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Watch recorded webinar: http://go.kareo.com/twssaud Physician practices can and must decrease their audit risk from both government and private payers. How can they do that? Stop, look and listen. This one-hour webinar will present five preventive strategies that will decrease coding risk in your medical practice. At the end of the session, you will be able to: • List three sources of coding risk in your own practice • Describe the OIG Work Plan, it’s importance, and where to find it • Implement two key strategies to decrease coding risk
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Webinar Q&A As a follow up to our recent webinar, Five Critical Activities to Prevent a Government Audit, Betsy Nicoletti and Kareo have answered the many questions posed by participants.
Q: Will you provide the slides from this presentation? A: Yes, you should have received an email with the link to the recorded webinar and slides. If not, here are the links to the recording and slides. Q: Is there a way that I can get CEU credit? A: To apply for PAHCOM CEUs you have to register and attend the event with your name and email address. To request the CEUs, please email [email protected]. Q: As a billing service, are we liable if one of our clients gets audited? Should we be keeping track of their coding activity? A: It is the provider who does the coding and it is the practice that is responsible for ensuring that their coding is accurate. If the practice is audited for coding practices, they are liable not the billing service they use. This is a question to address to your lawyer. Q: You provided some norms for family practice. Could you provide a similar example for a specialist? A: These are available for purchase from DecisionHealth in the E/M Bell Curve Book 2013. Q. We have a coder who audits our charts for us. She looks at HPII, PH, FH, and SR. If those are ok, she goes on and often skips checking physical exam and assessment and code as level 5. Is this ok? A: This is not a procedure I would recommend. For more details on my recommendation, revisit the slides or recording. Q: Are there private audit companies and how can we find one that is right for us? A: Yes, there are thousands of private companies that can do an audit for you. I suggest starting with your specialty organization to see if they have recommendations. Q: Is there an app or online version of the CPT book? A: There is an online option for the CPT code book. And there are many apps. If you do a search for CPT apps you’ll find options for android and apple. The AMA offers bound books, eBooks and apps for CPT at www.ama-assn.org. Q: Does the OIG have geographical areas that are more likely to be audited? A: Not really. Larger metropolitan areas are more likely to have cases of large scale fraud so there are some things that are monitored or looked for related to that. But a medical practice in New York isn’t any more likely to be audited than a practice in small town in the Midwest.
Q: If we do an internal review and we find a mistake, how do we notify Medicare without raising a red flag that triggers an audit? A: If there are just a few claims, correct the claim. If there are multiple problems or systemic issues, contact a healthcare attorney.
5 Critical Activities to Prevent a Government Audit
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Q: Are we supposed to have a notebook or file in our office documenting our compliance policies? And if yes, what specifically should be documented in it, besides our HIPPA policies? A: You should have a compliance plan. You may be able to find a sample online, or purchase a template for one. Otherwise, you will have to contact a health care attorney or consulting firm to develop one for you.
Q: I have been documenting in paper charts but am now transitioning to an EHR. Am I vulnerable to an audit only for my electronic charting going forward or would an audit go back through my paper charts? A: The method of documentation does not affect an audit period. Q: Can we use CPT code 99051 even though our regular office hours run up to 6 or 7pm? A: The CPT code does not define the time of the office hours. This CPT code is not typically reimbursed.
Q: Does E/M coding differ for Medicare, Medicaid, and commercial payers? A: No it doesn’t. The CPT codes are set by the AMA and they are the same regardless of payer.
Q: Can you please explain using code 99215 for our primary care office? A: Look at the definition of the code in the CPT book. There isn’t anything I can add to that information.
Q: Is there somewhere we can go to look up which diagnostic codes can go with which procedure codes? We have had claims rejected by payers because the diagnostic code can’t be used with the procedure code. A: Look at the national and local coverage determinations, and the Medicare coverage manual. Google those words to locate.
Q: You discussed avoiding duplicate claims. I sometimes rebill a claim because I put the wrong code in. Is this going to trigger an audit? A: I have never seen it do so.
Q: My physician sees a lot of patients with chronic and complicated conditions so most of his coding is at the highest levels. Should I lower the levels to prevent an audit? A: The goal is to be complete and accurate in your coding and to be able to justify your coding in the event of an audit. If the documentation, diagnosis, etc. supports higher levels of coding, then code for the services you are providing. I would not recommend changing your coding to prevent an audit if the changes are not reflecting the documentation. But, there are many patients with chronic illnesses and not all physicians use the highest level of codes.
Q: My physician rents his office space from a hospital. Should his POS be 11 or 22? A: It depends on the arrangement. Your healthcare attorney should review this.
Q: We are a psychotherapy practice so we generally use the same codes over and over again? Does this increase our risk of audit? A: No. Q: I work at a urology practice where we do cystoscopy? We use 99213 with modifier 25 and procedure code 52000. Is this right? A: It depends on what was performed. For a scheduled procedure, bill only for the scheduled procedure. Q: If I see a patient and do an injection the same day, and I place 25 to EM code, does this put me at risk? I do this very often. A: No. Q: Can EKGs be done by non-professionals? A: It depends on your state laws and scope of practice. If you need more assistance, consider speaking with a healthcare attorney or consultant who can help you dig into this more.
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Q: I do billing for a physical therapy practice. Am I liable if they are making mistakes? A: It isn’t the individual who is liable in the event of an audit, it is the business. So, if you believe that a physician is not coding accurately, I recommend using the five strategies I outlined in the presentation and doing an internal review. If you identify issues then you can work to resolve them before it becomes a problem for the practice. You aren’t going to personally be liable, but I am sure you don’t want an audit any more than anyone else in the practice does.
Q: We are a physical therapy practice and the history of present condition, mechanism of injury stays the same from visit to visit when treating for a diagnosis. We copy that information from one visit to the next as we treat the patient. Are we at risk of audit or is this ok for the ongoing treatment provider at rehabilitation practices? A: The HPI should reflect the patient’s symptoms since the last visit. I am not able to assess your risk of audit. Q: We are an allergist office and we do use modifier 25 and 59 often. Do we need to reduce our use of these modifiers? If so, how do we still get paid for the services we are providing? A: Use these services when the criteria for using them is met. Q: How do you run the E/M Productivity report in Kareo? A: To run an E/M Productivity report in Kareo, go to the Productivity and Analysis section of the Reports menu. The Provider Productivity report provides summary totals for all procedures rendered by a provider, grouped by provider, and sub-grouped by location, over a period of time. For help using your Kareo Practice Management system or EHR, visit the Help Center. Small Practice & Billing Company Resources Please visit Kareo Resources at www.kareo.com/resources for helpful tools, webinars, whitepapers, and tips for how to help small practices become best practices. You can also view recorded webinars or register for our next event at www.kareo.com/resources. About Kareo Kareo is committed to providing education and insights to small medical practices. We work with in-the-trenches influencers, consultants, and Kareo customers to provide relevant tips on how to successfully manage medical practices and medical billing services. Find out more at www.kareo.com.
