"How to minimize post-payment audit risk and what to do if audited?"
“… the payer's motive is money, the means is a gargantuan statistical database, and every provider is an opportunity...”—Jeffrey Randolph, Esq.
ANJC Legal Counsel
The top two revenue-boosting wells for payers, i.e., recruiting new members and raising premiums, are drying up. Premiums increased disproportionately beyond inflation and workers' earnings growth in 2001-2006 (health insurance premiums – 65.8%, inflation – 16.4%, workers' earnings - 18.2%).
Premium wars preclude insurers from further raising rates, and recently enacted timely payment laws limit how long they can withhold repayment to earn interest as they had in the past.
To meet profit expectations and still play within the new rules, insurers must go after the reimbursements that were already paid.
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The "Business" of Healthcare Provider Audits
How Payers Are Getting Away with Practice Murder
Table 1. Fraud Statistics – Health and Human Services
Civil Division, U.S. Department of Justice |
| |
| Year |
New matters |
Judgments |
Average Judgement |
|
|
| 1993 |
61 |
$155,323,165 |
$2,546,281 |
|
|
1997
|
347
|
$920,350,127
|
$2,652,306
|
|
|
2000
|
260
|
$912,388,758
|
$3,509,188
|
|
|
2003
|
243
|
$1,825,406,640
|
$7,511,962
|
|
|
The Justice Department recovered a record $3.1 billion in fraud and false claims in 2006. It is an undeniably unscrupulous game (Table 1).
If your skepticism has led you to the “rational” rebuttal that audits are expensive for everyone, rest assured that the invisible hand (gloved in technology) has helped insurers overcome this traditional obstacle. With the advent of electronic submission, building claims databases became almost costless. As with many purportedly win-win propositions we have seen from insurers, electronic submission has proven to be a wolf in sheep's clothing. As providers submit claims to be paid, insurers simply add each claim to their growing database, and their computer science geeks regularly crank out reports that give executives a bird's eye view of all their providers
Invariably, providers are in denial about their exposure, and insurers are quick to comfort them. They will tell you that audits are an unfortunate but necessary tactic for keeping fraud in check, implying that honest providers have nothing to worry about. But insurers are not crusaders for truth and justice. Providers need to understand that the payer's motive is money, the payer's means is a gargantuan statistical database, and every provider is an opportunity. The system automatically pinpoints providers that are “easy audit targets:” for one of the following reasons (Table 2):
- They are doing something differently from the pack,
- They are lacking infrastructure for systematic denial follow-up,
- They are lacking compliant medical notes.
|
Table 2. Audit Triggers –
Profiling Methodology | | | | Stage | Report | | |
| Prepayment Review | CCI and LMRP rules
Inter-claim, intra-claim, cross-claim
Lifetime duplicates
Date range duplicates
Re-bundling
Modifier codes
E&M crosswalk
Visit level
| | | | Post-Payment Audit | Procedure repetition
High payments per day
Surge analysis
Unusual modifiers
Unusual procedure rates
Geographic improbabilities
5/50 patterns
| | | | External Resources | Providers watch lists
OIG sanctions databases
High-risk address databases
|
| The risks of noncompliance have changed too from money return to exclusion from government programs and loss of practice license. Administrators can be barred from working in the healthcare industry and clinicians, managers, corporate directors, even outside consultants can be jailed for healthcare fraud and abuse.
The federal government strongly encourages health compliance programs and promotes voluntary compliance and self-policing in a variety of ways. The existence of a compliance program may determine whether the matter can be routinely handled as an overpayment by the payer or it must be investigated by the OIG, or even referred to the Department of Justice to be pursued as a civil infraction or as a criminal matter.
|
| |
Now you can reduce audit risk and avoid audit threat by preparing for an audit:- Integrate disciplined visit documentation procedures using SOAP notes.
- Monitor audit trigger red flags in real time.
- Track claims that might offend national or local frequencies for specific CPT codes.
Contact Billing Precision for a demo today to discover how you can protect your practice.
Billing Precision works hard to increase your collections, reduce audit risk, improve your productivity, and focus on building your practice using powerful methodology and a single, completely integrated system. Our approach is timed to meet your objectives and to adapt to your evolving priorities. The bottom line is that your audit exposure shrinks as a result of rigorous teamwork between your office and our team. Explore our methodology to discover how hundreds of office managers and doctors just like you have been delighted.
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- T. Foster Bryant, DC, Jubilee Family Chiropractic, Naples, Florida |
"Billing Precision goes beyond making sure we are paid in full and on time - their leading edge chiropractic billing software has turned my entire office into a completely paperless and compliant operation, so I can focus on my patient health and practice growth."
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"No insurance offers protection against audit risk, which carries enormous potential penalties. Billing Precision's unique chiropractic
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- Robert White, DC, True Health Chiropractic, Springfield, New Jersey |
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Billing Precision's founders hold advanced degrees in chiropractic, computer engineering, and mathematics, and were awarded several patents in artificial intelligence and information security. Our core team has a deep understanding of the needs of chiropractors and the challenges we all face in the current healthcare environment. To achieve maximal effectiveness of Billing Precision's compliance program, our system developers teamed up with Jeffrey Randolph, Esq., the ANJC Legal Counsel. To hear Dr. Sigmund Miller, Executive Director of ANJC, interview Jeff Randolph, click here. For more information, join Interactive Online Audit Risk Seminar.
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Our billing system uses centralized technology serving hundreds of
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Contact Billing Precision for a demo to discover how you can protect your practice.
The federal Department of Justice, the
Office of Inspector General (OIG) at the Department of
Health and Human Service, state Medicaid fraud control
units, and other enforcement agencies have brought multiple
enforcement actions against various healthcare practices
- even small practices - over the course of the past twenty
years
The institutional risks of noncompliance have grown since
1995 from relatively non-adversarial audits and occasional
return of payments to formal investigations, prosecution
under the False Claims Act, and whistleblower action.
The personal risks of noncompliance have changed too from
money return to exclusion from government programs and
loss of practice license. Administrators can be barred
from working in the healthcare industry and clinicians,
managers, corporate directors, even outside consultants
can be jailed for healthcare fraud and abuse.
The federal government strongly encourages health compliance
programs and promotes voluntary compliance and self-policing
in a variety of ways. For instance, in the case of Medicare
and the OIG, the existence of a corporate compliance program
influences the approach to a violation of a federal requirement
in terms of an innocent mistake or a fraudulent act. The
existence of a corporate compliance program may determine
whether the matter can be routinely handled as an overpayment
by the payer or it must be investigated by the OIG, or
even referred to the Department of Justice to be pursued
as a civil infraction or as a criminal matter. |