A recent OIG enforcement action emphasizes the need to understand the proper use of units. A healthcare provider in Connecticut submitted multiple units for urine drug screening tests. The press release stated that "Urine drug screening tests use a single sample of a patient’s urine to test for multiple classes of drugs. Although the test screens a patient’s urine for multiple classes of drugs, Medicare considers it a single test that should be billed only once per patient encounter."
Noridian, the Jurisdiction F Medicare Administrative Contractor (MAC), recently announced that they will be extending their pilot program: Provider Self-Audit with Validation and Extrapolation (PSAVE). Whenever a program is extended, that means that it has been successful for the payer, which likely means that they are saving money. It doesn’t state precisely HOW they are saving money. Historically, when a pilot program is proven to be successful, it isn’t too long before other MACs follow. Before signing up to participate, providers need to carefully evaluate the program.
Effective March 14, 2016, the CMS Final Rule regarding the reporting of overpayments took effect. This ruling clarifies the standards that have been unclear for years since the the PPACA created what is called the "60-day rule." The problem has been the unclear standards on what it means to "identify" an overpayment and when the 60 day clock begins running.
Now, the 60-day rule requires anyone who has received an overpayment from either Medicare or Medicaid to report and return the overpayment within the latter of:
Many healthcare organizations are not aware of how critically important it is to screen their employees against ALL state and federal exclusions databases. The OIG is reviewing organizations in ALL federal healthcare programs - this includes Medicare, Medicaid, CHIP, etc. - for those who have employed individuals on ANY exclusions database. Not only must you screen employees on the OIG Exclusions database, but employers are also responsible to check state exclusions databases as well.
When documenting the history components in an Evaluation and Management service, the clinician is not required to use the headings that the Documentation Guidelines define. That is, the history section does not need to be labeled: History of the Present Illness, Review of Systems, and past medical, family and social history. The auditor may use history found in any part of the history. The ROS may be in a section labeled as ROS or it may be part of the HPI.
All refund demands from payers are not alike. Some could be justified. Recently a payer asked for a refund request from a ChiroCode subscriber. She said: “We sent the No Refund letter from ChiroCode. However, they ignored it and they still want a refund. What do I do next?”
When a payer audits you the first thing to do is respond to the audit. Do not ignore it; it won’t go away. In the initial stage of the audit, they will probably ask you to send them your notes on approximately 5-10 patients. Either have a health care attorney or yourself send exactly what they want in a timely fashion. Delaying, or not sending the notes, might lead the insurance carrier to think that you are hiding something.
Send nothing more and nothing less than what they ask for.