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RAC Court Ruling Deals Blow to CMS

A US Court of Appeals ruling earlier this month that invalidates a provision of Medicare’s 2014 Recovery Audit Program contracts is the latest setback for federal officials who administer the program. Best Medical Coding Course!

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Auditing Modifiers

It is not enough to merely audit the codes billed by the provider of healthcare services.

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RAC audits: Can an EHR system help you avoid a visit?

We’ve all probably heard about how an electronic health record (EHR) system can streamline your practice. What about audits? Can EHRs really help you mitigate risk from recovery audit contractors (RACs)?

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Just the RAC Facts: Controversial Program Roots Out Fraud, Waste in Medicare

Here are the facts: Medicare is one of the largest insurance programs in the United States, and every year it helps insure more than 49 million seniors and other beneficiaries. And, for a variety of reasons, its prognosis is anything but certain; estimates indicate that Medicare will be bankrupt by 2026.

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OIG Seeks Improvements To RAC Program, Enhanced CMS Efforts To Stop Improper Medicare Payments

The OIG has called on CMS to strengthen activities to prevent improper Medicare payments, including enhancements to the Recovery Audit Contractor (RAC) program.

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AHA Survey: Medicare RAC Audits Up 47% Since Last Year

The number of Recovery Audit Contraction (RAC) requests for medical claims reviews has increased “dramatically” since 2012, according to the American Hospital Association’s (AHA) newest RACTrac survey.

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History of Present Illness Must Be Taken by MD, NPP

Don’t let nurses do the doctor’s work, or risk downcoded E/Ms upon audit.

The only parts of the E/M visit that an RN can document independently are the Review of Systems (ROS), Past, Family, and Social History (PFSH) and Vital Signs, according to a June 4, 2010 Frequently Asked Questions (FAQ) answer from Palmetto GBA, Part B carrier for Ohio. The physician or mid-level provider must review those three areas and write a statement that the documentation is correct or add to it.

Only the physician or non-physician practitioner who conducts the E/M service can perform the History of Present Illness (HPI),  Palmetto says.

Exception: In some cases, an office or Emergency Department triage nurse can document “pertinent information” regarding the Chief Complaint or HPI, Palmetto says. But you should treat those notes as “preliminary information.” The doctor providing the E/M service must “document that he or she explored the HPI in more detail,” Palmetto explains.

Other payers have expanded on Palmetto’s announcement, letting physicians know that they cannot simply initial the nurse’s documentation. For example, Noridian Medicare publishes a policy that states, “Reviewing information obtained by ancillary staff and writing a declarative sentence does not suffice for the history of present illness (HPI). An example of unacceptable HPI documentation would be ‘I have reviewed the HPI and agree with above.’”

Good news: Thanks to this clarification, your doctor won’t have to repeat the triage nurse’s work. Right now, if the nurse writes “knee pain x 4 days,” at the top of the note, some auditors might insist that your doctor needs to write “knee pain x 4 days” in his/her own handwriting underneath. But that requirement is a thing of the past if your carrier echoes Palmetto’s requirement.

Bad news: Now this carrier has made it…

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Recovery Audit Contractors: Know These RAC Fast Facts

RACs are just another tool in the government’s arsenal to collect improper payments.

You’ve got so many compliance acronyms flying at you every day that you may not be able to differentiate your RAC from the OIG. Know these quick facts about RACs to stay better informed.

  • Recovery audit contractors (RACs) detect and correct past improper payments so CMS and the MACs can prevent such problems in the future
  • RACs are hired as contractors by the government, and they can can collect “contingency fees,” which means that they get a percentage of the amount that they recover from providers who were paid inappropriately The maximum RAC lookback period is three years, and they cannot review claims paid prior to Oct. 1, 2007
  • Between 2005 and 2008, RACs involved in the original demonstration project recovered over $1.03 billion in Medicare improper payments, but referred only two cases of potential fraud to CMS, according to a February OIG report on the topic, which noted that “because RACs do not receive their contingency fees for cases they refer that are determined to be fraud, there may be a disincentive for RACs to refer potential cases of fraud.”
  • Unlike RACs, the OIG is a government entity. Although the OIG also performs reviews and audits and seeks improper payments, the OIG does not collect contingency fees.

For more on the RAC program, visit www.cms.gov/rac.

Part B Insider. Editor: Torrey Kim, CPC

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Auditors Review Your Notes Based on the Regs as of the Service Date

auditorIf you performed a consult in 2006, the auditor will use 2006 guidelines — not today’s rules.

Most Part B practices have grown accustomed to tucking consult regulations into the backs of their minds, since Medicare no longer pays for…

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EM CODING: Don’t Bill High-Level E&M Codes Until You Read This

Sicker patients may not always mean higher MDM.

If your physician bills a lot of high-level office visits, he may be at risk of an audit — which may not be cause for concern — if his documentation justifies his…

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Global Billing: Document ‘Unrelated’ for Modifier 79 Services

MACs are looking for ‘red flags’ to halt additional global period pay
Billing for additional services during a global surgery period is always tricky, but now you can expect special scrutiny for modifier 79 claims.
After the OIG got wind of fraudulent surgery billing with modifier 79 (Unrelated procedure or service by the same physician during the postoperative period), CMS contractors have been on the hunt […]

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  1. These 8 Services Are Not Part Of The Global Surgical PackageIf you’re not reporting these services separately, you’re losing money….
  2. Modifier Cheat Sheet: Banish Your E/M Modifier Phobias ForeverOnce you have this tool, you’ll never again wonder which…
  3. Bone Up On ASC Orthopedic Coding With These Global Period, Modifier Tips 3 ways your physician claim better look different than…
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Double Ultrasound Codes Spell Double Trouble With Auditors

Authorities scrutinize medical necessity for 76830 & 76856.
The OIG is watching your ultrasound orders and code combinations — and it doesn’t like what it sees. Take note of these problem spots to keep your claims in the clear.
An OIG audit of ultrasound services billed in 2007 found that nearly one in five ultrasound claims “had characteristics that raise […]

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  1. OB or Not OB: That’s the Ultrasound Coding QuestionQuestion: For an ultrasound, the radiologist documented measurements of the uterus,…
  2. New From CPT Assistant: Help with Trunk Ultrasound Coding Do you know exactly what’s in the mediastinum? Your US…
  3. OIG Auditors to Cardiologist: You’re Billing Medicare ProperlyReport reveals what he and his billing staff did right….
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OIG Auditors to Cardiologist: You’re Billing Medicare Properly

Report reveals what he and his billing staff did right. Does your practice have the right stuff?
Turns out the old saying is true: If you haven’t done anything wrong, an OIG audit is nothing to worry about.
A New York cardiologist who collected over $1.3 million over a three-year period for 5,061 claims caught the OIG’s […]

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  1. Double Ultrasound Codes Spell Double Trouble With AuditorsAuthorities scrutinize medical necessity for 76830 & 76856. The OIG…
  2. Medicare Fraud Fighter Reveals 9 Billing Patterns That Draw HEATA Department of Justice senior trial attorney behind the widely…
  3. HHS Plans to Crack Down on Fraud, Improper BillingMedicare loses $60 billion a year in improper payments. A…
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Service Doesn’t Meet Incident-To Rules? Report Under NPP’s NPI

Heads up: These vaccine admin codes are excluded from incident-to requirements.
Incident-to rules don’t always apply to diagnostic services, but many medical practices aren’t aware of that.
And based on a new wave of scrutiny directed toward incident-to claims, you should know physician supervision rules inside and out.
A recent audit from the HHS Office of the Inspector […]

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  1. Nonphysician Providers and Incident-To: Your Coding Questions AnsweredHere’s why you should keep your physicians’ work schedules on…
  2. Use This Incident-To Checklist to Breathe Easy During an Audit You don’t need to second-guess the way you bill…
  3. 5 Rules Pinpoint Date of Service for Laboratory ClaimsTip 3: Here’s DOS advice for archived samples. You can’t…
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A Physician Coder’s Guide to the 2010 OIG Work Plan

If your practice does lab panels, sleep studies, hospice visits and more, take heed.
The HHS Office of Inspector General has published its 2010 Work Plan, which should give us all a heads up on what the watchdog agency will be auditing and evaluating this year.
Why you should care: The 115-page document is like a map […]

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  1. Proposed 2010 Physician Fee Schedule: A Closer Look21.5 percent cut looms for your services Last week, Coding…
  2. New PQRI, E-Prescribe Tool from CMS If your head is spinning with all of the…
  3. How Obama’s Medicare Cuts Hit Physician Reimbursement  The budget released Thursday suggests we cut $300 billion from…
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