Anesthesia Coding Alert

Your practice has received that dreaded notification: a Medicare audit letter. Whether it’s from a Medicare administrative contractor or a zone program integrity contractor, you don’t necessarily need to panic. Take the advice of our experts and let seven steps help you prepare for the process.

First Things First: Examine Yourself

Managers and physicians should start by forming “a team of staff members dedicated to handling the practice’s compliance activities,” advises Vera Watkins, a perioperative nurse and Certified Health Auditor.

Ideally, the compliance team should create formal Standards of Conduct, provide training and education on proper coding procedures and handling of PHI, form auditing and monitoring guidelines, create corrective action plans, and institute disciplinary guidelines for staff who commit fraud and abuse, Watkins recommended. Compliance teams should also conduct internal audits and disclose any issues they find. Although there is no guarantee that you’ll get amnesty for self-disclosing, the benefits of doing so far outweigh the risks.

Take the Steps

Once the notification arrives, some simple actions can help you move toward the next phase.

1. Verify the address. Although it might sound silly, the first thing to do is to confirm that the full address on the letter is correct, advises George F. Indest III, President and Managing Partner of Orlando-based The Health Law Firm.

In his Medical Economics article, “19 Tips to Prepare You for a Medicare Audit and Site Visit,” Indest warns that if you haven’t updated your physical address — or if your current address is incomplete — in the Provider, Enrollment, Chain and Ownership System (PECOS), auditors may not be able to find you, putting your Medicare billing privileges in danger of being terminated.

2. Contact the auditors and confirm exactly when and where the audit will take place. Give auditors any codes they need to access parking garages, buildings, and so on, recommends Indest.

3. Contact your attorney. Practice leadership should ask their attorney to be present during the audit and site visit, says Indest.

4. Get your office in order. After making those calls, visually inspect your office, Indest advises. Are all desks, cabinets, and closets clean? Make sure all certifications and degrees displayed in the office are up to date.

5. Designate one member of your staff to liaise between the auditors, your practice, and your attorney. This person should be present during the audit and stay with auditors as they tour your office.

6. Ask for ID. When auditors show up at your door, make sure they present their IDs and letter of intent. Make a copy of their IDs and escort them to a private room. “Don’t let them wander around your office because they’ll talk to anyone,” Watkins advises.

7. Make copies for your files. Whenever auditors ask you for a copy of a document, make two copies and keep one for yourself.

Continue the Work After the Auditors Leave

If auditors find an issue with your practice, you’ll need to develop a Corrective Action Plan.

Your practice’s compliance team should conduct a root cause analysis of the issue, develop an action plan, and engage all staff members in implementing it.

“Nothing drives behavior like data,” says Watkins. When trying to get staff to change the way they perform a process, show them data that proves why the change is necessary.

Just doing their job: Even though audits are anxiety-producing, Watkins offers practices some comfort: “You’re never going to have a 100 percent clean audit. Auditors are hired to find something wrong.”