Is Your Practice Medicare RAC Ready? - The Answer Lies in Your Documentation
The three year Medicare RAC demonstration that was conducted in California, Florida and New York demonstrated that one of the biggest areas where improper payments were identified was due to improper documentation by the physician.
As a practice administrator you may wondering how to ensure physician documentation leads to proper coding in the billing cycle. You may also be wondering how to go about improving the documentation of the physicians that work in your practice. Proper training and education is critical to ensure that physician documentation is compliant and that it leads to accurate coding and billing.
As the Medicare Recovery Audit Contractors (RACs) roll out nationwide, it's now more important than ever that your practices administrative and physician staff work together to assess documentation risk areas that may be a potential audit risk to your organization. That way once these areas are identified, you can implement proper training and education for your physicians so that any documentation weaknesses will improve and your audit risk will be reduced.
During the demonstration period, approximately one third of improper payments identified by RAC auditors were cited as improper due to the fact they did not meet Medicare's medical necessity criteria for a particular service. Another significant amount of claims were identified as improper was due to the fact there was not enough documentation on requested medical records or information could not be gathered in time to respond to the RACs request. During the demonstration, through March 2008 improper payments totaling more than $391 million were recouped due to medical necessity criteria not being met, with another $74 million being recouped for insufficient documentation.
Here are a few steps your organization can perform to ensure that you will be RAC ready.
Identify Any Risk Areas
The first step is to assess your practice's documentation to identify any areas of risk. By examining past medical records, your practice can identify any areas of risk and the things your physicians may need additional training and education on. This review can be conducted internally if you feel that you have qualified staff that can conduct an independent review of your physician's documentation.
If you don't feel competent about your internal staff performing the review, it is definitely worth considering hiring a qualified third party audit firm to come in and do a base line audit of all of your physician's documentation to identify any compliance issues.
The key whether you do this internally or utilize a third party is to make sure and involve both your clinical staff and administrative staff. Everyone needs to be informed of any defined goals, progress and issues identified so that everyone will buy into doing whatever it takes to correct the identified issues and bring your organization compliant.
Provide Education and Training
If issues are identified, your physicians must be open to receiving training and additional education so that they can learn how to properly document patient encounters. This will greatly reduce your organizations audit risk in the future.
Make sure and also include your administrative and billing staff in the education process. Make sure and use real-world examples from your practice in you training as this is vital to ensuring your organization's documentation is thorough enough for clinical and billing needs.
Training and education should be provided by certified professionals that have the coding and documentation knowledge relating to your specialty.
Education and training should not be a onetime thing but an on-going practice that is implemented into your organization's goals and objectives. The rules and regulations of compliance are constantly changing so it's critical that your organization continued to obtain proper education to ensure that your organization is current with compliance requirements.
Engaging both your physicians and staff in the process of RAC preparation is critical because it ensures that your organization will be as prepared as possible should the RACs select your organization for an audit.
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