Practice Management Alert

Put Yourself Under the Microscope Before Your Payer Does

Self-audits can be your best defense against billing-compliance breaches

They say that admitting you have a problem is the first step to recovery, but you might never know your billing office has a problem unless you do a little sleuthing.
 
Conducting a "self-audit" of your billing practices (i.e., examining a representative number of claims with a focus on finding errors) is a great way to gain insight into potential problem areas, characterized by similar mistakes made over and over again.
 
Self-audits are key because they can help you catch your problems before someone else does, says attorney Robert Wanerman with Reed Smith in Washington. Self-audits are a great way to show the government and other payers that you're taking a proactive approach to ensuring accurate billing. This display of dedication makes it difficult for the feds to accuse your practice of "willful neglect" of the rules, Wanerman says.
 
"Performing routine self-audits is an ideal way to determine plans of action for identified problematic areas," says Brenda Burton, president of MedExtend in Fayetteville, Ga. For example, you might find that you need to change your policies and procedures, beef up your staff training, or even revise certain claims processing procedures, she says.
 
Experts say you should conduct self-audits every six months - or at least yearly. Of course, if you have high turnover or if you suspect you might have a problem, you should audit yourself more frequently.
 
When performing your self-audit, be sure to focus on these common risk areas, Burton says:
 

  • unbundling
     
  • upcoding
     
  • failure to use modifiers properly
     
  • alteration of documentation
     
  • coding without proper documentation
     
  • billing for services provided by unqualified personnel.

    But don't haul out the shovels if you're not prepared to deal with any problems you might dig up, experts say. If you turn a blind eye to the problems you find, it'll be worse than never finding them at all if a disgruntled payer comes calling - and if that payer happens to be Medicare, you could be in store for a billing fraud investigation.
     
    "Any identified errors should be properly adjusted, documented and resubmitted for proper payment or refund if necessary," Burton says. If you unearth a far-reaching,
    systemic problem involving many claims and/or a large sum of money, you should consult with legal counsel to determine how best to proceed.
     
    Ideally, you should audit yourself on a prospective basis, meaning you audit "charges for services that have not yet been billed," says Jim Collins, CHCC, CPC, president of Compliant MD Inc. in Matthews, N.C. "This way, if you find overcharges, you can correct them before the claim goes out," which will save you from having to refund overpayments, he says.
     
    A self-audit may save you from charging too much, and  it may also save you from charging too little, especially for surgical and diagnostic procedures, Collins says. "Practices can go years without knowing they are missing charges," he says. "Auditing diagnosis code assignment/documentation can also be profitable, as this is where many claim denials come from." Fixing the problem will usually result in a higher collection percentage.

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