Medicare Compliance & Reimbursement

Employees should be handled differently than outside entities.

If an entity outside of a physician's practice changes his documentation, the physician's responsibilities may be slightly different than if an employee makes the changes.

For example, suppose a durable medical equipment provider alters Certificates of Medical Necessity a doctor has signed - or a contractor changes some files somehow.

Step 1: Ward Off Fraud

The physician first needs to protect the  practice from fraud charges, says attorney Joan Roediger with Obermayer Maxwell & Hippel in Philadelphia. The doctor should keep copies of all forms he signs in the patient's chart, so he can compare them to the version he gets back from the outside entity.
 
Step 2: Self-Report

After making sure his records are in order, a physician that suspects that an outside entity has been altering documentation should also alert the HHS Office of Inspector General, say attorneys.