then select the appropriate Medicare Advantage
plan from the menu. The page that follows includes links to more
information on the CMS-HCC Medicare risk adjustment model and to
a free MRA ICD-9-CM coding tool that can be downloaded to a personal
computer or personal digital assistant (PDA).
The following Web sites also provide more information
about risk adjustment:
www.cms.hhs.gov/healthplans/riskadj
http://mcoservice.com/new/usergroup/traininginfo.html
www.ahima.org/infocenter/guidelines/standards.cfm
Talk to your administrative staff and clinicians about
the continued importance of ICD-9-CM diagnosis coding, coding according
to proper guidelines and proper medical record documentation, and
ensure that they understand which dates of service affect which
payment periods.
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