I've never heard of someone filing a note under a different service name. Who controls the templates? At our hospital we use our own template so my partner and I made our own, which we share, and internal medicine has their own. If I needed to edit the template it's something I can do myself.
It sounds like you're saying IT controls the templates. If they can't change the template then there's something wrong with that IT department.
This could be a medico-legal thing. While IM can admit to rehab, I don't think they can pretend they're PM&R just as you can't pretent you're IM. Now if they have 1yr of rehab experience that lets their H&P count for Medicare purposes, but even then they're just a "rehab doctor" and not "PM&R," which is a title that conveys board-specified training. An IM doc can't write an "Allergy & Immunology" or "GI," note, and how a PM&R doc can't write an "internal medicine note." So I don't think that PM&R title is kosher--maybe you can ask your legal department to get involved? If I'm correct here on the use of the "PM&R" title, then legal telling IT it's not kosher will solve that problem quickly.
I think it comes down to two issues:
1) Can IM legally write a PM&R note if they're not PM&R board certified? Legal (ie., risk management) should weigh in. You can e-mail them directly with your current issue.
2) If IM is writing PM&R notes, then if you see them the same day and you both bill, it could be argued someone is committing fraud. Probably not you since you're actually PM&R, but as far as I know you can't have the same specialty write two notes on the patient on the same day and both bill for it. Since they're not actually PM&R and are doing IM things, maybe if you guys were investigated it'd get dropped and they'd see it's just a "filing/naming error" or something. Or maybe OAG asks for X amount of Medicare dollars back for double billing...
It's a bit nonsensical that given the risk of the above two things, which may not be totally clear even to legal/billing compliance, and the simplicity of fixing the issue (IM writes all notes with IM header), why your hospital wouldn't just go ahead and just fix the templates. It's quicker to fix the templates than to have legal/billing look into the compliance issues above.
If you're the medical director of the rehab unit, part of your job is to protect the unit and minimize risk of (and from) audits. So you can tell them "this is how it needs to be done--now figure it out."
If I'm totally misplaced, I'm sure someone will correct me. But while I can (legally) go out and hang a shingle to start a "psychiatry-like" practice, I cannot call myself a psychiatrist. That's fraud--I am not board-certified in psychiatry. And my guess is even if I called myself a "mental health physician" in advertising to patients, were I to title my notes "psychiatry intake," it might open up some legal/med-mal issues.
You are preaching to the choir Ranger Bob! Those are exactly the points I have argued. The issue is that this medicine group covers a number of the facilities in other sister hospitals. Here in this facility I am the only PM&R doctor and they are IM however they are "double credentialied" as "rehab doctors" -which doesn't make me comfortable to begin with. I guess bc there is a technicality of the one year experience that's where the "technicality" is - however that still doesn't make them PM&R doctors.
We had the EXACT issue you mention above - they were writing PM&R notes when I was writing them and I noticed that and was like wth? is going on? I told them that would be considered fraud if we get audited if two providers from same specialty chart and bill on the same day. So I said I am not only a Board certified fellowship trained PM&R doctor but I am also the medical director - this needs to get fixed now! Not only if we get audited it will be viewed as fraud, and I won't be the one in trouble since I am working and charting within my board certification - but they will likely be viewed as such and I wouldn't be suprised if Medicare/insurance takes payments back from them.
The whole thing made no sense.
The thing is that they didn't have a PM&R doctor for a number of months and they also see the Medicaid patients - when they were the only physicians here (no PM&R) they were acting as the "PM&R" physicians - which they shouldn't have and writing notes under the PM&R heading.
In another sister hospital we have, they have no PM&R because they coulnd't find a PM&R doctor willing to move to the area so the same group that rounds here - they made one of those physicians the "medical director" and that physicians (despite being either IM/FM i can't remember) acts as the "PM&R" physician at the other hospital.
So they were writing general notes and compliance told them that things were not in compliance bc they didn't have the 3 notes/week in terms of function - so the solution that they came up with was that they needed to write under PM&R.
When I came on board I said that's ridiculous and makes no sense bc I'm the PM&R doctor so I will be writing those notes.
I can't force corporate to change templates but I keep bringing this up because I'm not comfortable with it - I won't defend their use of this and their actions in this either if crap ever hits the fan and I have advised them of this. While I am doing the appropriate thing by writing notes under my board certification and competencies they are not.
So while I can pseudo accept the technicality of them acting as "rehab doctors" which is a general thing, for them to note under "PM&R" I don't find acceptable - I just don't know what the solution is. I agree that for them to do this is fraudulent.
I don't want to stir the pot, but this is making me uncomfortable.
