kareo - five critical activities to prevent a government audit for small practices

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5 Critical Activities to Prevent a Government Audit

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5 Critical Activities to Prevent a Government Audit

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Your Hosts Today…

Betsy NicolettiMS, CPC

Lea ChathamContent Marketing Manager, Kareo


How to Participate Today…



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Our Schedule for Today…

1 Introduction & Welcome Betsy

2 5 Critical Activities to Prevent a Government Audit

3 Discover Kareo’s Role

4 Answer Questions


Betsy Nicoletti, MS, CPC

Speaker, writer, and consultant in coding education, billing, and accounts receivable

Author of The Field Guide to Physician Coding

Founder of Codapedia.com

Developer of The Accurate Coding System

MS in organization and management

20 years experience in medical billing

Member of MGMA & HFMA

Betsy Nicoletti, MS, CPCwww.betsynicoletti.com

[email protected]

@BetsyNicoletti






4 Answer Questions


Agenda

• At the end of the session, participants will:1. List three areas of coding risk2. Describe the OIG Work Plan and where to find it3. Implement two key strategies to decrease coding risk

©2013 Betsy Nicoletti


Five activities

1. Be a copy cat2. Compare and contrast3. Audit high risk activities4. Don’t be a “WNL” victim (We never looked)5. Ignorance is never bliss: educate, educate,

educate



Be a copy cat!



If the government is interested, so are we

• Office of Inspector General publishes a Work Plan every year

• Recovery Audit Contractors post areas of interest

• No surprises!



OIG Work Plan for 2013

Published at: https://oig.hhs.gov/reports-and-publications/archives/workplan/2013/Work-Plan-2013.pdf



• Gives physicians fair warning of OIG areas of interest

• Assesses not just provider accuracy and coding, but the accuracy of the Medicare contractors in paying claims— Reports issued as a result, with recommendations for

us and CMS



• Released every year in October• Describes areas of interest for the OIG to review

— Some continuations, some new starts— Brief, some might say obscure descriptions of areas

of interest



For 2013

• List of 33 items on the OIG Work Plan related to Part B services

• Some are new starts, some continuations from previous years



Something for everyone on the Work Plan

• Topics related to enrollment and assignment of benefits

• High volume of services, cloned E/M notes, use of modifiers in global period

• Specialty services: ESRD, chiropractic, sleep, organ procurement,



Something for everyone on the Work Plan

• Place of service errors• Incident to services, Nonphysicians• Lab tests, including HgbA1c• Imaging, EMGs, partial hospitalizations,

anesthesia, ophthalmology



Your mission critical task

• Review the Work Plan• List services you provide that are on the Work

Plan• Review coding requirements for each one you

do• Audit each



Mission critical activities

• Review OIG WP each year

• Audit areas of interest• Educate



What about the RACs?

• Four RACs: search for the RAC for your region at: http://www.cms.gov/Research-Statistics-Data-and-Systems/Monitoring-Programs/recovery-audit-program/index.html?redirect=/rac/



RACs required to post issues

• One, Diversified, has 630 issues listed• Connolly also has many hundreds listed

—Can sort this list by type of service—Look at areas of interest in your region—to

numerous to mention….



RACs: some professional areas

• E/M services in global period• Minor surgery and modifier 25• Pulmonary diagnostic procedures and E/Ms• Duplicate claims• Add on codes without primary code• Not a new patient• Place of service• E/M with allergy services



RACs some procedures

• Barium swallow studies• Cardiac Caths• Chemo administration• Injection and infusion

codes• Units of medication



CMS warnings in Rules

• From CMS in Baltimore or your local contractor• Sign up for email lists • Be a copycat: if the government is worrying

about it, worry about it.• OIG reports a source of information



Results from OIG WP: reports

• Level of E/M services—Found level of service increased in past 10 years, all

categories of codes, all specialties—Identified 1700 clinicians who billed two highest level in

each category more than 90% of the time

• Incident toNon qualified professionals performing professional services



What are high risk activities?

• Items on OIG Work Plan/RAC areas of interest• High volume services• High RVU services• Ancillaries• New provider billing



Go beyond E/M auditing

• E/M—except for a clinician reporting all high levels—may not be your highest risk area

• Incident to a source of huge confusion• Modifiers



• Use of modifiers— Pay particular attention to use of modifiers 25 and 59

which override payment edits— Frankcohengroup.com Some free info, some for

sale— Compare each individual with CMS norms and

practice average

• Most frequently billed codes• E/M level of service

How risky is our business?Compare your data



New Percentage Established Percentage

99201 1.35% 99211 3.91%

99202 15.82% 99212 4.34%

99203 45.07% 99213 48.03%

99204 30.63% 99214 40.10%

99205 7.12% 99215 3.61%

CMS norms for Family Practice



Normative data

• Typically not free, unfortunately• Compare within group quarterly



Compliance plan activities

• Not required to audit the same services every year

• Select high volume or high dollar value services

• Select services that are confusing to group• Be a copy cat



WNL

• Common phrase—physicians use it to mean “Within normal limits”

• Wikipedia also notes it as “we never looked”



What shall we look for?

• Copying from previous notes

• Sequential visits for patients with chronic illnesses

• Same complaint (frequency) for multiple patients



Now, don’t be a copy cat

• HPI copied from previous note

• Assessment and plan is a list of patient’s medical history, not issues addressed today



Is the note complete?

• Weekly, run a report of non signed/opened notes

• Some groups do not submit claims unless note is complete, some do

• If a clinician is chronically behind, do not submit claims— No RVUs, no revenue



Non-completed notes

• Medical liability• Compliance risk• Set a policy about when

notes must be completed• Run a report: date of

service, date completed



Ignorance is bliss? Not for coding

• OIG Compliance Plan for Small Practices includes education as a component

• On or off site• Webinars, seminars, books• Document attendance



Source citations

• AMA is the definitive source for coding (www.ama-assn.org)

• CMS, payers develop reimbursement policies (www.cms.gov)

• CMS manuals and Contractor billing guide good source of coding/reimbursement for Medicare

• Specialty societies



Start with CPT

• Editorial comments• See and see also, report and do not report• Professional edition also references CPT

Assistant



Specialty societies

• Terrific source of coding information related to your specialty

• Specialty societies have high validity with physician members

• Often allow 3-5 free coding questions/year to physician members

• Some offer in person coding seminars



Commercial vendors

• General coding and specialty specific• Look for vendors with long history and good

reputation• Consultants are not source citations but often

have access to source citations to support their points



Resources

• Critical to budget for newsletters, books, seminars

• Document attendance in compliance files• Physicians often more receptive in smaller

increments



Predict and protect

• No crystal ball needed

• Government tells us what it is worried about

• Protect your practice with a robust compliance plan





2 5 Critical Activities to Avoid a Government Audit


4 Answer Questions


Discover Kareo’s Role

“…Make Your Practice a Best Practice!”



• PAHCOM has approved 1 CEU credit.

• Each attendee will receive an email today with a link to request certification. Certificates will be mailed within the next few days.

• Attendees must be logged into the webinar to receive credit.

• Questions - email [email protected]

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1 Introduction & Welcome Elizabeth



4 Answer Questions


Let’s Answer Your Questions

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5 Critical Activities to Avoid a Government Audit

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kareo - five critical activities to prevent a government audit for small practices

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