Our on-site compliance review is a comprehensive audit that begins with the anesthesia and operation room records and ends with reimbursement information.
This comprehensive compliance review is structured to accomplish the following for your group:
- Fulfill the need for annual compliance audits as a part of an internal compliance program.
- Assess code assignment accuracy and compliance for professional services through a review of documentation and coding.
- Identify any anesthesia coding compliance issues.
- Review reimbursement for accuracy and comparison to MGMA and ASA Benchmark data.
- Fulfill requirements for annual education.
We believe that it is important in assessing risk to look at supporting documents. We have found many variances between the anesthesia copy and the original record. This is primarily due to copy benign pulled prior to completion. Some variances relate to medical direction elements, end time variances, and transfer discrepancies. Anesthesia time has been a focus of concern by OIG and it is important that the provider’s documentation can be supported by other sources.
The results of an on-site compliance review will include but is not limited to the assessment of the following:
- Appropriate documentation of pre-evaluation and plan
- Appropriate documentation of medical direction or supervision
- Appropriate ICD-10-CM and CPT-4 coding review
- Base unit discrepancies
- Appropriate modifier designation
- Medical necessity for MAC
- Appropriate documentation of relief services
- Concurrent case review
- Appropriate documentation of ancillary services
- Appropriate documentation of evaluation and management services
- Appropriate documentation of post-operative rounding
- Verification of appropriate completion of records to comply with carrier billing requirements
- Time analysis, which includes monitoring and rounding analysis
- Compliance with Correct Coding Initiative (CCI) bundling edits
- Reimbursement Analysis
The information will be used in preparation of our written education report. Our report is easy to follow that lays out the rule and explanation for an educational flow, and then follow each section with the specific findings and recommendations related to the topic. A summary of recommendations is given in the end to help guide the practice on issues for continuing compliance activities throughout the year. If it is of interest to the group we can also provide a “Score Card” that grades the group on each compliance element.