Physicians documented their subsequent hospital care poorly. Meanwhile, the CMS report indicates that Medicare paid out nearly $39 million more than it should have for subsequent hospital care code 99232 in the "no documentation" error category. "It's possible that doctors in the hospital tend to peek in on the patient and don't write a lot in the chart," notes Barbara J.Cobuzzi, MBA, CPC,CPC-H, CPC-P, CENTC, CHCC, senior coder and auditor for The Coding Network and president of CRN Healthcare Solutions. "The physician may write, 'Patient stable,' or 'Patient a bit worse, order this exam,' and although they may be examining the patient, they may not document it well enough," Cobuzzi adds. Therefore, what Medicare's reviewers may classify as upcoding may simply be your physician underdocumenting his charts. Plus: CMS tagged consults with the highest outpatient error rate (16.6 percent), followed by new patient office visits (99201-99205), with a 15.5 percent error tally. "I have done many audits and I do find that physicians often code new patient visits incorrectly," says Susan Vogelberger,CPC, CPC-H, CPC-I, CMBS, CCP-P, CEO of Healthcare Consulting & Coding Education, LLC. "The key component requirements are different from the established patient's in that you need three out of three of the key components and that often is the problem," Vogelberger says. "They also tend to score lower in one of the key components and that pulls the code down."