Medicare Compliance & Reimbursement

Will Medicare be asking you to return part of the $59 million overpaid to radiologists? CMS is watching your claims, but the errors the agency is targeting may not be the ones you expect. Medicare's Comprehensive Error Rate Testing (CERT) scoured diagnostic radiology backup documentation and uncovered documenting disasters and an estimated $59 million in overpayments. But downcoding also made CERT's list of diagnostic radiology mistakes. Here are examples of the problems CERT found and how you can avoid them -- so Medicare won't be asking you to repay part of that $59 million next time. 1. Try Checklists For Adequate Documentation CERT uncovered multiple cases of insufficient documentation for billed services. Example: One provider billed cervical myelography radiological supervision and interpretation (72240), but the documentation didn't mention contrast or fluoroscopy. Protect yourself: If trying to code from inadequate documentation is one of your greatest frustrations, you aren't alone. Try educating physicians about the precise documentation you require to do your job accurately and efficiently -- and to get the doctor the reimbursement she earned. Strategy: Gather information on documentation guidelines for the procedures your radiologists perform most often and create a documentation checklist to guide their reports. For example, for digital bilateral diagnostic mammogram with CAD, you should report the following codes, says Barbara Rutigliano, MS, RT(R), CPC, RCC, coding manager for Jefferson Radiology in Connecticut: • G0204 -- Diagnostic mammography, producing direct digital image, bilateral, all views • +77051 -- Computer-aided detection (computer algorithm analysis of digital image data for lesion detection) with further physician review for interpreta- tion, with or without digitization of film radiographic images; diagnostic mammography (list separately in addition to code for primary procedure) A typical report for digital bilateral diagnostic mammogram with CAD should specify using these technologies and may look like this, Rutigliano says: Direct digital imaging was used for this exam Computer-aided diagnosis was used for this exam Comparison is made to film dated ____________ Right breast findings: ___________ Left breast findings: ____________ Impression: __________ Remember: A checklist can help remind the physician about what he needs to cover in his report, but the interpretation should be specific to the patient who underwent the service. Payers come down hard on physicians who use cloned documentation in their reports. 2. Stop Little Details From Causing Big Problems Medicare's focus on technicalities came through loud and clear in the CERT review. Example 1: CERT found fault with a chest x-ray billed with modifiers 26 (Professional component) and 77 (Repeat procedure by another physician) because the report didn't have a radiologist's name or signature. Without this information, CERT had no indication that the billing provider performed the billed service. Example 2: One provider billed [...]