Looking for opinions about something I once heard in a seminar. I heard that you are almost better off NOT having a specific written policy about a particular coding issue such as E&M levels in case you are ever audited; because if the policy is written and available and not followed you are non-compliant. If there is NO written policy you can basically say you were "not informed". We are currently doing physician education in our practice for E&M level documentation and were contemplating doing some written policies for this to include documentation guidelines and internal auditing with consequences for continued lack of documentation. Our concern is even though this would be an internal policy and auditing system our we puttting ourselves "out there" for compliance issues??? thanks for any in-put.
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Wiki Physician policy for E&M level compliance
- Thread starter joy2code
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mitchellde
True Blue
I am not sure exactly what you are referring to about having a policy vs being"not aware". Your physician should always follow either the 95 or the 97 guidelines and they should be aware of which guidelines they are using. The coder should let no claim be submitted without a review of the documentation. Even if the provider is the one selecting the codes the coder is still responsible for assuring that the correct codes are submitted on the claim and that includes the visit level. If the coder disagrees with the code selection then you need a policy as to what your office decides should happen next, such as does the coder change the codes for the claim, or does the coder have to consult with the physician prior to changing the codes. Either is acceptable.
camillecoder@hotmail.com
Networker
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May I suggest reviewing the OIGs voluntary compliance program? The link below is for independent and small group practitioners; there are other programs for other scenarios, I just happen to have this link saved as a favorite.
Willful ignorance is not a good excuse for noncompliance. In my opinion, a compliance program demonstrates a willingness and effort to comply.
https://www.federalregister.gov/art...ndividual-and-small-group-physician-practices
Willful ignorance is not a good excuse for noncompliance. In my opinion, a compliance program demonstrates a willingness and effort to comply.
https://www.federalregister.gov/art...ndividual-and-small-group-physician-practices
There is no longer any such excuse as being not informed. According to Medicare, if your practice participates, then you agree to abide by their rules - and you had better know what they are. They are no longer accepting "not informed" as an excuse. Information on compliance is everywhere. Even though compliance plans are voluntary at this point, a good faith effort can go a long way in the event of an insurance audit. I currently work for a fairly large specialty practice who does not have a compliance plan. I am starting to conduct audits, but I can't seem to convince them of the need for development of a compliance plan and program. I may be looking for a new job soon!