CMS increasing use of RAC (Recovery Audit Contactor) audits catching unprepared providers in their cross-hairs, and commercial payers are using sophisticated data analytics to identify coding and billing outliers as targets for audits. It’s critical that providers ensure that all documentation is as complete and accurate as possible. Here are a few tips to reduce the chances of an audit, or to pass one if your practice is targeted.
The Importance of Medical Documentation
Accuracy encompasses all forms of information oversight: patient identification, amendments and corrections to records, validation of author, plus auditing for document validity before sending out as part of a claim for payment. Knowing that multiple systems will probably be involved in an audit, all data should be documented, including meaningful use, reports generated by the practice’s EHR system, and other evidence supporting medical decisions.
Procedures that are more likely to be scrutinized are sleep studies, outpatient physical therapy and MRI’s, which the Office of Inspector General (OIG) believes may be overused and are among the OIG/RAC targets requiring careful documentation.
Use Technology to Help Avoid Discrepancies
Besides understanding best-practice procedures, incorporating better technology into the documentation process can sharply reduce errors due to wrong coding or missing other critical information. However, beware of relying too much on templates, and avoid cut-and-paste documentation that isn’t patient-specific. Sometimes changing EHR billing software is enough to require upgrading or changing a practice’s multiple systems to be workable.
Review Every Process and Improvement Utilized
Without documentation safeguards, incomplete or erroneous records could give an incorrect picture of a patient’s condition whether at the outset or during treatment. Practices also need to implement risk-based auditing into their review processes, including avoiding over-coding evaluation and management (E&M) relative to their peers, which could put them at risk for an audit. Be sure that codes and modifiers are used correctly as well: RN Teri Romano also recommends that providers avoid overuse of levels 4 and 5 codes when compared to other peer providers in their state and specialty, as doing so can send a “red flag” to CMS as well as other payers. Remember that your EHR E&M coding-selector engines aren’t always consistent or accurate.
Download: RAC Audit Checklist – Simple Action Plan for RAC Audit Compliance
Plan for the Worst-case Scenario
As the saying goes, “prepare for the worst and hope for the best.” Most audits are triggered due to a history of non-compliance or related past problems; however, more practices are being randomly audited, even with no apparent violations or errors. According to Frank Cohen, director of analytics at Doctors Management LLC, being audited is almost an inevitability given the use of predictive analytics by the government. Be proactive: hope alone will not prevent an audit nor ensure that your practice passes one. If your practice is audited at random, having all of your documentation complete, accurate and fully compliant is the only way to be confident that your practice won’t be caught off guard and that if audited, the results will be favorable.
Experienced Medical Billing Service Provider Part of Your Team
M-Scribe was founded by physicians for physicians who know better than most about the risks leading up to audits and their results. Our team includes CPT-certified coders, with experienced medical billers and account receivable (AR) personnel to ensure that documentation is complete and claims are sent out accurately each time. Our experienced coding auditors and pre-adjudication experts also review claims before submission for any additional information as well as what will be paid.
Contact M-Scribe today at 770-666-0470 or email me at h.gibson@m-scribe.com for a confidential assessment of your practice’s needs including pre-audit status, and learn how we can increase your revenues while ensuring full compliance.
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