Urology Coding Alert

Don’t fall victim to these potentially risky actions.

Merit-Based Incentive Payment System (MIPS) measures that don’t meet threshold requirements followed up by lackluster supporting documentation are risky actions and may cause you to fail a MIPS audit. However, some practices skirt the rules to boost their chances of an incentive — and that’s fraud.

“Overall, CMS is looking for instances of fraud, waste, and abuse of this system,” warns ONC HIT certification manager Lora Woltz in the April 25 webinar, “Bulletproofing the MIPS Audit File.”

“If they suspect it, they will escalate the audit into an investigation status,” Woltz explains. “You can help avoid this by not engaging in high-risk behaviors.”

There are five specific things Woltz cautions MIPS providers to watch out for. Review these questions to see if you’re pushing the limits:

• Are you “cloning” patient data by cutting and pasting in your EHR from one visit to the next? “If you undergo a medical record audit, cloning is going to be one of the primary sources of their investigation,” she says.
• Do clinicians identify themselves and take ownership of their inputs when adding notes to an EHR record? As Woltz points out, “If there’s not a clear way to track who did what, then that can cause a problem for you if you undergo an audit.”
• Are you overusing the auto-populate option of your EHR? Woltz says doing so is the equivalent to data cloning, which is allowed – but data should still be checked and confirmed.
• Do you add or alter dates after the fact? Date of service changes are going to draw attention to your audit log, intentional or otherwise.
• Are you lying about measures, codes, or more to increase payments? Patient fabrication and upcoding are on the “darker end of the spectrum,”
• Woltz says, and auditors will zero in on these malicious EHR actions.

Keep the repetition in perspective: “I think one of the toughest parts about being a provider is, at times, the documentation that is required can be so repetitive,” shares Kimberly Quinlan, CPC, a senior medical records coder for the University of Rochester Medical Center in Rochester, NY. “While documentation is a necessary part of the visit, the focus should always be on the patient. I feel enabling providers to document pertinent findings and only what has changed just since the last visit promotes good patient care,” she adds.

Reminder: You can no longer submit 2018 Merit-Based Incentive Payment System (MIPS) data, but you can take a peek at your performance feedback from CMS. You have until June 30 to review your information, but CMS warns that the feedback is fluid. Special status, hardship applications, scoring, and more can make your performance levels go up and down, according to an MLN Connects brief.