Seven Ingredients Key:
Compliance Plan for Cardiology Practice Can Improve Reimbursement as Well as Stave-off Auditors
Published on Sun Nov 01, 1998
With the changes in coding for Evaluation and Management (E/M) services, cardiology practices are caught between a rock and a hard place: fear of overcoding and bringing down the wrath of Medicare auditors vs. undercoding, thus forfeiting countless dollars in the squeeze.
A cardiology practice may document enough information for a visit to be considered a level 4, but then they downcode because they are afraid too many high-level visits will open them up to an audit, says Stephanie Servy-Gajic, director of coding management and education at Cardiology of Georgia, a 25-member group in Atlanta.
But even if youre comfortable with the E/M guidelines, beware: physician practices are coming under increasing scrutiny from Health Care Financing Administration (HCFA) auditors looking for Medicare fraud, waste and abuse.
Cardiology practices are especially vulnerable because we have so many Medicare patients, explains Servy-Gajic, who was hired to perform in-house audits as part of her cardiology groups compliance initiative.
Due to the HCFA mandate for prepayment review audits, several of our sources say they have recently seen an increase in the number of auditor requests for medical records, as well as requests for documentation on medical necessity.
Cardiology practices can decrease their chance of an audit and perhaps even ethically increase reimbursement by implementing a compliance program, Servy-Gajic says.
Although such programs are common in larger acute care hospitals, many physicians have been reluctant to implement one in their practice.
Plan Not as Difficult As It Seems
The biggest problem is that they are intimidated by the idea of a compliance plan, particularly if they look at whats on the OIG (Office of Inspector Generals) Web site (http://www.hhs.gov/progorg/oig) as a sample plan, says Susan Stradley, CPC, CCS-P, senior consultant for Medical Group of Elliott Davis and Co., LLP, headquartered in Greenville, SC.
The sample OIG compliance plan does not illustrate what a physicians office needs to do, but rather uses a large laboratory as a model. (Neither OIG nor HCFA mandates the use of compliance plans, but they highly suggest it.)
Its a very long detailed document that doctors cant relate well to, she says. They take one look at it and say Well never be able to accomplish this.
But by sticking to seven basic principles, cardiology practices can satisfy the OIG requirements and not drown in documenting detail. Its fairly easy to give the OIG what they want, offers Stradley. Its not as frightening as you think.
However, both Stradley and Servy-Gajic caution that a compliance program should not be just another exercise in putting policy and procedure on paper.
Auditors want to see more than words, they want to see evidence of a working plan, Stradley cautions. Remember that having a compliance program is more for your benefit than [...]
