Audit

Consider an internal audit referred to as a compliance audit of your chart notes/medical record documentation and billing/coding to determine if you are potentially at risk of an audit or clawback by CMS, the Centers for Medicare and Medicaid Services or by a commercial health insurance carrier and determine what steps need to be taken to mitigate those risks. It is inevitable that in all likelihood a provider will be audited. An audit should never be more than an inconvenience. It should not be a life-changing event. If a clawback takes place, it would be bad enough if face value reimbursements were requested after the fact. Unfortunately, this is usually not what occurs. The assumption is that since the billing, coding and documentation did not support the claim(s) that were filed, the requested amount to be repaid will be far greater. Interest, penalties and an extrapolation is instituted referred to as the Statistically Valid Random Sample or SVRS that will result in an amount that needs to be repaid that is far greater than what was initially reimbursed.

Can you please explain what a “RAC” audit is?

“I am part of a recovery audit from CMS for using a modifier 59. Cotiviti Healthcare has been hired by CMS to review my use of modifier 59. They stated that my operative report supports documented Charcot reconstruction and the use of application of external fixator (CPT 20692) but modifier 59 was inappropriately used since both procedures were performed at the same session. Should I have used a different modifier in this situation? Is application of an external fixator (CPT 20692) not considered a separate procedure if it is performed at the same session as other reconstruction procedures?"

“I received notice I am being selected for a TPE (targeted probe & education) review by Novitas Medicare. I practice in New Jersey. I have gone over the LCDs and the “educational” materials they sent. My documentation seems to be aligned with what they want. Any advice for working with them to have this resolved as soon as possible? Any things to avoid? Should I have someone other than myself act as a liaison between Medicare and me?”

in order to be HIPAA Compliant, you must maintain a "Culture of Compliance" at your office. This can include keeping your software up-to-date, regular required training and addressing risks that pose to your office. This month we address dedicating a privacy officer, testing your backups and proper disposal of patient records.