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11/11/2011
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Dental Fraud: The Claim Review PerspectiveThe Claim Review Perspective
Stewart R Balikov DDSNational Dental Director
Utilization Management
Aetna IncAetna, Inc.
The content of this presentation and related views and/or opinions expressed are solely those of Dr. Stewart Balikov are his own and not representative views and/or opinions of any company, group,
association, society and/or entity, implied or otherwise.
Dental Fraud: The Claims Review Perspective
Investigative
•Department of Justice•FBI•IRS•Attorney General•State Dental Boards•State Regulatory Depts
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•State Regulatory Depts•DA
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Dental Fraud: The Claim Review Perspective
Third Party Payers•Eligibility
•Non-Covered•ID Falsification
•Group status
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Dental Fraud: The Claim Review Perspective
•Services Not Rendered•Crown Build-ups•Prophylaxis vs. 4 QSRP•PRR vs. Sealants•Gingival restorations
•Drug administrations•Crown material (%Au)
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Clinical
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Dental Fraud: The Claim Review Perspective
Third Party Payers
Investigative
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Clinical
Claim Review
Dental Fraud: The Claim Review Perspective
Claim Review Tools Clinical Staff
Diagnostics•X-rays / Images•Photographs•Provider treatment records
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Historical Information•Diagnostics•Claim Experience
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Three key issues that determine it is fraud
DUI: Deception
Unlawful gain
Intent
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What is Fraud?
“Fraud" includes, but is not limited to, knowingly ki i t b d f l f d l tmaking or causing to be made any false or fraudulent
claim for payment of a health care benefit.” Obtain something of value by intentional acts of
deception, misrepresentation or concealment. Fraud is sometimes called the "hidden" crime
because we are all victims without even knowing it.
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Dental fraud is any crime where an individual receives insurance money for filing a false claim, inflating a claim or billing for services not rendered.
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What is not Fraud?
Honest mistakes by the provider
Si i h h fili l i ( Situations where the person filing a complaint (states that) “I just knows something is wrong”
Feels the bill is just to high
Has not received the check
“I only saw the Doctor for 10 minutes. How could I be
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ycharged this much?”
What is not Fraud?
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What is not Fraud?
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What is not Fraud?
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Claim System Experience“Red Flags”
Claim experience (history) Consistent billing at ‘highest’ level
Unsigned claims
Letterhead not used in narratives
Requested receipts or records are unidentified
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Claim System Experience“Red Flags”
Individual Claim Provider not in same geographical area as
member
Misspelled or misused terminology
Provider and member have same address
Erasures, strikeovers or other alterations
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Unsigned claims
Letterhead not used in narratives
Requested receipts or records are unidentified
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Areas of fraud
Claim Review Related Billing for services not performedg p Upcoding Altering And/or Falsification of:
Dates of services Diagnostics
Unbundling / (Intentional) Improper use of codes
Non Claim Review Related
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Non-Claim Review Related Misrepresenting patient identities Not disclosing existence of additional or primary
coverage Waiver of co-payments and/or deductibles
Billing for services not performed
Appears self explanatory What about billing for prep date vs. seat date for a
crown? When is the service actually performed?
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Billing for services not performed
Claim experience can provide ‘clues’ Claim history and patterns
Examples Repetitive submissions
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Billing for services not performedMultiple Dates: Same Service
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Billing for services not performedMultiple Dates: Same Service
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Billing for services not performedMultiple Dates: Same Service
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Billing for services not performedMultiple Dates: Same Service
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Billing for services not performedMultiple Dates: Same Service
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Billing for services not performedMultiple Dates: Same Service
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Billing for services not performedMultiple Dates: Same Service
Investigation Multiple patient lines
Pattern uncovered Claim submissions upsurge 2009 Plan participation change late 2008
2 -3 week intervals
E l l fil bit i h fl id
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Exam, occlusal films, bite wings, prophy, fluoride application
On site facility review
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Billing for services not performed
Claim experience can provide ‘clues’ Claim history and patterns
Examples Crowns and Crown build-ups on all submissions
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Billing for services not performedCrowns and Crown build-ups
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Billing for services not performedCrowns and Crown build-ups
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Billing for services not performedCrowns and Crown build-ups
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Billing for services not performed
Claim experience can provide ‘clues’ Submitted diagnostics can be of value
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Billing for services not performed
Claim experience can provide ‘clues’ Submitted diagnostics can be of value
Submitted diagnostics have limitations
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Billing for services not performed
Diagnostic limitations Example: Gingival (gum line) restorationsExample: Gingival (gum line) restorations
(CDT code: D2330)
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Billing for services not performed
Diagnostic limitations Example: Gingival (gum line) restorations
(CDT code: D2330)
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Billing for services not performed
Diagnostic limitations Example: Dental Sealants (CDT code: D1315) vs
Composite Resins (fillings) (CDT code: D2391)
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Billing for services not performed
Sealants vs Composite fillings
Dental Sealants (CDT code: D1315)
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Composite fillings (CDT code: D2391)
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Billing for services not performed
Diagnostic limitations Example: Dental Sealants (CDT code: D1315) vs
Composite Resins (fillings) (CDT code: D2391)
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Upcoding
Coding a procedure as having a more extensive degree of difficulty
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Upcoding
Coding a procedure as having a more extensive degree of difficultyg y
D7111 extraction, coronal remnants – deciduous tooth: Removal of soft tissue-retained coronal remnants
D7140 extraction, erupted tooth or exposed root (elevation and/or forceps removal): Includes routine removal of tooth structure, minor smoothing of socket bone and closure, as necessary.
D7210 surgical removal of erupted tooth requiring elevation of mucoperiosteal flap and removal of bone and/or section of tooth:
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Includes cutting of gingiva and bone, removal of tooth structure, minor smoothing of socket bone and closure.*
* CDT 2011 2012 American Dental Association ©2010 American Dental Association
Upcoding
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Upcoding
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Upcoding
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Upcoding
E F
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Upcoding
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Upcoding
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Upcoding
L K
H I
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Upcoding
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Upcoding
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Abuse
BBA B
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Abuse
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Altering dates of services
Submitting a claim for treatment using a date Submitting a claim for treatment using a date other than the actual date of service to secure payment is considered a fraudulent act. Correct dates are relevant to patient eligibility
requirements and waiting periods
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requirements and waiting periods.
Altering dates of services
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Altering dates of services
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Altering dates of services
Framework Final restoration
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Altering dates of services
Submitting a claim for treatment using a date other than the actual date of service to secure payment is considered a fraudulent act. Supporting documentation can be suspect
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pp g p Narratives
Altering dates of services
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Altering dates of services
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Alteration / Falsification of diagnostics
Submitting diagnostics in support of Submitting diagnostics in support of treatment using data other than the actual data relevant to that of the actual service to secure payment is considered a fraudulent act.
A t d t d t i l t t
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Accurate and correct data is relevant to appropriate adjudication of the submission.
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Alteration / Falsification of diagnostics
Periodontal charting
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Alteration / Falsification of diagnostics
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Alteration / Falsification of diagnostics
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Alteration / Falsification of diagnostics
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Alteration / Falsification of diagnostics
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Alteration / Falsification of diagnostics
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Alteration / Falsification of diagnostics
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Alteration / Falsification of diagnostics
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Unbundling / Improper use of codes
T l d t d ib i To use several codes to describe a service where one code is sufficient is considered a fraudulent act. Need to verify if ‘reporting’ or unbundling Example: billing for the administration of local
th ti (CDT 2010/2011 D9215) h
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anesthetic (CDT 2010/2011 D9215) when a crown procedure is performed
Unbundling / Improper use of codes
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Unbundling / Improper use of codes
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Unbundling / Improper use of codes
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Unbundling / Improper use of codes
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Unbundling / Improper use of codes
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Unbundling / Improper use of codes
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Unbundling / Improper use of codes
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Unbundling / Improper use of codes
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Unbundling / Improper use of codes
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Unbundling / Improper use of codes
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Unbundling / Improper use of codes
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Unbundling / Improper use of codes
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Unbundling / Improper use of codes
$2306.00 ‘Prophy’
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Unbundling / Improper use of codes
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Unbundling / Improper use of codes
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Unbundling / Improper use of codes
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Unbundling / Improper use of codes
Abuse Over treatment Over treatment
Over-use
Financial
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Unbundling / Improper use of codes
Abuse
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Unbundling / Improper use of codes
Abuse
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Unbundling / Improper use of codes
Abuse
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Unbundling / Improper use of codes
Abuse
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Unbundling / Improper use of codes
Medical / Dental
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Questionable diagnostics
Medical / Dental
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Questionable diagnostics
Medical / Dental
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Alteration of Records
Medical / Dental
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Alteration of Records
Medical / Dental
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Alteration of Records
Medical / Dental
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Alteration of Records
Medical / Dental
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Alteration of Records
Medical / Dental
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Unbundling / Improper use of codes
Fragmenting Fragmenting is a practice similar to unbundling.
The procedures and/or services are not necessarily performed on the same day and are may still be considered to be in the global period.
Separate claims are submitted for each procedure th t k th j d diff t
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that makes up the major procedure on different dates of service.
Non-Claim Review Related Areas of Fraud
Non-Claim Review Related Misrepresenting patient identities
Not disclosing existence of additional or primary coverage
Waiver of co payments and/or deductibles
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Waiver of co-payments and/or deductibles
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Misrepresenting patient identities
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Misrepresenting patient identities
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Misrepresenting patient identities
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Misrepresenting patient identities
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Misrepresenting patient identities
Performing treatment on patient and submitting a claim for that person as someone else is fraud.
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Not disclosing existence of additional or primary coverage
Deliberate submission to different carriers Deliberate submission to different carriers without disclosure of additional or identification of primary or secondary coverage status to obtain benefits as if each were the primary carrier, is a fraudulent act
Covered patients may receive benefits from
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Covered patients may receive benefits from more than one dental plan provided each plan knows about the other.
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Waiver of Co-payments and/or Deductibles
Waiving of co-payments may encourage more usage Waiving of co payments may encourage more usage of the coverage than would normally occur
Waiving of deductibles may encourage more usage of the coverage than would normally occur Co-payments and deductibles are considered to be an
essential element of the contract the cost structure
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Skews the cost structure of the contract between the purchaser and the Third Party Payer Co-payment and Deductibles, by contract, are to be collected
Time for a few questions before closing. . .
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Dental Fraud: The Claim Review Perspective
Summary Opportunities for fraudulent activity in the Dental
industry exist
Detection of fraudulent or suspicious activity through the claim review perspective can aid in a through investigation
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Dental Fraud: The Claims Review Perspective
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The End
