Don’t Land in Hot Water-Audit Proof your Coding and Documentation
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SuperCoder’s “Don’t Land in Hot Water: Audit Proof Your Coding and Documentation” webinar focuses on how to correctly interpret CMS medical record documentation guidelines and what to expect from an RAC audit. The webinar, which is presented by The Coding Institute expert Nikki Taylor, MBA, COC, CPC, CPMA Auditor, has been designed to help you implement certain practices that could make your coding and documentation processes audit proof. The webinar delves into understanding government audits and their areas of inquiry, dealing with CMS medical record documentation guidelines, how to handle an RAC audit, how to leverage self-audits and external audits to improve your documentation process, find out areas where you are lacking and how to correct insufficient provider documentation, tips to avoid civil monetary penalties, and more. You will also learn how to use SuperCoder tools like E/M audit tool and medicare audit tool, to make your practice more secure and safeguard your revenue against penalties.
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Don’t Land in Hot Water-Audit Proof your Coding and Documentation
- 1. Don’t Land in Hot Water Audit Proof your Coding and Documentation Presented by: Nikki Taylor, MBA, COC,CPC, CPMA Auditor-The Coding Institute
- 2. Learning Objectives • Government Audits • How they work • Areas of Concern • How self-audits and external audits can: • Identify areas for improvements in documentation • Point out corrections that need to be made • Review diagnosis coding to ensure specificity and accuracy • Crack-down on insufficient provider documentation • Avoid undercoding, overcoding, and bad coding habits • Identify great resources and tools • EM Auditor • CCI Edits Checker • TCI Consulting & Revenue Cycle Solutions 2
- 3. Why Audits are Important • Good Practice • Audits ensure regular check-ups • Boost up compliance • Reel in reimbursement • Increased payer scrutiny=increased risk • Includes: • Internal/In-house • External/Third Party 3
- 4. Why Audits are Important, cont. • Audits help: • Ensure proper billing and coding • Correct reimbursement • New reimbursement opportunities • Fight back against government audits • Payer medical record requests and denials • Ensure provider education • Documentation requirements • Quality patient care • Malpractice litigation 4
- 5. Documentation Issues • Not just for coding! • Documentation equally important! • Clinical staff • Providers • Enter documentation at time of service • Shortly thereafter • Timelines for compliance • Good patient care 5
- 6. Documentation Issues, cont. • Signature requirements • CMS guidelines • Legible-hand written • Signature stamps-NOT appropriate • Electronic-often require physician code or login • Signatures = provider reviewed and agree • Dates and Time • All entries • Allow medical treatment to be reconstructed at a later time • If time of service and time of entry are different -document why 6
- 7. Documentation Issues, cont. • Types: • Handwritten • Dictation • Templates • Electronic • Handwritten: • Often illegible • Dictation: • Clear and thorough • Timing-transcription • Summaries • Signatures 7
- 8. Documentation Issues, cont. • Templates: • Cloning • Information lacking key details • Not thorough • Electronic • Cloning • Built-in templates • Over documenting/medical necessity 8
- 9. RAC Audits •Recovery Audit Program (RAC) • Mission: • Identify and correct improper payments • Overpayment detection and collection • Identifying underpayments • Prevent future improper payments 9 https://www.cms.gov
- 10. RAC Audits, cont. • National Recovery Audit program • Demo program- utilized Recovery Auditors • Medicare overpayments and underpayments • Between 2005 and 2008 • Resulted in > $900 million being returned to the Medicare Trust Fund • Nearly $38 million in underpayments to health care providers. • Secretary of the Department of Health and Human Services • Instituted permanent and national Recovery Audit program 10 https://www.cms.gov
- 11. RAC Audits, cont. • Post-payment basis • Follows Medicare policies • Carriers, FIs and MACs: NCDs, LCDs and CMS Manuals • Two types of reviews: • Automated (no medical record needed) • Complex (medical record required) • No claims paid prior to October 1, 2007 • Can go back three years • Date of payment • Staff consists of nurses, therapists, certified coders, and a physician CMD 11 https://www.cms.gov
- 12. RAC Audits, cont. •Demand letter is issued by RAC •Opportunity for provider • Discuss the determination with the RAC • Not part of the normal appeal process •Issues reviewed by RAC - approved by CMS •Issues approved are posted to website before widespread review 12 https://www.cms.gov
- 13. RAC Audits, cont. • RAC contractors are paid a contingency fee • % of every dollar in overpayments collected • Lose the appeal-must pay fee back • Focus--organizations with billings higher than the majority • Other providers/suppliers • Medicare services only • Nearly ANY inconsistency is grounds recovery demand 13 https://www.cms.gov
- 14. RAC Audits, cont. • Top issues for 1st Quarter: • Non-covered services • Duplicate claims • Incorrectly coded services • Incorrect payment amounts • Prolonged services • Physician-referring/ordering info • Insufficient documentation 14 https://www.cms.gov
- 15. RAC Audits, cont. • Check the RAC website • www.cms.hhs.gov/RAC • Check CERT reports • www.cms.hhs.gov/cert • OIG reports • www.oig.hhs.gov/reports.html • Locate the types of improper payments found in the reviews 15 https://www.cms.gov