Wiki Internal Audits/Provider Amendments

[stephsaylor30@yahoo.com]

I have a question about internal chart audits and provider documentation. Two of my providers have asked that if I notice a discrepancy between the E/M level they have selected and the E/M level I feel is supported by their documentation that I notify them prior to changing the code so they can "fix" their note. In other words, they want the opportunity to add documentation to support billing 99214 rather than 99213. I am incredibly uncomfortable with this. It's my understanding that amendments can only be added to clarify or correct conflicting documentation, and that amendments made to support a higher code may be considered fraudulent. I am unable to find any authoritative guidelines to support my point of view. Can you offer any insight or resources into how the governing bodies (CMS, OIG) may view such amendments? Thanks in advance.

 

[kdlberg]

You are absolutely correct. Amendments are intended to clarify things that may have been unclear in the initial documentation or to add new relevant information. For example, the provider diagnosed a UTI based on the patient's symptoms but also sent a specimen to the lab. When the results come in, those can be added into the encounter note ("Addendum, 2/18/2020, Dr. Smith: specimen came back positive for E.coli.")

Changing the documentation after the fact solely for the purpose of billing a higher code is upcoding. Upcoding is fraud.