May 17, 2011
Question:
Jennifer,
I appreciate why you sent out the link to the OIG's most wanted list, but I have to say it was a depressing email to receive; one I wish there was no need to send. I have been in practice now for over 15 years, and while I try to do everything by the book, I am a solo doctor trying my best, and I know sometimes mistakes happen. I would like to inquire as to whether you have any advice on how I can better sleep at night, feeling secure my name won't be posted on that list!
Thank you for all of the information! Please keep it coming!
Dr. Concerned
Answer:
Dr. C, I hear you and frankly when I happened upon the updated OIG site, I was taken aback at the presentation. The good news I have for you is that landing yourself on the OIG "most wanted" list is not an easy task. The Office of Inspector General is really looking for the few who are perpetrating egregious healthcare fraud at the tax payers expense, ourselves included.
Tips I have for those out there looking to ensure their practice is operating in a compliant manner include PREVENTATIVE PLANNING, such as:
(1) adopting an effective compliance plan (required for those taking or ordering Medicaid reimbursable services, recommended for all practices) - get your policies in place so your staff has an approved, written process to follow in your billing;
(2) meet at least once a year with an outside certified coder - not just your internal billing person - to review your documentation for completeness;
(3) take the time to educate yourself or make sure your staff is educated about changing documentation requirements and billing codes (i.e., the new Medicare initial visit code);
(4) I always recommend being active in a professional society/association - whether your county or State medical society or a specialty or ethnic society - so long as such association is a resource for practice concerns and exposes you to your peers and applicable concerns for practitioners; and
(5) Lastly, continue being an active member on our listserv!
Remember, so long as you are providing medically necessary care, and your documentation reflects the services you are providing, you are operating appropriately. Typical problems that do arise oftentimes happen when the practice is perceived to be doing something wrong. For instance, when you believe your documentation is stellar, when in fact, on an objective basis (which is, of course, necessary so that payors have a baseline for review - especially if you participate) your documentation is awful. The same goes for your office procedure, for instance, if you are polite, efficient and a caring practitioner, whereas your staff is making you look bad with insurers and patients (i.e., by sending in incomplete information - forgetting to send in operative reports when requested, or sending page 1 but not page 3 or speaking inappropriately to patients on the phone or mishandling HIPAA protected information).
Without written procedures and annual reviews, many practices continue with business-as-usual, which usually means neglect to optimal operating standards.
The thing is about preventative planning that many of you refuse to accept is, for every dollar you spend implementing the practices I've outlined above, you are saving yourself X times that amount (typically the applicable multiple is at least 10) on the back end should you be audited. I've offered this before and will offer it again for the benefit of the listserv, for the rest of the week (ending Sunday at Midnight), I'll extend 15% off any compliance document any listserv member purchases, with the hope that some of you will actually take preventative measures seriously.
If you would like to discuss in greater detail, contact me at (516) 747-6700 x. 302 or at Jennifer@kirschenbaumesq.com.
Copyright © 2011 by Kirschenbaum & Kirschenbaum, P.C.
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