Gastroenterology Coding Alert

Hint: The provider is responsible for every claim submitted to payers.

Sometimes handling the practice management tasks at a busy GI practice can be so time-consuming that it's easy to focus on correct coding and forget about compliance considerations, but medical offices must do both to avoid scrutiny from the government.

That was the word from NGS Medicare representatives during the MAC's Aug. 23 webinar, "Medicare Fraud and Abuse." Gastroenterology Coding Alert staffers listened in and gathered the five most applicable tips that can help your practice stay on the right side of the compliance rules. Read on for the scoop.

1. Always Collect Deductibles and Copays. "You've probably heard this before, but you can't routinely waive deductibles and copays," said NGS's Lori Langevin during the call. "It's unlawful because it can result in false claims, can violate the anti-kickback statute, and is considered excessive utilization of items and services paid for by Medicare."

Of course, there will always be instances when you spend hours trying to collect, and patients simply won't pay, but the NGS reps had advice for that situation as well. "What we like to say is, as long as you make a good faith effort to collect deductibles and copayments from your patients and you document your efforts in the patient's medical records, then you wouldn't really have to worry about this issue, but there are some practices that, believe it or not, routinely waive so they can get the business," Langevin said. "Those practices will say, 'Come to our office, we're not charging copays.' You can't do that as a Medicare provider. That's a violation."

In addition, if you advertise that you're offering a "free exam" to patients, you can't charge Medicare for that, nor can you bill for items and services before they were actually delivered. "You should not be billing Medicare until the services are actually performed," Langevin said.

2. Use Billing Services Wisely. You may think your billing service is just as capable as your in-house coding and billing staff, but that doesn't mean you should avoid oversight. "Pay attention to your billing services' practices, make sure they're keeping accurate, complete administrative records of the claims that they submit on your behalf," Langevin advised. "Instruct the service not to change your codes, procedures and diagnostic, as well as other information furnished by you in your office." Errors made by the billing service do not relieve the practice of responsibility.

3. Keep NPIs Private. Protect your practice by keeping provider identification numbers safe and assigning procedure codes yourself. "Remember, you asthe provider are responsible for accurate billing under your NPI," Langevin said. "However, if you delegate this responsibility, please make sure you're conducting periodic checks to ensure accuracy in the coding," she advises.

4. Keep Pristine Documentation. "You want to make sure your medical notes are legible, make sure every entry is signed and dated, and you've probably heard this before, but if a service is not documented it is not done," Langevin said.

5. Act Quickly If You Did Something Wrong. If you think you're in a problematic relationship or you've been using billing procedures that you discover are wrong, immediately follow the steps below, said NGS Medicare's Gail O'Leary during the webinar:

• Seek legal counsel
• Stop filing using the problematic methods
• Find out if you collected any money in error
• Take any necessary to free yourself from involvement and from any suspicious relationships
• Consider using self-disclosure protocols set out by CMS and the OIG

Providers have to report overpayments within 60 days after they have been identified, but accepting voluntary refunds from providers does not limit the government from taking action to pursue any remedies, O'Leary added.