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Hey all – with the HEDIS audit – it has come to our attention that if we are billing WIC services to Medicaid, we should be having a separate record for all their visits showing the services provided, codes, amounts charged, and a signed disclosure giving us permission to bill Medicaid for their visit.
Now, this was a surprise to us here at Barry County. Is everyone else doing this? If so, do we need to have the client sign an authorization to bill Medicaid and/or HIPPA disclosure at each visit?
We are not doing this either and at this point HEDIS has not notified us of this. Can you please tell me where I can obtain these requirements in writing?
Thank you!
Your record of billing will contain codes and charges. Patient sign Rights and Responsibilities for WIC BUT I don’t know if that contains a line about billing for services.
I have not seen any written requirement.I was going to ask how everyone was approaching this. We have the Nutritionists fill out information on a large group spreadsheet and when it is full they move on to another. The spreadsheet has DCN numbers, DOB, Name, and place to write ht,wt,hgb.Do you think its ok to white out the ones they haven’t requested and send that? This is all so confusing!
We do not keep a separate chart and the time it would take to document everything twice would make it not even worth billing when you look at the salary and benefit expense for the time to do so. I think that is crazy. I don’t see why we cannot print out the Participant Summary and black out the WIC ID and household number and use that for our documentation. I was told we cannot do that. I am planning to write an SBAR about this issue as soon as I have time. Also, when I called Keri Burk she said that we should be having clients sign an authorization to bill Medicaid. Everyone I’ve talked to so far says they are not doing that. If anyone knows where it is in writing that we are required to do that I’d love to know. Also, I was told that if we give them the MOWINS printout that is going against federal regulation. I’d like to know what regulation. MOWINS is the vehicle that carries the record, like any other EMR. So, you’re telling me if we had paper WIC charts instead of electronic charts it would be okay to provide that documentation? I’ve already seen a drastic decrease in my Medicaid revenue over the last five years and in-kind thousands of dollars every year to WIC…
I thought a few weeks ago were instructed not to be sending WIC records for HEDIS in the WIC updates?
At our department, we have all WIC participants sign our regular PH office consent form on each visit. The signed consent includes: Consent to Treat statement, Release of Information for Billing, and Payment Assignment. We also then make a charting note in our PH software that states why the patient was seen (very generic reasons (ex: wic cert, wic re-cert, finger stick, etc.)), by whom and date/time.
We have never had an audit on it though.
There really needs to be a discussion between the groups (DHSS, LPHAs, Medicaid and FS) about this. Years ago we were able to bill for WIc services and it was a very easy billing process. I actually called about the process to bill when I started here in 2007. I was told then we did not have to have an RN doing the WIC visits to bill Medicaid for them. The only rule was that we could not bill for services unless we could show that we did not have enough money from WIC to cover WIC. As we are all learning more about billing/coding (because we have been forced to for revenue) and review the provider manual we realize we cannot bill the 99211 unless an RN is seeing the clients. There have also been many questions asked about how to verify new vs established client since most of us dont’ have MD’s in the office but are using standing orders in which the MD who wrote the orders will likely never see our patients. There is so much confusion around this and the only assurance I can get it “well everyone bills WIC and they have always allowed it so they can’t do much to you.” Ummmm, no thanks. I need something more in writing or within a policy than that.
Our WIC caseload is down and the WIC budget situation is not good. If we ever needed the revenue for these visits from Medicaid it is now. Add to the revenue loss the confusion about signing releases in WIC, audits, etc and all of this will take more time=more money.
I have been asking for someone to create a task force or group to address these issues for the last two years but nothing gets done. It is the lpha’s who are suffering. We are losing revenue and we need guidance. We are left either unfunded or in a situation where we can get into legal trouble for billing incorrectly. It baffles me that we are still all confused about this and cannot get a solid answer from anyone. There are simple fixes to all of these issues if we could just get a group of decision makers from the agencies above to sit down and listen to the LPHA’s. I know an SBAR has been created to address the issues on HEDIS, hopefully that conversation will expand and we can get something done.
Angie – why do you think you can only bill a 99211 if the client sees an RN?
This all started when my WIC Coordinator was confused on the email we received in prepping us for the HEDIS audit. The email stated that we HAD to disclose records but COULDN’T disclose that they were in the WIC program. When my coordinator spoke to her contact (can’t remember their name now) I specifically asked this person how we were suppose to disclose the record without disclosing that they were WIC. This person is the one that told me about the WIC encounter form that shows just a small statement of what they were seen for (codes, fee, etc) along with their signed authorization that I could bill those said charges to Medicaid. She then recommended that we keep these encounters in a separate paper file for such instances as an audit. She emailed me an example, and we have been drafting our own copy from it.
The question I still have is – do they have to sign this authorization EVERY appointment – or is it like our regular HIPPA form that our other clients sign once a year? We do NOT have EMR here – we are old school with paper files.
Ok ladies –
I called Keri Burk at 573-751-6498 (Keri.Burk@health.mo.gov) to clarify what the state says about using MOWINS screen shots as proof of visit, and this is what she said: paraphrasing Policy 1.01700 Confidentiality – we as providers CANNOT share any kind WIC record. This includes print outs from MOWINS or any other state owned software with information blacked out/redacted because WIC is confidential and owned by the state.
She also stated that WIC clients cannot be treated any different than your regular clients. If the auditor asked about a non-WIC client, how would you complete their request. We must be able to do the same thing for our WIC clients. We are discussing how to separate them here at Barry County. Our clerks feel like it would be easier to give them their own file (just like our other clients), but we are still unsure if we have to have them sign the billing authorization each time they come in. Keri stated that I needed to get clarification on that from Medicaid, so I have reached out to the Provider Education department; unfortunately, I had to leave a message, so who knows how long it will be before I get a response.
I will keep you updated on what I find out.
My reply to HEDIS when it comes to WIC clients is that the State has those records and we can’t get access to them. So I send the appointment demographics page because that is all we have in our EHR for WIC clients. I don’t know but are these HEDIS requests part of the Managed Medicaid Contract? I have only gotten requests from the managed care companies for Medicaid clients.
Update:
Per Dana LaFontaine (Medicaid Provider Education Supervisor) at 573-751-6683 – client agrees and understands that all services done by a provider (doesn’t matter reason why) are subject to billing. Therefore, client does NOT need to sign any kind of authorization giving the provider the right to bill for services.
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