Facility Side
I'd be interested in what others have to say. The challenge on the facility side is that there, at least yet, are no specific guidelines on levelling like 95-97 on the physician side. The general guidelines basically state that the Levels must be auditable (which you are doing) and reasonably relate to resources utilized etc. So basically you have to review the Levels based on the Levelling tool the ED is using assuming that the tool is reasonable( and the tool could be the problem in some cases). So if it's a point system, are the resources and services that have points identified and added properly? If it's ACEP, per the ACEP guidlines are all of the necessary resources, procedures etc documented to support the Levels. If you are outsourceing what is their tool?
One quick thing you can do as a starting point is just look at the acuity percentages for the period you are auditing. If a Level seems overutilized either high or low you might focus the audit there a bit. I've done a fair amout of research on facility Levels, and there still is quite a bit of variance on the way levels are coded. Or a more focused audit could result from initial findings.
If you wanted to provided me with the acuites privately, no PHI about the facility of course, I could at least give you a feel about your levels since I've looked at hundreds of ED facility Levels over the last few years.
Big brother is looking at 99285 since there has been a dramatic increase in recent years. And 99285s admitted are not coded. so auditing regularly is necessary.
jim