Don’t count on the EHR for billing codes. Electronic health records have a function, which practices can turn on or off, that suggests level of service codes based on documentation. But that’s only part of what goes into proper coding. It’s difficult for an EHR to determine the impact of things like risk, according to David J. Zetter, a health care consultant at Zetter Healthcare.
Don’t rely on the billing department or staff to bill correctly. “Many group practices have either an internal billing expert or use an outside billing company to help them submit bills. Some of these experts are there merely to make sure that appropriate codes go out and that they’re lined up with the proper ICD-10 codes,” said Jonathan Rubenstein, MD, of Chesapeake Urology Associates.
“But many billing experts just don’t understand the nuances of what a doctor is or is not doing. Sometimes a billing expert will trust that a doctor is submitting bills appropriately.”
Do train, then train some more. Dr. Rubenstein said he trains all new providers in proper billing and coding at Chesapeake Urology before they start practice.
“And within the first 3 months into practice, I personally look through their charts for appropriate coding. I get monthly reports from our billing staff, which outlines our doctors’ coding patterns, and if I see an abnormality in coding patterns, I will do a specific review of a doctor who is more than one standard deviation above the mean of the practice,” Dr. Rubenstein said.
“I have monthly meetings with our billing staff where they alert me to any problems that they might see with billing or with certain providers. And we have an internal compliance plan where we have the ability to enforce a behavior change with a provider who may be coding or billing out of the normal range or as would be expected.”
Smaller practices can hire outside consultants or coding experts to educate practices and do chart reviews, or internal staff can attend training classes. The AUA offers yearly training, according to Dr. Rubenstein. PRS, LLC offers an online course on the topic for physicians.
Don’t under-code for fear of an audit. “Medicare looks for patterns, and sometimes if you under-code, that may be sending a red flag as somebody trying to hide something that they’re doing wrong,” Dr. Rubenstein said.
Realize that whistleblowers, or relators, can come from anywhere. These individuals alert the government about possible False Claims Act violations. They can work in practices. Some are patients. Others, as in the case with Skyline Urology, are practice consultants.
Don’t view audits as death sentences. “Everybody is going to get audited one way or another. There’s no way to code or report things that doesn’t get you in trouble,” said Mark Painter of PRS, LLC. “Ultimately, the best way to behave is to think that you will be audited at some point in time in your practice, and as long as you approach it by supporting everything you do with documentation and medical necessity, there’s no reason to fear an audit.”