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HEALTH SYSTEMS,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION
v.
LOGAN GENERAL HOSPITAL,
Defendant
.
.
NO. fr- 14D1- CIVIL ~ftM
NOTICE
YOU HAVE BEEN SUED IN COURT. If you wish to defend
against the claims set forth in the fOllowing pages, you must
take action within twenty (20) days after this Complaint and
Notice are served, by entering a written appearance personally
or by attorney and filing in writing with the Court your defenses
or objections to the claims set forth against you. You are
warned that if you fail to do so the case may proceed without you
and a jUdgment may be entered against you by the Court without
further notice for any money claimed in the Complaint or fo~ any
other claim or relief requested by the Plaintiff. You may lose
money or property or other rights important to you.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF
YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE
THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL
HELP.
CUMBERLAND COUNTY BAR ASSOCIATION
2 Liberty Avenue
CarliSle, PA l701J
717-249-3166
NOTICIA
Le han demandado a usted en la corte. Si usted quiere
defende se de estas demandas expuestas en las paginas siguientes,
usted tiene viente (20) dias de partir de la fecha de la demanda
y la notifcacion. Usted debe presentar una apariencia escrita 0
en persona 0 por abodago y archivar en la corte en forma escrita
sus defensas 0 sUs objeciones alas demandas en contra de su
persona. Sea avisado que si usted no se defiende, la corte
tomara medidas y peude entrar una orden contra usted sin previo
adviso 0 notificacion y por cualquier queja 0 alivio que es
pedido en la peticion de demanda. Usted puede perder dinero 0
sus propiedades 0 ostros derechos importantes para usted.
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NATIONAL HEALTH SYSTEMS,
INC. ,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION
v.
LOGAN GENERAL HOSPITAL,
Defendant
,
(,1 c.'. I '10 \
NO. r
CIVIL 199B
COMPLAINT
NOW COMES Plaintiff and makes the following Complaint
against Defendant:
l. plaintiff is a Pennsylvania business corporation, with
its principal place of business at 1104 Fernwood Avenue, Fourth
Floor, Camp Hill, Cumberland County, Pennsylvania.
2. Defendant is a not-for-profit hospital organized and
existing under the laws of the state of West virginia with its
principal place of business at 20 Hospital Drive, Logan, West
Virginia.
3. Plaintiff is in the business, inter alia, of providing
hospitals with expertise in the areas of DRG coding, Laboratory
and Radiology coding, and medical bill auditing services.
4. On or about September 23, 1996, plaintiff and Defendant
entered into an Agreement under which Plaintiff agreed to provide
to Defendant DRG Quality Validation Assessment services.
5. On or about November 21, 1996, Plaintiff and Defendant
entered into an Agreement under which Plaintiff agreed to provide
to Defendant'a Prospective DRG Quality Validation Review.
.. .-:
. ..
6. On or about April 2B, 1997, Plaintiff and Defendant
entered into an Agreement under which Plaintiff agreed to provide
to Defendant a DRG Quality Validation Assessment.
7. All three of these Agreements were accepted by
Plaintiff in Camp Hill, Cumberland County, Pennsylvania.
B. Plaintiff performed all of its duties and obligations
under the Agreements, and Defendant received the services as
outlined in the Agreements.
9. Plaintiff submitted the following statements for
services to Defendant, in accordance with the Agreements:
January 2B, 1997
February 10, 1997
February lO, 1997
February 14, 1997
March 5, 1997
June 9, 1997
August 7, 1997
$6,350.00
2,900.00
4,000.00
3,300.00
4,675.00
5,000.00
5,000.00
The statements are attached hereto collectively as Exhibit "D".
lOt To date, Defendant has paid Plaintiff none of the
above-referenced amounts.
ll. Even after repeated requests for payment, Defendant
refused to make payment to Plaintiff.
l2. Defendant is in breach of its obligations under the
Agreements in that it has not made proper payment to Plaintiff.
The Agreements are attached hereto as Exhibits "A", "an, and "COO
and incorporated herein by reference.
l3. Defendant owes Plaintiff $3l,225.00 to date, plus
interest and costs of suit.
'",
. .
Record Selection and Review Methodology
Logan General Hospital is requesting a prospective review of those cases reimbursed under the
DRG payment system. These include reviewing all Medicare, Medicaid, Workmen's
Compensation and Public Employee third party payer charts, NHS will review these cases to
determine the quality and accuracy of the coded data and its initial ORG assignment by the
hospital coding staff,
Each medical record will be reviewed by an experienced medical record professional. Each
inpatient medical record will be reviewed to verify the ICO-9-CM coding, ensure assignment
of the most optimal DRG assignment and the r.esulting reimbursement while focusing on the
following criteria:
. Correct selection and sequencing of principal and secondary diagnoses and procedures
. Identification of comorbid and complicating conditions
. Correct use of ICD-9-CMIDRG principles to classify diagnoses and procedures
. Reference Coding Clinic regulations, as needed
. Verify medical record documentation to support the reported diagnoses and procedures,
Our DRG specialist will be on-site at the facility three days per week to avoid any delays in
billing the charts. Once the hospital coder has coded a chart being reimbursed under the ORG
payment system, the coder will then flag the chart for review and not bill the case, After the
chart is reviewed by our specialist it is immediately returned to the coder for final billing if
there are no recommendations for DRG adjustments. If a DRG change is made, our specialist
will prepare a DRG Review Findings worksheet for each discrepancy identified during the
assessment. Hospital staff will receive a copy of the worksheet. The worksheet is designed to
document all relevant infonnation developed during the review process, Copies of the
worksheets will be provided to appropriate hospital personnel for review, comment, and fmal
billing on a daily basis to eliminate any cash flow delays,
Exit Interview
NHS will discuss all discrepancies identified during the review process at the time of the exit
interview to be held on a bi-weekly basis. The exit interview is welcome to all coders and any
other personnel the hospital wishes to involve, It is to be used as a forum for educating the
key staff on coding principles which impact the day to day coding process. All discrepancies
identified during the previous two weeks will be discussed for educational purposes. It will
focus on any coding patterns identified, specific coding principles and optimization techniques
to facilitate the learning process for the coders.
2
Exhibit "B"
. .
Record Selection and Review Methodology
NHS suggests a retrospective review of selected cases to determine the quality and accuracy of
the coded data for Medicare, Medicaid, Workmen's Compensation and Public Employee cases
or all third party payers reimbursing under the DRG system for inpatient medical records.
Under existing Medicare regulations, hospitals have an opportunity to review and resubmit
DRG coding information within 60 days following reimbursement from the Fiscal
Intermediary. NHS will identify accounts for review from remittance advices falling within
the 60 day "window of opportunity." NHS will also review remittance advices for case
seleciion for Medicaid, Workmen's Compensation and Public Employee third party payers.
The selection process will take into account DRGs that traditionally have been undercoded by
the facility and/or other facilities or have shown increased potential for review by third party
payers. The number of records reviewed will vary and be dependent on the hospital's
caseload at the time of review.
Each medical record will be reviewed by an experienced medical record professional. Each
inpatient medical record will be reviewed to verify the ICD-9-CM coding, ensure assignment
of the most optimal DRG and the resulting reimbursement while focusing on the following
criteria:
. Correct selection and sequencing of principal and secondary diagnoses and procedures
. Identification of comorbid and complicating conditions
. Correct use of ICD-9-CM/DRG principles to classify diagnoses and procedures
. Reference Coding Clinic regulations, as needed
. Verify medical record documentation to support the reported diagnoses and procedures.
NHS will prepare a DRG Review Findings worksheet for each discrepancy identified during
the assessment. The worksheet is designed to document all relevant information developed
during the review process. Copies of the worksheets will be provided to appropriate hospital
personnel for review. comment, and rebilling at the exit interview.
Exit Interview
NHS will discuss all discrepancies identified during the review process at the time of the exit
interview. The exit interview is welcome to coders and any other personnel the hospital
wishes to involve. It is to be used as a forum for educating the key staff on coding principles
which impact the day to day coding process.
2
Exhibit "e"
. . .
NHS will provide copies of the DRG Review Finding worksheet indicating proposed coding
changcs and relatcd Issues. Workshcets will be providcd to key staff involved in the coding
process at Logan Gencral Hospital for discussion and rcview for educational and rebilling
purposcs. Any coding patterns identified during the review process will also be discussed. It
will focus on specific coding principles and reimbursement optimization techniques to facilitate
the learning process for the coders. The methodology and results of the review process will
be incorporated into the exit interview.
DRG Validation Review Summary Report
DRG Review Summary Reports will be provided to Logan General Hospital at the conclusion
of the review. The report will be designed to provide a quantitative project fmding recap and
medical record specific detail. The detailed written report may contain the following:
. Detailed report outlining specific DRG changes and the Relative Weight differences per
case
. Forecast the fmancial impact as identified through the overall discrepancies
. Summary of the individual case fmdings
. Recommend solutions where coding problems exist, whether the problem is within the
coding area itself, or an interdepartmental issue
. Recommend solutions to facilitate timeliness of coding, in terms of changing a process
or utilizing reports to enhance coding
. Identify problems which may be attributed to technical errors, documentation
problems, and/or process issues.
Re-Submisslon of Claims
For each discrepancy identified, NHS will compare the payment difference from the original
to the revised DRG to assess the fmancial impact. No claim will be re-billed without Logan
General Hospital's adminigtrative approval. Logan General Hospital will have fmal
responsibility for the re-submission of claims. Any claim being re-billed will adhere to each
individual third party payer policies on rebilling procedures. NHS will also assist the hospital
in drafting any correspondence to third party payers to justify claim re-submission, as needed,
or to request any DRG changes.
Under this engagement, NHS will provide appropriate support to Logan General Hospital for
cases reviewed under this engagement where DRG issues are raised by the state Peer Review
Organization.
We will also be available to offer advise for DRG coding issues that may arise on records not
included in this engagement.
3
Exhibit "e"
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NATIONAL HEALTH SYSTEMS,
INC. ,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION
v.
LOGAN GENERAL HOSPITAL,
Defendant
NO. 98-1405
CIVIL
PRAECIPE TO ENTER JUDGMENT BY DEFAULT
TO THE PROTHONOTARY:
Please enter judgment by default in favor of Plaintiff,
National Health Systems, Inc., and against Defendant, Logan
General Hospital, for its failure to plead to the Complaint in
this action within the required time. The Complaint contains a
Notice To Defend within twenty (20) days from the date of service
thereof. Defendant, Logan General Hospital, was served with the
Complaint on March 23, 1998, and its Answer was due to be filed
on April 13, 1998.
Attached as exhibit "A" is a copy of Plaintiff's written
notice of praecipe to enter judgment by default, which I certify
was mailed by regular mail to Defendant, Logan General Hospital,
at its last known address on April 14, 1998, which is at least
ten (10) days prior to the filing of this Praecipe. I have not
been notified by any attorney that an appearance has been entered
of record on behalf of Defendant, Logan General Hospital.
Please assess damages in the amount of $31,225.00, plus
interest at the legal rate of eighteen percent (18%), which is
the interest rate pursuant to contract.
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