How would you like an investment that returns $7.20 for every dollar
you invest? Our government has found just such an investment —
healthcare providers.
HHS recovered $4.1 billion in healthcare
fraud monies in 2011 to achieve their astonishing 720 percent return on
investment. And like any investor on a winning streak, the feds are
investing more — another $350 million is allocated to anti-fraud
policing under the new healthcare laws.
You may believe you are beyond reproach if you don't order a mobile
scooter for every patient or dump your patient records in the nearest landfill, but you should exercise caution in these cautionary times:
what the feds consider "fraud" is much broader than your definition.
E&M coding, for instance is a potential target; the 99213 and 99214
office follow-up codes were the top two CPT codes in terms of both
charges and unit volume in 2010. Don't let your practice be caught up in
Medicare's recovery program. It's a simple matter to examine your own
coding patterns and compare them to national utilization data collected
by Medicare. Knowing how you compare to others within your specialty is
important in assessing possible exposure to recovery efforts.
Here are a few reasons you should conduct your own internal chart audits:
Avoid being an outlier. The
following chart compares the office follow-up code utilization of four
family physicians (Drs. Lovett, Raitt, Nelson, and Jennings) to
Medicare's like data for family physicians. Medicare and its fraud
contractors have the ability to perform such meta-analyses. Drs. Lovett
(red line) and Nelson (purple line) code similarly to the national
average (dark blue line). Dr. Raitt (green line) uses a 99213 to code
nearly ninety percent of his visits, which makes him a larger target for
a chart audit. Dr. Jennings (light blue line) uses 99214 nearly 50
percent more than the national average and 99215 at almost three times
the national average. She also is a target for a chart audit.
E&M utilization. While staying under the bell curve will not make
you audit-proof, it does decrease the odds that you will be targeted.
Medicare produces a data file that contains E&M code utilization and
charges by specialty by year, with the most recent year being available here.
To
use this data file, extract the unit volume for each E&M code —
organized by code set (i.e., office follow-up, hospital admissions,
etc.) — into a spreadsheet. Sum the total, as shown below.
Next,
calculate a percentage for each code. For instance, family medicine
physicians coded a 99211 3.7 percent of the time when Medical billing Services Medicare
for an office follow-up visit in 2010.
Extract
billing utilization data from your practice management system. Follow
the same procedure to calculate the frequency for your utilization of
each code.
These
percentages can then be used to create a line charge, as shown earlier.
While coding above, below, or at the national bell curve for your
specialty does not mean you are coding accurately or not, knowing how
your personal bell curve stacks up offers a clue to the likelihood of
being targeted.
Coding and documentation audits. Regardless
of whether your personal bell curve mirrors the national average, I
urge you to have your coding and documentation audited on a regular
basis. It is critical to know whether your CPT coding, ICD-9 coding, and
documentation support one another. I subscribe to the "Noah's Ark"
school of chart audits: at least two charts for every E&M code, at least twice a year, by at least two different certified coders. For frequently used codes such as 99213 and 99214, at least five charts should be audited.
Step One: Have your staff randomly
pull the billing and chart documentation for recent patient visits for
each E&M code. If you game the system by selecting which charts
should be audited, you are only gaming yourself.
Step Two: Have a certified coder review each chart and provide a detailed report on your coding, billing, and documentation.
Step Three:
Repeat step two, but use a different coder, preferably an outside
coder. I say this not to insult certified coders but to protect you. All
coders are not created equal, and E&M coding is much more art than
science, in my opinion. Medicare will not give you the benefit of the
doubt when reviewing your documentation, so you want these audits to be
tough and instructive.
Step Four: Repeat this audit on a
semi-annual basis. If you see no substantive differences in the findings
of your two coders, you may elect to forego the second set of eyes.
Still, I recommend that a second coder review your E&M coding at
least every two years.
Summary
Remember the $7.20
return on investment the feds are getting on every dollar it invests in
healthcare fraud? Medicare estimates it is but the tip of the iceberg.
Because their definition of fraud and yours are quite different, it is
incumbent on you and your practice to take steps to minimize exposure.
Ensuring your E&M coding is in order is a prudent first — and
ongoing — step.