The Best Way to Avoid an Audit
Time and time again, we hear about how the Health and Human Services (HHS) Office of Inspector General (OIG) has audited another carrier for improper payments. Time and time again, the underlying cause has something to do with improper billing of units. In fact, according to a Medicare Claim Recovery Audit Contractors (RAC) demonstration, excessive/multiple units accounted for 70 percent of outpatient hospital billing errors in the first quarter of this year.
Take Palmetto GBA—the railroad Medicare Part B carrier for providers nationwide—for example. Palmetto processed more than 37 million claims between 2004 and 2006. Of those claims, 145 resulted in high-dollar payments of $10,000 or more. That is what alerted the OIG. After investigation, the OIG found Palmetto overpaid eight providers a total of $110,905. According to the report, providers attributed the incorrect claims to clerical errors or insufficient documentation to support the units billed.
To err is human. To supply inefficient documentation or incorrectly bill units, however, is avoidable. Just remember to report units in multiples of the units included in the long HCPCS Level II code descriptor. Do not go by the short descriptors as they don’t always capture the complete description of the drug. Nor should you bill units based on the way the drug is packaged, stored, or stocked. If, for example, the HCPCS descriptor for a drug code specifies 1 mg and a 10 mg vial was administered to a patient, bill 10 units.