The Approved and Only Acceptable HCA Incentive Pay Plan for Coding Is Documented in The

DEPARTMENT: Regulatory Compliance Support / POLICY DESCRIPTION: Coding: Additional Compensation Plans
PAGE: 1 of 2 / REPLACES POLICY DATED: 5/97, 9/2/98, 8/1/00, 6/30/02, 3/1/04 (HIM.COD.008), 3/6/06, 2/1/08, 1/24/09
EFFECTIVE DATE: January 1, 2011 / REFERENCE NUMBER: REGS.COD.008
APPROVED BY: Ethics and Compliance Policy Committee
SCOPE: Employees responsible for performing, supervising or monitoring coding of hospital inpatient and hospital outpatient services, including, but not limited to, employees in the following departments:
AdministrationEmergency Department
Registration/Admitting/SchedulingFacility Health Information Management
Radiology DepartmentAncillary Departments
Ethics & Compliance OfficersCorporate Regulatory Compliance Support
Laboratory DepartmentCase Management/Quality Resource Management
Human ResourcesPatient Access
HIM SharedService Centers (HSC)
PURPOSE: To ensure that onlythe approved HCA Incentive Pay Plan for Coding is used for any employeeinvolved in the performance or management of hospital coding processes. Implementation of an approved coding incentive plan is voluntary; however, if a plan is implemented then it must be done pursuant to this policy.
POLICY: The HCA Incentive Pay Planfor Coding is the ONLY acceptable plan that can beusedfor employees responsible for performing, supervising or monitoring hospital coding of inpatient and outpatient services if a plan is implemented. Lump sum payments or other incentive pay plans for non-codingrelated special projects or functions are acceptable such asmeeting education expectations, survey results, budget management, clean-up projects and employment/sign-on.
PROCEDURE:

The approved and only acceptable HCA incentive pay plan for coding is documented in the Attachment to this policy.

The HCA Incentive Pay Planfor Coding is the ONLY plan that may be implemented for any Company employee involved in the performance or management of hospital coding processes, with exception as noted within the plan.

If anHSC/facility has a coding related incentive or bonus pay plan that is different than the approved plan in Attachment A, then:
Thenon-approved coding incentive and bonus pay plan must be terminated immediately and reported to the HSC/facility CFO and ECO.
Current coding incentive and bonus pay plans must be reviewed with the HSC/facility CFO to determine an immediate and appropriate coder compensation transition plan and/or transition to the approved coding incentive plan.
Consult the HSC/facility Human Resources Department for advice on coder compensation plans and/or implementation of the approved coding incentive plan.

The HCA Incentive Pay Plan for Coding will be monitored by Corporate Regulatory Compliance Support (Regs) and Shared Services Division HeathInformation Management (SSD HIM).

a.It is the responsibility of HSC/facility HIM Management to ensure that this plan is applied to all eligible individuals involved in coding of hospital inpatient and outpatient services.
b.HSC/facility HIM Management is responsible and accountable for ensuring all documents and calculations are valid,accurate and retrievable.
c.Employees who have questions about a decision based on this plan or wish to discuss an activity observed related to application of this plan should discuss these situations with their immediate supervisor to resolve the situation.
d.All day-to-day operational issues should be handled locally; however, if confidential advice is needed or an employee wishes to report an activity that conflicts with this plan and is not comfortable speaking with the supervisor, employees may call the toll-free Ethics Line at 1-800-455-1996.
e.For any questions regarding this policy, please contact the HIM Operations Communications mailbox or RegsHelpline via Outlook.
REFERENCES:
Coding Documentation for Inpatient Services Policy, REGS.COD.001
Coding Documentation for Outpatient Services Policy, REGS.COD.002
Coding Documentation for Skilled Nursing Facilities/Units Policy, REGS.COD.010
Query Documentation for Clinical Documentation Improvement (CDI) & Coding – Compliance Requirements Policy, REGS.DOC.002
Inpatient Coding Quality Monitoring & Benchmark Analysis Policy, REGS.COD.016
Records Management Policy, EC.014 (applies to all clinical and business records)
Health Information Management Productivity Guidelines (By Function)
Coding Quality Control & Benchmark Analysis Manual
CPCS Abstract Module Compiled Reports

12/2010

Attachment to REGS.COD.008

HCA Incentive Pay Plan for Coding

Purpose

To ensure that the HCA Incentive Pay Plan for Coding is used for any Company employee involved in the performance or management of coding processes. The implementation of the incentive plan is voluntary; however, if the plan is implemented then compliance with the outlined process is mandatory.

Scope

Coding Management may include HSC/Facility Coding Director, HIM Director, HSC/Facility Coding Manager, Coding Supervisor, HSC Coding Leads.
Coding Staff includes all HCA full-time and part-time acute care coders (inpatient, outpatient, and inpatient/outpatient)
HSC Coding Management can either participate in the HCA Incentive Pay Plan for Coding or the HSC Incentive Plan but not both.

Eligibility for the incentive plan

Coding Management

Employees who are listed in the above scope statement
Reporting Manager affirmation that the employee’s behaviors and actions were consistent with HCA’s Mission and Values, Corporate Code of Conductand other regulatory requirements
Coding Management may qualify for only one (position) level of incentive (e.g., coding supervisor or lead coder that codes X% of the time)
Employees are employed at the HSC/facility at the time of pay out
Employees with no formal disciplinary actions during the incentive period
Employees must have been employed and working in the covered role by October 1 of the incentive calendar year

Coding Staff

Reporting Manager affirmation that the employee’s behaviors and actions were consistent with HCA’s Mission and Values, Corporate Code of Conduct , and other regulatory requirements

All coders who are listed in the above scope statement

Coders who were employed at the HSC/facility for the entire incentive calendar year

Payment shall be made annually, based upon the preceding calendar year performance

Coders who are employed at the HSC/facility at the time of pay out

Coders who have had no formal disciplinary actions during the incentive period

Coding Management and staff that are hired after January 1 but prior to October 1 of the incentive calendar year will be eligible for a prorated portion (for annual measurements) of pay based upon the number of months they are eligible in that year. A new coder’s productive and quality measures should not be included in the measurements until the month following the completion of 90 days.

For example, if a coding management employee was hired by May 10, she/he would be eligible for seven (7) months prorated incentive (June through December).

Continuing the example, the total prorated incentive amount based on a percentage of annual salary is calculated as follows: X% x $XX,XXX = $X,XXX

Eligible incentive percentage current annual salary 12 month incentive rate

$X,XXX x 7/12 = $X,XXX

12 month incentive rate # of months eligible Total eligible incentive amount

The total prorated incentive amount based on a predetermined payment amount iscalculated as follows:

$X,XXX x 7/12 = $X,XXX

Predetermined payment amount # of months eligible Total eligible incentive amount

Criteria

Coding Management

Coding Management must meet ALL of the following criteria to receive incentive pay:

All staff ‘tagged’ as coders (including themselves as applicable and prn coders) have performed and met all educational requirements per REGS.COD.006; and
Productivity (using the attached coder productivity tool) for the entire coding staff must be 95.00% or greater; and
Results of all internal/external coding quality reviews must be at 95% or greater.
Internal reviews -Internal reviews include coding quality reviews performed by HSC/Facility Coding Director, HIM Director, HSC/Facility Coding Manager, Coding Supervisor, and HSC/Facility Coding Leads.
External reviews - External reviews include allcoding reviews performed by a credentialed coder such as HCA Internal Audit, Regs, RAC, OIG, CERT, MIC, etc.Final review outcomes must be included for discharges within the incentive calendar year for which the employee managed the coding processes.

Goal / Measurement
Coding team training and development / All coding staff and staff ‘tagged’ as coders (including themselves as applicable) have performed and met all required educational requirements per REGS.COD.006
Coding Team Review MS-DRG/Overall OutpatientAccuracy Rate[1] / Results of all internal/external coding reviews for year are ≥ 95%.
Coding Team Productivity Rate[2] / Results of the entire coding team’s productivity for year are ≥ 95%.

Coding Staff

Coders must meet BOTH the accuracy and productivity standards for the incentive calendar year AND be in compliance with REGS.COD.006.

Productivity (using the attached coder productivity tool) must be 95.00% or greater; and
MS-DRG/Outpatient accuracy rate must be 95.00% or greater and
Completion of coder education requirements as outlined in REGS.COD.006

Goal / Measurement
Productivity /  95.00%
MS-DRG/Overall Outpatient Accuracy Rate /  95.00%
Coder Education Requirements / Timely completion of coder education requirements
as outlined in REGS.COD.006

In order to ensure a balanced approach of quality and quantity, the coding incentive plan may NOT include the following indicators:

a. Case mix,

b. Base case mix,

c. Percentage of major surgery,

d. Medicare Focus List I, II, or III percentages or volumes,

e. Complication and comorbidity (CC) percentage,

f. MS-DRG pair percentages or volumes,

g. Days from discharge to bill.

h. Accounts Receivable Days/Dollars, or

i. Other coding indicators that are impacted by factors beyond complete, accurate and consistent coding(e.g., Core Measures,Hospital Acquired Conditions (HAC), State Reporting initiatives, etc.).

Procedure

Incentive compensation amounts for coders and coding management will be determined based on the HSC/facility’s annual budget. Incentive is paid out once annually. The following options need to be determined for budget approval prior to the calendar year the incentive plan is implemented:

Percentage of annual salary or predetermined payment amount
Incentive approach
Tiered; or
Non-tiered

Example of a non-tiered incentive:

Accuracy Rate / Productivity Rate / REGS.COD.006 / Eligible Incentive
 95.00% /  95.00% / In compliance / Ineligible
 95.00% /  95.00% / In compliance / Ineligible
 95.00% /  95.00% / In compliance / Ineligible
 95.00% /  95.00% / Non-compliant / Ineligible
 95.00% /  95.00% / In compliance / X% or $X

Example of a tiered incentive(incentive is based on lowest line item met):

Productivity Rate

In order to incorporate individual coder productivity measures into an incentive pay plan, the facility or HSC MUST adhere to the HCA Productivity Guidelines, which lists the following hourly coding productivity standardsfor each specified patient type:

Record Type / Facility Environment / HSC Environment
Inpatient / 4 / 4
Observation / 5 / 6.25
Same Day Surgery / 5 / 6.25
Emergency Department / 20 / 25
Emergency Department
w/E&M without Charge Entry / 15 / 15
Emergency Department
w/E&M and Charge Entry / 12 / 13
Clinical / 30 / 37.5
Recurring / 30 / 37.5

These standards are required to be utilized in conjunction with the Coder Productivity Monitoring Tool. HSCs standards become applicable six months after the coder migrates into an HSC. The Coder Productivity Monitoring Tool calculates individual coder productivity. The tool contains the mechanism to measure productivity based on the difference in the record type coded. Productive hours from the Kronos report are entered into the tool. Productive hours are the coder’s hours minus allowance for the following non-coding time:

Standard Daily Allowance which includes: two 15 (fifteen) minute breaks per eight hour shift, when taken, and 15 (fifteen) minutes daily for system start-up and shut down including email review.
Educationincluding but not limited to Healthstream courses, AHIMA education sessions, mandatory conference calls, other required Corporate mandated education, journal reading, review of new Coding Clinic and CPT assistant publications.
Meetings/Quality Review including standing or scheduled meetings between the coder and manager including time spent reviewing personal coding audit results and reviewing educational opportunities, staff meetings.
System Downtime – this category requires manager approval. Examples of appropriate use include time spent working with IT staff to troubleshoot a system issue.

The corresponding Kronos report, along with the productivity tool calculation must be retained in accordance with EC.014 for Internal Audit purposes. This tool is complimented with the Coder Productivity Monitoring Procedure Tool, which provides instructional direction regarding the use of the Coder Productivity Monitoring Tool. These tools can be accessed via the Atlas link below.

HIM Director’s Toolkit

MS-DRG/Overall Outpatient Accuracy Rate

Internal coding quality control monitoring must be performed on a quarterly basis using a random sample for each coder. It must be a true random sample as described in the Random Inpatient/Outpatient Record Selection section below. The quarterly reviews are to be performed retrospectively on at least 30 inpatient records for inpatient coders; 30 inpatient and 30 outpatient records for inpatient/outpatient coders; or 30 outpatient records outpatient coders. The inpatient accuracy rate will be based on MS-DRG validation. The outpatient accuracy rate will be based on a combined accuracy rate. The individual coder must achieve an annual MS-DRG, MS-DRG/OP, or OP accuracy rate of 95.00% or greater to be eligible for incentive.

Inpatient

All inpatient types are included.

In addition to MS-DRGvalidation, the following items must be reviewed (will not impact incentive eligibility):

Sex

Age

Patient Status Code

Birth weight for neonates

Patient Type (IP vs. OP)

Admit/Discharge Date

Outpatient

Outpatient types include:

Observation (INo)

Surgical Day Care (SDC)

Emergency Department (ER)

Clinical (CLI)

Recurring (RCR)

If HIM coding staff is responsible for assigning Evaluation and Management (E&M) codes for any patient type, these codes must be validated in the process of reviewing applicable records.

Outpatient records will be reviewed based on the accurate assignment of:

HIM APC

CPT code(s)

ICD-9-CM codes

Modifiers

E&M assignment

Who Performs HSC/Facility Based Reviews

Reviews must be performed by HCA HIM/Coding staff (e.g., HSC Coding Director, HIM Director, Coding Manager, Coding Supervisor, HSC DQE, Lead Coder) who has met all mandatory educational requirements as outlined in Company policies REGS.COD.005, REGS.COD.006, or by a Certified External Coding Vendor (refer to REGS.COD.011).

Random Inpatient/Outpatient Record Selection Process

A report should be compiled in MEDITECH Abstracting Statistical Reports. Ensure the correct discharge date or service date range is selected for the quarter and abstract status is Final. All payers are to be included. For example, if the HSC/facility is conducting QC for the first quarter of the year, select date ranges of 1/1/xx through 3/31/xx. The report should be ‘Major’ sorted by coder. ‘Minor’ sort the report by MEDITECH patient status.

In order to obtain patient level information, the report must be printed from Patient Reports in Abstracting. For more information on complied reports, please refer to the CPCS document on Atlas:

Once the Patient Report is printed, record selection for each coder must include every 5th record for each patient type until the minimum review volume is achieved. For example, Coder A is an IP/OP coder which codes inpatient and SDC records. For inpatient record selection, you will select every 5th record on the report totaling 30 for inpatient. For SDCs record selection, you will select every 5th record on the report totaling 30 records for SDCs. A total of 60 records would be reviewed for Coder A.

If a patient type’s total volume for the quarter does not equal 30 records following the random selection process of every 5th record, the process shall be repeated applying the selection of every 6th record until the minimum review volume is achieved.[3] If the total volume for a patient type by coder is 30 or less, then 100% of the records must be reviewed. If a HSC/facility chooses to review volumes beyond the minimum requirements the same volume must be reviewed for all coders to ensure equity. In addition, the same random sampling methodology must be used to select the records.

Quarterly volumes:

Inpatient Coder – minimum of 30 inpatient records

Inpatient/Outpatient Coder – minimum of 30 inpatient and minimum of 30 outpatient records

Outpatient Coder – minimum of 30 outpatient records

(Note: Record review sample must be equally distributed among all patient types coded by the coder for the quarter being reviewed)

Coder / IP
Records / OBS Records / SDC Records / ED Records / CLI Records / RCR Records / E/M Assignment[4] / Total
Records
Quarterly
IP Coder:
Codes IP only / 30 records / 30
IP/OP Coder:
Codes IP, OBS & SDC / 30 records / 15 records / 15 records / 60
IP/OP Coder:
Codes IP and all OP types / 30 records / 6 records / 6 records / 6 records / 6 records / 6 records / 60
OP Coder:
Codes ED & CLI / 10 records / 10 records / 10 records / 30
OP Coder:
Codes all OP types / 5 records / 5 records / 5 records / 5 records / 5 records / 5 records / 30

Accuracy Rate Calculations

The plan incorporates the minimum accuracy rate that must be attained for consideration of a quality incentive. For example, to be eligible for incentive pay, a coder is required to meet a 95.00% or greater MS-DRG, MS-DRG/OP or OP accuracy rate.

Overall MS-DRG Accuracy Rate

An overall MS-DRG accuracy rate represents the accuracy of overall MS-DRG validation as identified from the review results.

# MS-DRG Changes____ = ____ X 100 = % Overall MS-DRG error rate

Total # Records Reviewed

100% – ___% MS-DRG error rate = % MS-DRG Coding Accuracy Rate

HIM APC accuracy rate

An HIM APC accuracy rate represents a statistical assignment of the accuracy of the HIM assigned APC codes in relationship to the review sample of HIM APC assignments in total.