Anesthesia Coding Alert

Check the OIG work plan to be on the safe side.

Despite the nation still being in the throes of the coronavirus public health emergency (PHE), the feds have restarted most of their pre- and post-payment claims review programs, including the following:

• Targeted Probe and Educate (TPE)
• Recovery Audit Contractors (RAC)
• Supplemental Medical Review Contractors

That means Medicare fee-for-service (FFS) claims reviews should be on your compliance radar again.

Know this: Though a Centers for Medicare & Medicaid Services (CMS) frequently asked questions (FAQ) points out that COVID-19 hardships will be considered, providers should expect things to be back to business as usual. Auditors will follow billing and coding guidelines while adhering to regulations, the FAQ suggests. “Comment[s] make it clear that services rendered and claims submitted during the COVID-19 public health emergency are fair game for these Medicare contractors,” warns attorney Shannon K. DeBra with Bricker & Eckler LLP in online analysis.

Providers “that were in the midst of an audit or other medical review process should be ready to reengage in those processes and be prepared for new audit activity,” counsel attorneys Meg Pekarske, Bryan Nowicki, and Emily Park with Husch Blackwell.

If you were already in a review process and haven’t already done so, now would be a good time to determine what you might be able to do better to be in compliance with program rules.

Even if you don’t think that scenario applies to your practice, review the current OIG Work Plan and your area’s last CERT report to see if any targeted areas might impact you. Taking time to refocus your organization’s compliance efforts is always time well spent.

Bottom line: Many of the recent releases from the feds have repeatedly mentioned the importance of clear and concise documentation to back up any billing or coding, compliance, fiscal, or IT changes — and challenges — your organization may have experienced during the PHE. Now is a good time to start compiling that information while continuing to jot down the pandemic’s impact on your practice and how you are adapting your compliance.

Resource: See the FAQs at www.cms.gov/files/document/provider-burden-relief-faqs.pdf.