Internal Reviews in Anesthesiology: Head Off Audit Findings at the PassHint: Payers are on the lookout for non-covered services billing & improper modifier use
As an experience coder, “compliance” is term you’re more than familiar with. But do you fully understand how to be compliance-ready for a potential anesthesia audit from the Office of the Inspector General (OIG) or Medicare?
The OIG, Medicare, and other payers are scrutinizing anesthesia providers more and more thanks to controversy over billing for non-covered services and the improper use of anesthesia modifiers. So it’s high time to put an internal review process in place, says certified coder Kelly Dennis in her live presentation, Auditing for Anesthesia Practices for the upcoming AudioEducator 2019 Coding Updates Virtual Boot Camp. If you’re to survive this heightened scrutiny, compliance must begin at the executive level and permeate the entire organization so everyone is audit-ready 24/7.
What an Internal Review Plan Looks Like
To be always prepared for an audit, your anesthesia practice should have in place an internal review process that involves at least the following steps:
- Designated a contact person to handle both the audit and any audit-related questions; and
- Outline how and when to maintain records for the auditor.
In addition, with the government’s fraud and abuse detection efforts at a record high, it’s crucial you know what kinds of audits your practice could face—and what’s involved in each. Knowing what each audit is looking for will help you prepare for and handle your internal reviews, and keep you extra prepared for when the audit itself happens.
This is not an exhaustive list, but here’s a sampling of the audits your practice could face:
- Comprehensive Error Rate Testing (CERT): Its key purpose is to monitor fee-for-service payments.
- Contractor Medical Review Program Audits (MR Audits): The main focus is on incorrect documentation, Medicare payments, and billing issues.
- Recovery Audit Contractor (RAC) Audit: Its chief function is to uncover erroneous Medicare payments (both underpayments and overpayments).
Work as a Team: Although your practice will be grateful for your knowledge on this topic, be sure your practice has an actual internal review process in place. Presenting a united front to the auditor will make it that much easier to survive any investigation.
OIG Work Plan Issue #1: Anesthesia Modifiers
One other key element of your internal review process should be a constant monitoring of OIG’s Work Plan website for any updates concerning anesthesiology. Compliance gurus recommend checking these monthly updates often and ensuring your internal review program is nimble enough to adjust to any updates accordingly. Missteps that your team catches and resolves during the internal review process now means fewer issues that have the chance to become audit findings later.
Two anesthesia-related issues in the OIG’s 2017 work plan – and still relevant today – are: (1) anesthesia modifiers and (2) billing for non-covered services. To the first point, note that proper use of anesthesia modifiers requires that the documentation clearly state who exactly performed the services and whether there was any medical direction or guidance. For more comprehensive information on this topic, turn to this previous post.
OIG Work Plan Issue #2: Non-Covered Services
The second point of OIG interest is non-covered services. To comply with Medicare Part B, you must ensure that anesthesia services were performed according to Medicare requirements – namely, that a patient who received anesthesia also received a service requiring that anesthesia. Any non-covered services not covered and resolved in an internal review will result in an audit finding.
Internal Review Programs: A Key Step to Surviving Audits
Audits are no fun for anyone, but a little extra preparation will at least help you survive them with greater ease. As part of AudioEducator’s 2019 Coding Update Virtual Boot Camp, Dennis’s four-part webinar series will prep you to initiate an internal review as well as to adapt to any anesthesia CPT® code changes. You’ll want to familiarize yourself with the OIG’s Work Plan to keep your practice in tip-top shape.