2020 is here and it is time for you to take a few moments and really think about the compliance activities needed for your practice. There are a couple of recommendations ACE would like to bring to your attention.
The 2019 April 1-Sept 30 report was issued in December and you all will not be surprised to know that the OIG has been busy and continues its dedication to safeguarding federal programs. $5.04 billion in expected investigative recoveries, 809 criminal actions and 695 civil actions filed, and 2,640 exclusions from federal programs. Opioid Misuse and pharmaceutical seems to top the high dollar recoveries. But make no mistake, there were several providers implicated in kickback schemes and improper referral arrangements which would indicate that vetting all arrangements and contracts with facilities/offices would be a “to do” for 2020.
ACE finds it interesting at how much data mining is playing a part in identification of outliers and would also recommend that in 2020 your practice run some reports to do your own comparisons of individual providers in specific areas of your practice.
Another piece of information ACE reviews to make recommendations on compliance activities is the Self Disclosures recorded in 2019. Again, by far the kickback arrangements top the list but a sizeable amount of disclosures dealt with billing for excluded providers which would emphasize doing your quarterly provider checks on excluded individuals. Other settlements dealt with topics of insufficient documentation for critical care services, incident to and Split-Shared Services billing, and billing for pre-operative evaluations. If your practice deals in any of these types of services, focused reviews may be a good way to ensure that your group is compliant with the rules.
Of course, in anesthesia groups there are several items that always cause risk: anesthesia time, medical direction documentation, post-operative pain services, and obstetrical documentation are a few that come to mind where focused audits might be appropriate.
Annual education is one of the key elements’ investigators look for in determining if the group has an effective compliance program. We are happy to help with any educational needs your group might want.
At ACE, we continue to do the all-encompassing 360 compliance review for groups that includes documentation and reimbursement. We also do have specific audits for coding or reimbursement focused. This year we are offering a new service which involves managed care services. The new service has us analyze up to 100 claims from a single payor to ensure appropriate payment and collection of services. We find many times providers are unaware of what their true collection per unit rate is within the managed care claims and do not always understand the denials and collection efforts necessary to achieve the negotiated unit rate. If your revenue does not seem to be what you are expecting or if you are getting ready for a specific contract negotiation, you may find this type of audit to be helpful in providing information regarding claims processing.
As always, we are here to help with your anesthesia coding and auditing needs. Please feel free to reach out to us if we can be of service to you.
Welcome to a new decade and lots of opportunities that are sure to present themselves in the coming year.