Podiatry Coding & Billing Alert

Pay close attention to your documentation.  

As you are busy submitting multiple claims every day in your podiatry practice, you have to be diligent on each and every claim, or errors could creep in. In fact, podiatry practices logged a 13.6 percent error rate, according to the latest report from CMS. Among the biggest culprits contributing to this error rate was insufficient documentation, which came in at a whopping 72.6 percent and incorrect coding, which came in at 23.7 percent.

Background: CMS recently released the “2019 Medicare Fee-for-Service Supplemental Improper Payment Data” report as part of its Comprehensive Error Rate Testing (CERT) program. The CERT report breaks down the biggest errors among Medicare claims and covers the causes of the improperly paid charges. Overall, the government found a 7.25 percent improper payment rate among Part A and B claims during 2019, which represented a total of $28.9 billion in improper payments.

Discover 3 Podiatry-Specific Areas Where Improper Payments Hit the Hardest

In the CERT report, on the list of the services with the most Part B improper payments, podiatry visits totaled over $222 million in projected improper payments. Take a look at three podiatry-specific areas where CMS noticed massive overpayments.

Area 1: DMEPOS: For improper payment rates and amounts for durable medical equipment, prosthetics/orthotics and supplies (DMEPOS), podiatry came in with projected improper payments of $68 million, according to Tables I2 and J2. The improper payment rate is 67.1 percent. The following errors contributed to these improper payments:

• No documentation came in at 3.2 percent.
• Insufficient documentation came in at 89.4 percent.

Area 2: Office visits: Office visits for podiatry came in with $59 million in projected improper payments, according to Table H1. This has an improper payment rate of 14 percent.

Area 3: Lower limb orthoses: Also, for the improper payment rates for lower limb orthoses by the referring provider category, podiatry came in with projected improper payments of $25 million, according to Table H4. The improper payment rate is 39.6 percent.

DMEPOS Among Top 20 Service Types for Improper Payments

Overall across all specialties, CMS calculated the top 20 service types for DMEPOS with the highest improper payments, as found in Tables D2 and E2. These findings are below:

• Lower limb orthoses — The projected improper payment is $297 million. Specific errors contributing to the improper payment are insufficient documentation, which came in at 61.7 percent and medical necessity, which came in at 32.8 percent.
• Lower limb prostheses — The projected improper payment is $166 million. Insufficient documentation is the main error contributing to this improper payment, and it comes in at 98.9 percent.
• Diabetic shoes — The projected improper payment is $97 million. Insufficient documentation is the main contributing factor to this improper payment, coming in at 84.9 percent.
• Orthopedic footwear —The projected improper payment is $13 million. Contributing factors to this improper payment include no documentation at 16.2 percent and insufficient documentation at 74.7 percent.

“These are repetitive errors we see from year to year,” says Arnold Beresh, DPM, CPC, CSFAC, in West Bloomfield, Michigan. “But if people would just follow the rules as spelled out by their carriers, many of these mistakes wouldn’t occur.”

Avoid These Documentation Errors in Your Practice

CMS devotes a lot of space in the CERT report, outlining insufficient documentation errors. Numbers don’t lie, and as you can see from the figures above, podiatry practices are not immune to documentation errors. Below are some of the top root causes of DMEPOS errors due to insufficient documentation. Note: These were errors CMS found from all providers who bill DMEPOS items, not just podiatrists.

Error 1: Clinical disease management for DME is missing or inadequate.

Error 2: Proof of delivery is missing or inadequate.

Error 3: ACA 6407 requirement missing or inadequate. Note: “ACA” refers to the Affordable Care Act of 2012, and “6407” is the specific section of the Affordable Care Act, which requires a face-to-face encounter with a physician and a valid written order prior to delivery.

Error 4: Wound management documentation is missing or inadequate.

Error 5: Documentation to support medical necessity of diabetic item(s) or supplies is missing or inadequate.

Error 6: A valid provider’s order is missing or inadequate.

Don’t miss: CMS categorizes errors 1-5 as “missing/inadequate records,” which CMS defines as occurring when, “a required record has not been submitted or has not been fully completed.”

CMS categorizes error 6 as “missing/inadequate orders,” which occurs when “a valid provider’s order (or intent to order for certain services) for the service/supply does not meet the required elements for the order.”

To avoid making DMEPOS documentation errors, fill out the information completely, Beresh says. You should include all reports in a separate section of your chart and make sure all of the information is there before the item is dispensed to the patient or have the patient sign a waiver so they are responsible for payment of the DME.

Bottom line: To side-step DMEPOS errors in your podiatry practice, you must always document, document, document, Beresh adds.

Resource: To read the full CERT document, visit  https://www.cms.gov/files/document/2019-medicare-fee-service-supplemental-improper-payment-data.pdf.