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Averting Audits: Part 2

How to ensure your EHR doesn’t place you at risk for a billing review

APRIL JASPER, O.D.

In “Avoiding Audits Part 1” I explained, in part, how the use of the wrong technology at the wrong time or, worse yet, for the wrong purpose or without medical necessity leads to overpayment recoveries.

Here, in Part 2, I discuss the manner in which the misuse of EHR — yet another type of technology — may serve as a trigger for audits and overpayment recoveries and how you can avoid this scenario.

Targeting EHR

For the second year in a row, the U.S. Department of Health & Human Services’ Office of Inspector General (OIG) says it is targeting EHR for investigation:

“We will assess the extent to which CMS made potentially inappropriate payments for E/M services and the consistency of E/M medical review determinations,” the OIG says. “We will also review multiple E/M services for the same providers and beneficiaries to identify electronic health records (EHR) documentation practices associated with potentially improper payments. Medicare contractors have noted an increased frequency of medical records with identical documentation across services.”

Your EHR may state (i.e., auto code) that your documentation reaches the level necessary to bill a higher-level code at a higher level of frequency during a calendar year than is really necessary. Furthermore, audit data analysis reveals that the “copy or carry forward” features in EHR systems give physicians the ability to “re-document” past exam findings to support documentation levels that exceed what is realistically “medically necessary” in the ongoing care of patients.

Removing the risk

To make certain you are not placing your practice at “auto code” risk for audits and overpayment recoveries, follow these three steps.

1. Don’t blindly accept your EHR’s “auto-code” feature. Make certain you choose the level of E/M coding as determined by each carrier. It is appropriate to utilize the EHR auto-code feature to ensure the “completeness” of the medical records prior to claim submission, but inappropriate to rely on it to make billing decisions for you with regard to the level of coding.

2. Review your records. Do this to make certain you are not inadvertently cloning or piggybacking details that are unnecessary or completely unrelated to the current exam.

3. Generate and evaluate the utilization and frequency patterns of billing E/M codes. Do this for each doctor in your practice to verify an expected “fat” bell curve distribution and not a “skinny mountain” bell curve created by the graph of this data. Also, check that a doctor in your practice who “varies” in his or her pattern of billing has a documented reason for the difference.

The risk is real

Don’t ignore the risk of an audit from utilizing EHR technology. Instead, follow the three steps outlined above to avoid an adverse audit outcome. OM

DR. JASPER IS A VISION SOURCE ADMINISTRATOR IN PRIVATE PRACTICE IN WEST PALM BEACH, FLA. E-MAIL DRJASPER@AESWPB.COM, OR SEND COMMENTS TO OPTOMETRICMANAGEMENT@GMAIL.COM.