Double Dipping Redux

June 15, 2011

A discussion arose between the auditors in my office regarding "double dipping" and I am wondering if you would mind clarifying something for us. One auditor says that it is permissible to obtain a review of systems (ROS) from the CC of "arm pain" - using arm as the location in the HPI and pain as the ROS under MS. I have never audited in this manner and would appreciate any advice or direction you can offer.

Question: After reading your article on the history of present illness (HPI) and the chief complaint a discussion arose between the auditors in my office regarding "double dipping" and I am wondering if you would mind clarifying something for us. (From the November 2010 journal.)

One auditor says that it is permissible to obtain a review of systems (ROS) from the CC of "arm pain" - using arm as the location in the HPI and pain as the ROS under MS. I have never audited in this manner and would appreciate any advice or direction you can offer.

Answer: In the article you refer to I was surprised that any reviewer would have some type of "mutually exclusive" approach to elements of the HPI and CC. In your example, it looks like the CC is being used as the source of HPI and ROS elements.

To my knowledge, there is no body of regulation that really parses these issues in any way at all outside of the HPI/ROS double-dipping discussion. But in the spirit of the thing, the CC should be a concise statement, the HPI should amplify or expand on that (not rely on it), and the ROS is a discussion of potential or actual related issues related by the patient in response to a question or questions by the physician.

Any further attempt to qualify these components and their shared or discreet attributes is speculative at best. I think the example of the "arm pain" with "pain" as ROS is a huge stretch. It is simply the CC - HPI would develop the symptomology - and ROS questions would look for cause or context.

But at the end of day, it's all subjective.

Bill Dacey, CPC, MBA, MHA, is principal in the Dacey Group, a consulting firm dedicated to coding, billing, documentation, and compliance concerns. Dacey is a PMCC-certified instructor and has been active in physician training for more than 20 years. He can be reached at billdacey@msn.com or editor@physicianspractice.com.

This article originally appeared in the April 2011 issue of Physicians Practice.