National Fraud Enforcement Division
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Unless you have been ignoring the news this past year, the fact that CMS and the Federal government have gotten very serious about cracking down on fraud is no surprise…
Recently the Department of Justice has formally organized a National Enforcement Division. The goal of this new entity is to strengthen the enforcement of fraud and abuse investigations of all taxpayer-funded programs. The hope is to ensure that these data driven investigations will have stronger interagency coordination between those agencies already conducting fraud and abuse investigations.
No mater your involvement in medical billing, whether a frequent DME provider of orthosis (AFO), wound care, shoes, etc. one should have one question- How can I be sure that my documentation meets the LCD and medical necessity requirements for what I am billing?
The answer is quite simple. Stay up to date on all LCD requirements, for all services you are providing. Routinely review and strengthen your note templates to ensure they comply with third party payer regulations. Stay up to date on patient chart documentation and whatever you do NEVER change a chart note once it is completed. Addendums to specific notes are acceptable so long as they are contemporaneous to the DOS. Addendums written and completed after the initiation of an audit will likely be seen as an attempt to defraud a payer. it is. And that’s not good!
Pre-payment review (TPE) is a tool primarily used to point out weak spots in your documentation. Failure to improve TPE scores, can result in mandatory pre-payment review or referrals to other types of audits, including CERT and RAC post payment recoupments.
Conclusion: The new National Enforcement Division promises to strengthen the long arm of the law.
What you can do: If you have a question and are unsure how to document certain DME or other medical services, or you have questions about whether your existing documentation for the medical/surgical services or DME you provide meets the LCD medical necessity requirements, ask an expert. Kevin Root is happy to provide a referral for both Foot and Ankle Foot Orthotics as well as for Prosthetic devices (e.g. L5000) which we manufacture. Also you can subscribe to http://www.codinghelpline.com an online forum where you can post questions and receive responses from one of several experts.
Keeping your practice financially sound can be accomplished by being proactive.
By staying up to date on the LCD requirements and documentation for all the services you provide, you can successfully defend any audit that comes your way!
