What’s the Best Defense? A Good Offense
A Chicago-based academic health system recently made headlines after an audit by the Health and Human Services Office of the Inspector General (HHS OIG) uncovered roughly $21.1 million in Medicare overpayments.
This is nearly double the amount reported back in 2017 when the results of the initial two-year audit recommended the hospital refund Medicare $10.2 million. According to the report, the Hospital complied with Medicare billing requirements for 63 of the 120 inpatient and outpatient claims reviewed by the OIG. However, they did not fully comply with Medicare billing requirements for the remaining 57 claims, resulting in overpayments of $814,150 for calendar years 2014 and 2015.
More specifically, 51 inpatient claims had billing errors, resulting in overpayments of $812,744, and 6 outpatient claims had billing errors, resulting in overpayments totaling $1,406.
Since the initial report, the OIG uncovered an additional $10.8 million stemming from a four-year audit.
The government alleges billing errors resulted in overpayments for inpatient and outpatient rehabilitation claims.
According to the report:
The Hospital generally disagreed with our findings and recommendations. The Hospital agreed that for some claims in the sample, the documentation supports a different level of reimbursement. The Hospital disagreed with more than half of the findings on the inpatient rehabilitation claims reviewed and said that it believes the error rate to be much lower than what OIG claims. The Hospital also stated that it did not have a sufficient understanding of OIG’s sample methodology to confirm OIG’s extrapolated amount or to offer an alternative amount.
What is an overpayment?
The official definition from the Centers for Medicare & Medicaid Services (CMS) states that a Medicare overpayment is a payment that exceeds amounts properly payable under Medicare statutes and regulations. When Medicare identifies an overpayment, the amount becomes a debt you owe the Federal government. Federal law requires CMS to recover all identified overpayments. Medicare overpayments commonly occur due to:
- Incorrect coding
- Insufficient documentation
- Medical necessity errors
- Processing and other administrative errors
What is the deadline for refunding Medicare overpayments?
According to Section 6402 of the Patient Protection and Affordable Care Act, the overpayment must be returned within 60 days from the date the overpayment was “identified,” or by the date any corresponding cost report was due, whichever is later.
Failure to return an overpayment has severe consequences.
If an overpayment is retained beyond the 60-day deadline, PPACA Section 6402 makes clear that it will be considered an “obligation” under the FCA. As amended by the Fraud Enforcement Recovery Act of 2009 (FERA), the FCA subjects a person to a fine and treble damages if he or she knowingly conceals or knowingly and improperly avoids or decreases an “obligation” to pay money to the federal government. PPACA treats Medicaid and Medicare overpayments alike in stating that failing to refund an overpayment will be considered an “obligation” under the FCA.
How can our health system be compliant?
The best way to verify you are in compliance is to schedule frequent external audits (coding reviews). By doing so, you can uncover any issues and put corrective action in place, so the issue doesn’t continue (and you won’t be forced to pay back the government!).
What kind of focus do we need?
If it’s been awhile (six months or more), we recommend starting with an external baseline review with a random sample. This provides a snapshot of where your coders stand. It also allows you to see strengths and where opportunities lie in order to focus on education and future reviews.
I’ve had my baseline review, now what?
Based on the results of the initial review, a thorough analysis of areas that fell below your expectations should be performed.
For instance, did specific DRG’s, Diagnosis, Procedures, MDC’s reveal a trend? Were there too many/too few queries, individual coders with less than stellar results?
For our clients, we provide an Executive Summary. This report highlights areas of priority with action plans and modules and a series of follow up focused reviews to ensure the education has not only been planted, but that it’s taking roots.
In 2019, we reviewed over 50,000 diagnosis codes from many different specialties for our Professional Fee clients. Here are the top three ICD-10-CM chapters where HIA identified coding opportunities: Z00-Z99 – Factors influencing health status and contact with health services; I00-I99 – Circulatory system and; R00-R99 – Symptoms, signs and abnormal clinical and laboratory findings, not elsewhere classified.
This is Part 5 of a five part series on the new 2020 CPT codes. For the remaining areas we will just briefly summarize the section. Due to the intricate nature of these sections in CPT, it is recommended that the coder read the entire section notes associated with the new codes.
This is Part 4 of a five part series on the new 2020 CPT codes. In this series we will explore the CPT changes for FY 2020 and include examples to help the coder understand the new codes. There is 3 new digestive system codes with 1 deletion and 2 revised; 1 revised urinary system codes with new category III codes; 6 new with 20 deleted nervous system codes with 3 revisions; 2 new eye codes with 3 revisions; and finally a new category III auditory code.
This is Part 3 of a five part series on the new 2020 CPT codes. In this series we will explore the CPT changes for FY2019 and include examples to help the coder understand the new codes. There are 11 new cardiovascular CPT codes added with 8 deletions and 2 revisions.
This is Part 2 of a five part series on the new 2020 CPT codes. In this series we will explore the CPT changes for FY2020 and include some examples to help the coder understand the new codes. There are 11 new musculoskeletal CPT codes added with 1 deletion and 0 revisions.
This is Part 1 of a five part series on the new 2020 CPT codes. In this series we will explore the CPT changes for FY2020 and include examples to help the coder understand the new codes. For 2020 in general, there were 248 new CPT codes added, 71 deleted and 75 revised.
This is Part 6 of a 6-part series focusing on CPT coding of breast procedures. There are many different types of breast reconstruction procedures, each having potential stumbling-blocks for coders. Part 6 focuses on revision of a reconstructed breast.
This is Part 5 of a 6-part series focusing on CPT coding of breast procedures. There are many different types of breast procedures, each having potential stumbling-blocks for coders. This series will address several of the more confusing topics. Part 5 focuses on the coding of different types of autologous tissue breast reconstruction procedures.
Part 4: CPT Breast Education Series | Use of Acellular Dermal Matrix with Breast Implant Reconstruction
This is Part 4 of a 6-part series focusing on CPT coding of reconstructive procedures following mastectomy. There are many different types of breast reconstruction procedures, each having potential stumbling-blocks for coders. Part 4 focuses on the use of acellular dermal matrix with breast implant reconstruction.
Part 3: CPT Breast Education Series | Immediate Versus Delayed Permanent Breast Implant Reconstruction
This is Part 3 of a 6-part series focusing on CPT coding of breast procedures. There are many different types of breast procedures, each having potential stumbling-blocks for coders. This series will address several of the more confusing topics. Part 3 focuses on the difference between immediate and delayed permanent breast implant reconstruction.
This is Part 2 of a 6-part series focusing on CPT coding of breast procedures. There are many different types of breast reconstruction procedures, each having potential stumbling-blocks for coders. This series will address several of the more confusing topics. Part 2 focuses on the use of tissue expanders in breast reconstruction.
With the implementation of ICD-10-PCS the description of codes became much more detailed to describe exactly what is being performed. Cardiac catheterization is one of the descriptions that changed to further detail exactly what is being performed during the procedure.
This is Part 1 of a 6-part series focusing on CPT coding of reconstructive procedures following mastectomy. There are many different types of breast reconstruction procedures, each having potential stumbling-blocks for coders. Part 1 is an overview of the types of breast reconstruction techniques commonly used. Future topics in this series will go into more detail of each technique and the CPT coding implications.
With Christmas fast-approaching, we’re making a list of our favorite holiday movies and checking it twice. And in the spirit of good humor and cheer, we’ve added some ICD-10 codes to these holiday classics. Have a safe, happy, and healthy holiday everyone!
“Lobar” pneumonia references a form of pneumonia that affects a specific lobe or lobes of the lung. This is a bacterial pneumonia and is most commonly community acquired. Antibiotics are almost always necessary to clear this type of pneumonia.
Why are so many sepsis records denied? It’s hard to say why there seem to be so many sepsis denials of late, but most likely this is due to the multiple sets of criteria for the diagnosis of sepsis, change in definition of sepsis, as well as physician documentation.
In Parts 1, 2 and 3 we learned about what sepsis is, sequencing of sepsis and what documentation is needed to report severe sepsis. In Part 4, we will look at clinical indicators needed to clinically support the diagnosis of sepsis and determine if a query is indicated.
Severe sepsis occurs when sepsis progresses and signs of organ dysfunction/failure develop. One site stated that approximately 30% of patients with severe sepsis do not survive. Patients may develop one organ dysfunction/failure, multi-system organ failure and/or septic shock.
In Part 2 of our Sepsis Series, we are going to focus on sequencing of sepsis when the diagnosis is clearly documented. Later in the series we will look at what to do when the diagnosis is not clearly documented.
In this series, we will learn what sepsis is or causes of sepsis, how to sequence the diagnosis in ICD-10-CM, what are the clinical indicators for sepsis, is a query necessary before reporting the diagnosis of sepsis, and how to prevent denials on sepsis records.
In the previous three parts of this four part series, we discussed the new ICD-10-CM diagnosis code changes, ICD-10-PCS procedure code changes and FY2020 IPPS changes. In this last Part 4 of the series, we will review the NTAP procedure codes and reimbursement add-on payments for FY2020.
In the previous two parts of this four part series, we discussed the new ICD-10-CM diagnosis code changes and ICD-10-PC procedure code changes. In this session we will review the major IPPS changes for FY2020. On August 2, 2019, CMS published the Final Rule for IPPS (CMS-1716) FY2020 IPPS Final Rule.
In Part 1 of this 4 part series we discussed some of the new ICD-10-CM diagnosis changes. In Part 2 we present the significant ICD-10-PCS procedure code changes. There are 72,184 total ICD-10-CM codes for FY2020.
We have finished with the step-by-step coding tidbits on coding of spinal fusions. If you were not able to catch Parts 1-13 of this series focused on spinal fusions, please visit hiacode.com/topics/series/spinal-fusion-coding/.
In Part 12, we focused on intra-operative peripheral neuro monitoring used during spinal fusion surgery. In Part 13, we are going to focus on harvesting of autograft and is it coded. Remember in Part 6, we learned that autograft is bone from the patient.
In Part 11, we focused on identifying the computer assisted navigation used during spinal fusion surgery. In Part 12, we are going to focus on intra-operative peripheral neuro monitoring.
In Part 10, we focused on identifying whether or not hardware from a previous spinal fusion is coded. In Part 11, we are going to discuss computer assisted navigation.
In Part 9, we focused on identifying if decompression was also performed and if so, on which body part. In Part 10, we are going to focus on identifying if hardware was removed from a previous fusion site.
In Part 8, we focused on identifying if a discectomy was performed, and if so, if it was a partial or a total discectomy. In Part 9, we are going to focus on identifying if a decompression was performed, and if so, was it of the spinal cord, spinal nerves or both?