394 years ago today, William Shakespeare, the man whose works continue to be the high points of narrative drama written in the English language, died in his home in Stratford-on-Avon just a few days before his 52nd birthday.

I have a sense of humor that leans heavily to the dark side, so when I think of favorite scenes from Shakespeare’s plays, my favorite among all of his scenes is towards the end of Julius Caesar, when the angry mob surrounds, attacks and kills Cinna the Poet in a case of mistaken identity with one of Caesar’s assassins who shares his name. I can imagine the Monty Python comedy troupe having a field day with this scene on a strictly absurdist level.  

There may be nothing worse in this world on an individual human level than being accused of something you simply didn’t do and feeling as if you have absolutely no recourse to defend yourself except to exclaim your innocence.  With this thought in mind, I find this to be a perfect opportunity to speak to the physician community about CMS’ expanded audit guidelines that are part of the Patient Protection and Affordable Care Act (PPACA).

I made a passing mention in a previous post about the expansion of recovery audit contractors (RAC’s) to the state level for Medicaid plans, in addition to expanding the focus of audit for the four national RAC’s already in place. It is important to internalize what this means on the individual physician level, namely that there are more sets of eyes on your practice than ever before.

While the worst of those committing fraud against the Medicare program or other insurances tend to rise to the top and get skimmed off quickly, it is my belief that the majority of physicians believe strongly that the services for which they are billing are commensurate with the actual services performed on behalf of the patient. Yet all the belief in the world will not help you if the documentation prepared in support of those billed services is lacking.

I’ve spoken before about the importance of reviewing documentation for E/M services. Perhaps it is also a good time to look at the documentation of the procedures you perform, both within the office and in other locations. Are your notes a complete picture of the procedure performed from beginning to end? If the procedure is so extensive as to require an assistant at surgery, does the operative report include documentation of the necessity of the assistant? Is the documentation signed, keeping in mind that any op report can be rejected due to a lack of signature under CMS’ new signature requirements? If the procedure note is handwritten, is it legible?

The same thing applies to medical tests and diagnostic services. Does the documentation currently in the patient’s file represent a 1:1 comparison with the services billed? If you are billing for interpretation and reporting, is your report documented?

When physicians hear the word “fraud”, a defense mechanism is usually triggered from their perspective that believes with every fiber of their being, much like Cinna the Poet, they are being accused of something they didn’t do. If you performed a service, fully document that service and go forward secure in the knowledge that you have evidence of every service performed on behalf of your patients and their welfare.

As delicately as I can, I’ll explain it to you this way: Cinna the Poet lacked documentation of who he was and what he did. How did that work out?

12:46 pm, April 23rd, 2010 |