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 “CODE THIS!”

New Code for Specialist Self Designation

by Renée Allen, MD, MHSc., FACOG and Meredith Morgan, MD

April 14, 2017 

 

SOGH strives to keep our members abreast of news that impacts our practice as hospitalists; news that you are unlikely to gain through other media. With that in mind, in lieu of a case of the month, “Code This”, has decided to instead share with you new developments within the coding world that may affect our field.

As of April 3, 2017, hospitalists can use their own dedicated specialty code. The dedicated code known as C6, allows hospitalists to differentiate themselves from those of outpatient practitioners including internists and family physicians.

According to Hospital Medicine, the C6 code may improve the accuracy of tracking hospitalists’ benchmarks such as performance and cost. Current measures fail to consider the unique complexities of the hospitalists’ patients as compared to an outpatient practice. Hospitalists serve patients from all demographics, often with severe illnesses, little available history and limited pre-admission care. Benchmarks used for an outpatient practice simply will not apply for the hospitalist. For this reason, hospitalists may be inappropriately penalized under meaningful use requirements. For instance, when a hospitalist designates a patient encounter as observation, this may be erroneously evaluated as part of an outpatient encounter. This leads to flawed evaluation of quality and cost metrics, which in turn misrepresents the performance and costs associated with being a hospitalist. Having this new code may help shape the Medicare Access CHIP Reauthorization Act (MACRA) and future healthcare policies.

Use of the new code by hospitalists is voluntary and its use should not affect billing. The potential information provided by those choosing to employ this new code will provide more accurate metrics for their performance. Benchmarks established by the self-designated specialty population of providers using the code should accordingly reflect the processes and outcomes of the data from those providers.

Currently, physicians self-designate their Medicare physician specialty at the time of enrollment in the Medicare program. Per CMS Manual System Pub 100-04 Medicare Claims Processing, Number 9716.04.1, “Contractors shall make all necessary changes to recognize and use the new physician specialty code C6 as a valid primary specialty code or a secondary specialty code for Hospitalist.”

While there are a few OB/Gyn hospitalists who limit their practice to OB/Gyn surgery, the number who restrict their practice to internal medicine inpatient care is unknown. SOGH welcomes feedback about any OB/Gyn hospitalists who do limit their practice to inpatient cognitive services (gynecologic or otherwise), internal medicine-type cases, and/or to Medicare beneficiaries such as pregnant patients on dialysis.

At the time of this writing, the self-designation status seems to primarily focus on internal medicine (CMS specialty code 11 and hospitalist C6). There are 59 physician specialty codes including 16 which designate obstetrics and gynecology.  Currently the Center for Medicare and Medicaid Services (CMS) states “MLN article: A provider education article related to this instruction is available at http://www.cms.gov/Outreach-and-Education/Medicare-Learning-Network-MLN/MLNMattersArticles/ .“

The option for OB/Gyn hospitalist to self-designate primary and secondary specialties is available. However, it may be prudent to await analysis of the aforementioned MLN article to determine the use of C6 as primary and 16 as secondary as opposed to 16 as primary and C6 as secondary. Until then, it seems logical that OB/Gyn hospitalists medical claims will be in the 16 specialty designation. Currently, the impact of changing from one’s established designation is unclear.

The C6 designation is strictly for usage with CMS (Medicare/Medicaid/tri-care) services databases.  When enrolling into the Medicare/Medicaid program, it is up to the provider or practice to self-designate what specialty to which they most closely align themselves. Providers may change their specialty designation through the Medicare enrollment application (Form CMS-8551) or through CMS’ online portal (Provider Enrollment, Chain, and Ownership System, or PECOS). As this does affect how data is tracked, the self-designation may impact flagging of “over/under usage” in additional data and claims that are pulled through the CMS system by providers.  Private third-party payers are not obliged to follow those guidelines.

Your thoughts on self-designation as a hospitalist are welcome. Please complete and submit this form. Feedback and analysis will be published in a future newsletter.

Dr. Meredith Morgan, serves as President of  SOGH

Dr. Renée Allen is the SOGH Liaison to the ACOG Committee on Health Economics and Coding, Chair of the SOGH Coding Committee and Co-Chair of the SOGH Development Committee.  She currently works as an OB/GYN Hospitalist with Mednax/Obstetrix at Eastside Medical Center in Snellville, Georgia.