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Archive for June, 2011

The RAConteur: RAC Updates From The Field

Posted by J. Paul Spencer, CPC, CPC-H in The RAConteur™

In a world that features increasing use of electronics in order to communicate, an ironic twist has developed. Namely, Twitter, Facebook and its many other permutations have led to a kind of “junk dialogue”. Of the billions of posts that appear on these platforms every day, perhaps one-tenth of 1% is important enough to share with the rest of the world. For actual, useful, truthful information dedicated to solving problems, face-to-face communication is still the best conduit.

In the past ten days, two updates came forth from live gatherings of actual human beings that will have a profound effect in our current world of audits gone mad.

The first update came on June 17th at CMS’ Health Care Fraud Summit in Philadelphia. In response to a pointed question regarding oversight of audit entities, Peter Budetti, the deputy administrator of the Center for Program Integrity, stated that the agency would be conducting an “audit audit”. This review of the multiple audit contractors dotting the landscape is being undertaken as a response to complaints about the number of audits now encumbering providers. As inconsistencies and redundancies develop between CERT, RAC and ZPIC, providers are increasing at a loss as to priorities and protocols between the entities.

It is worth noting that as far as the RAC providers are concerned, those of us in the provider community are still waiting for information regarding appeals and the quality of work being put forth by the RAC contractors. Through all of this, as well as Mr. Budetti’s announcement of audits of the entities, our fearless RAC Validation Contractor, Provider Resources Inc., continues its Marcel Marceau impersonation, sans grease paint.

The second announcement stemming from human interaction this week was revealed at the Healthcare Financial Management Association’s Annual National Institute. It was revealed in a presentation by an industry executive that audit contractors are focusing their attention on hospital services for back and chest pain, based on the potential for claim rejection upon review. This is based on the difficulty of proving medical necessity in these cases. The information on chest pain seems to be in sync with the findings of the latest AHA RACTrac survey showing that short stays for this diagnosis are under heavy scrutiny nationwide.  

As my wife disappears into her Twitter account as she sits next to me on the couch each evening, I happily remind the world at large that quality communication can’t occur at 140 characters per pop. Providers are facing a crisis of investigation right now. Working together with the substantive forum of discussion will provide information to everyone affected, which can only lead to better outcomes in the future.

As a footnote to today’s post, last week I received a comment on last week’s post from a representative of HMS, a company who has become the Medicaid RAC Contractor for 9 states (thus far). I invite the reader to review this comment, as it includes a link to a page on their website that includes an interactive map. The map shows the state-by-state progress of Medicaid RAC contracts that CMS is currently lacking.

Based on the information available on this map, and based on my own investigations and bush-rattling, I now have 19 states as having contracted with a Medicaid RAC contractor. It is more than likely that HMS has made this map available to pound their chest a little bit about having almost 50% of the finalized RAC contracts thus far, but any information is welcome, and I thank them for making it available.

A Casualty of Extrapolation

Posted by J. Paul Spencer, CPC, CPC-H in Hot Topics

This September, the state of New York will celebrate the 30th anniversary of one of the darker chapters in its history. It was on September 13th, 1971 that state troopers responded to a riot / hostage standoff at Attica State Prison by throwing tear gas and opening fire indiscriminately. The resulting deaths of 39 people, including 10 hostages, took 19 years to settle in the courts. It was an abject lesson in casting too wide a net to solve an immediate problem.

Something is about to occur in New York which, while not on the scale of the human loss at Attica, becomes yet another abject lesson in cutting too wide a path of destruction. It is being reported from state news sources that Jim Sheehan, the Medicaid Inspector General, will be asked to resign his post within 30 days of the conclusion of the current state assembly session.

On the surface, this would seem to be a counter-intuitive move based on Sheehan’s record of returning almost $1 billion to New York’s Medicaid coffers. Critics charge that Sheehan’s methods have been heavy-handed, with the word “fraud” being used too often in cases of honest billing mistakes. Terms such as “shakedowns” and “punitive nitpicker” have been offered from some corners of the provider community to describe Sheehan’s tactics.

One such method that has come under fire is Sheehan’s use of extrapolation to collect six-figure recoveries from some providers. Being a former Assistant US Attorney in Philadelphia, this method of determining overpayments would certainly not be foreign to him. However, as we enter the realm of expanded government investigations, many methods of extrapolation used by various audit entities have come under fire for being wildly inaccurate and mathematically flawed.

Better mathematicians than myself have explained to me that selecting one wrong set of parameters while performing extrapolation can lead to widely divergent results, many of which up to this point have been detrimental to the providers. Variations totalling hundreds of thousands of dollars, if not properly reviewed for accuracy, have the potential of putting providers quickly out of business. With the largest amount of criticism coming from institutional providers, such as nursing home companies that would take a much bigger financial hit through extrapolation, it becomes easy to see why Mr. Sheehan became suddenly unpopular in the state of New York.

Someone of Sheehan’s stature will more than likely find work very quickly. In addition to his recovery successes, he has built a solid reputation in compliance circles by attempting to educate the provider community on how to avoid audit repayments. New York is attempting to control future activities of the Office of Medicaid Inspector General through the legislative process to insure that future IGs have perhaps a less freewheeling approach.

With that said, extrapolation, no matter how trusted the source, should come under immediate suspicion. As an example, the RAC contractors, who have yet to prove their competence in the audit field in utilizing other methods, will be allowed to use extrapolation as one way of identifying improper payments. If someone with the stature of Jim Sheehan gets his head handed to him partly due to these methods, how forceful can we expect the push back to be against the RACs for utilizing the same techniques?

We all exist in a new world with regard to audits, but not all investigations equate to one another. Because of Mr. Sheehan’s competence, providers asked for his ouster. With lesser audit entities, I encourage providers to build strong defenses, lest the innocent be slaughtered alongside the guilty.

The RAConteur: Slowly, Medicaid RACs Assigned

Posted by J. Paul Spencer, CPC, CPC-H in The RAConteur™

Since I’m writing on what is the second day of summer, I thought I’d start today’s post with a baseball analogy. There’s a saying in baseball that when dealing with your pitching staff, the team “goes with the guy that got us there”. This could mean either that you leave your starter in beyond their endurance, or that you put in the closer from the bullpen, even if he’s struggling.

As news begins to trickle in regarding Medicaid RAC contracts awarded by individual states, this maxim appears to be repeating itself in the auditing universe.

State Medicaid plans have for some time hired independent contractors to conduct audits of  their operations, as well as with other program integrity functions. This could be either independent of or in concert with fraud control units already in existence. It appears that when selecting a Medicaid RAC contractor, states are looking to these entities first as a way of streamlining the process.

The latest case in point is the state of New York, which announced yesterday that HMS will be the Medicaid RAC for the Empire State. HMS has been performing program integrity services for the state since 2002, which appears to have assisted in abbreviating the selection process.

Part of the reason for a short list of candidates was the compressed timeline set forth in the proposed rule for Medicaid RACs. The original start date for the program nationally was April 1, 2011, with the state plan amendments having been due on December 31st, 2010. Given that three months was all that was originally allotted, it isn’t surprising that states looked to the familiar. Despite the delay in the final rule to “sometime later this year”, some states continue to seek out the familiar.

Thus far, including New York, I am aware of 8 states that have selected RAC contractors; Colorado, Delaware, Kansas, Michigan, Mississippi, New Hampshire and North Dakota have also settled on contractors. Pennsylvania appears to have chosen CGI as its Medicaid RAC contractor as part of a contract renewal with the state, but in reading the press release of the contract on the CGI website, everything but the term “RAC” is used. Mark my former homeland as a tentative “yes” for CGI.

Based on the lack of updates on CMS’ “State Medicaid RACs At-A-Glance” page, those of use looking for information on individual Medicaid RAC contractors continue to seek out enlightenment in the same way horse racing mavens seek out bookies walking through dark, wet city alleys, selling tips on the next day’s horse races. For states, we’re 18% of the way down the path of knowledge. For the remaining 82%, we’ll pick it up on the streets.

This Blog Is Making You Sleepy……

Posted by J. Paul Spencer, CPC, CPC-H in Medical Studies

Progress occurs when preconceived notions, even briefly, intersect with possibility.

The world of science, taken as a whole, has proven this thesis true time and again in human history. Whether it was Copernicus and Galileo challenging the Earth’s place in the universe, or the first doctor who dared to think that bleeding with leeches may not be the upper reaches of medical care, the presentation of possibility has assisted in human evolution and extension. There have been mistakes, such as the Nobel Prize for physiology and medicine being awarded in 1926 to Johannes Fibiger for his “discovery” that parasitic worms cause cancer (later widely disproved). Yet it is the unique role of the scientist to never give up. Science remains the welcoming home to the curious and impatient.

With this in mind, I relate the preliminary findings of a small Belgian study that showed that hypnosis, coupled with local anesthesia, led to an improved postsurgical outcome than the use of general anesthesia. Follow the pocket watch as it swings back and forth while I give you the details.

In the study, 18 of 76 breast cancer surgery patients and 18 of 54 patients undergoing thyroid procedures underwent a combination of hypnosis and local anesthesia for their procedures. The remainder of the patients in the study received general anesthesia. In both sides of the study, the patients who were hypnotized experienced improved recovery times, shorter hospital stays and decreased post-operative opioid use. Twenty percent of the patients were later observed to cluck like chickens as they crossed the street on rainy days. OK, I made that part up.

Up to this point, hypnosis has existed solely in the realms of psychotherapy, complementary medicine and vaudeville. The usage of such techniques in the operating room represents quite a shift. Because this was a small scale study, one would not expect surgical suites to immediately begin trading in their bulky anesthesia equipment in favor of spinning black and white spirals on sticks.

However, let’s take a look at this study as part of the larger argument going on currently with regard to ACOs and the desired savings that this model is hoping to provide. Everything being projected in the ACO model lacks imagination, mainly because medical treatment standards and protocols are being viewed through the ACO looking glass as stagnant and non-evolving, when nothing could be further from the truth. As the Belgian study shows, science continues on even as the American health care system and its underpinnings remain in a sort of money-inhaling vacuum.

Innovation is not forced, but rather imagined, tested and implemented. The ACO model as currently proposed constitutes unreasonable experimentation lacking in anecdotal example. Think of it in terms of trying to tune a banjo by putting it through a cycle in the dishwasher, then subsequently wondering why it sounds worse. ACOs, as envisioned in the proposed rules, are at best a guess, and not a particularly good one.

The nascent Belgian hypnosis study holds the promise of enormous savings, but like any scientific experiment it requires further study. If industry comments regarding the proposed ACO rules are any indication, many elements of the ACO model require further testing. Perhaps it’s as easy as waving a pocket watch in front of Kathleen Sebelius and Don Berwick, watching their eyelids close and subconsciously planting a different model in their heads. One can imagine the possibilities.

The RAConteur: Losing Before Winning

Posted by J. Paul Spencer, CPC, CPC-H in The RAConteur™

As a fan of the sport of ice hockey, tonight will mark a special moment. The Stanley Cup Finals will have a 7th and final game in Vancouver, British Columbia to decide this year’s champion. This will mark only the 16th time in NHL history that this has occurred.

One of the oldest cliches in sports is that playing in a Game 7 in hockey, baseball or basketball is the contest in which every young boy dreams of competing. Tonight, when I watch the introduction to the latest Game 7, which will more than likely include clips of plays from the previous 6 games, music that begins with one lonely French Horn playing a call to arms, and a voice-over talking about dreams and combat, I shall think about the part that’s always left out of this particular tale of sporting romance. To put it specifically, in order for a Game 7 to happen, your team has to lose three games in the series. Knowing this makes the lead-in less that dream-like.

Thanks to the RAC process, providers are finding out the hard way what it means to lose before winning. According to the latest AHA RACTrac survey, successful provider appeal rates remain unusually high as the RACs approach their second anniversary on October 1st of this year. Thirty-eight percent of hospitals participating in the latest quarterly survey stated that they had at least one claim overturned in the RAC discussion period. Further, 68% of hospitals reported filing at least one appeal and 71% of completed appeals have been found in favor of the provider.

While it can be seen as a positive that the RACs are on a learning curve, and that their first claim determinations have a way of not sticking, these facts do not necessarily mean that affected providers are coming out completely victorious. The administrative costs of responding to additional documentation requests can be prohibitive. The recognized reimbursement rate under the RAC program of 12 cents per page of medical records comes nowhere close to reimbursing the staff hours and supply costs expended for ADR response. Factor in the costs of determining (and subsequently preparing) appeals, and suddenly that 12 cents per page rate feels insulting.

If I were to give one piece of advice to providers, it is to beware of retrofitting the RAC response process into the existing correspondence infrastructures of the office or facility and assuming that everything is going to work perfectly. Because of the time lines involved, identifying and acting on RAC correspondence is an important step is establishing reasons for appeal later in the process. Most facilities have responded to the RAC threat by appointing RAC coordinators to manage the process, but this act alone does not insure timeline compliance. In most cases, the RAC coordinator is selected more for their auditing and compliance skill sets than any demonstrated acumen with correspondence. 

Any team builds toward victory by learning to adjust to the opponent. In the case of RAC contractors, they are big, unwieldy and not particularly organized, but I would add “yet”. Facilities are currently on the losing end because of the administrative burden and the RAC audits that have actually recovered funds, but continuing refinement of the RAC process, with a second eye pointed in the direction of clinical documentation improvement. In the Stanley Cup Finals of RAC preparedness, the facilities are in the second period of game two, down by a couple of goals and trailing in the series 1-0. Playing in Game 7 is the easy part. Arriving healthy in the arena for that game is the fight of a lifetime.

The Earth Strikes Back

Posted by J. Paul Spencer, CPC, CPC-H in Health Care & Society

WIth regard to human life on Earth, I am considered something of a dark overlord among my acquaintances. I am firmly of the belief that the planet considers human life an irritant, and will eventually rebel and shake us off in relative terms as quickly as it did the dinosaurs. Those that scream “Save The Planet!” can be viewed as naive, as the planet is a big, unfeeling rock that isn’t going anywhere. Nature adapts, and continues, and knowing that one organism has the ability to consider this fact doesn’t guarantee that particular organism’s survival.

As a species, we learned this in the most uncomfortable of ways in the past week with the E. coli outbreak stemming from organic vegetable sprouts from an organic farm in the Lower Saxony region of Germany. The infected produce killed 31 people and sickened more than 3,000 before the source of the outbreak was narrowed down. This particular strain of E. coli caused hemolytic uremic syndrome in some patients, leading to acute kidney failure.   

On the twisted road to a solution to the mystery, a lot of innocent bystanders were sucked into the Vortex of Blame. The European consumption of lettuce, Spanish cucumbers and tomatoes ground to a halt. Spanish produce suddenly became unpopular among trading partners in the Northeastern Hemisphere. Thanks to the efficiency of German health authorities, the source of contamination was isolated before further incriminations and finger-pointing could continue into other tried and true human interaction classics, such as scapegoating and mob rule.

Currently,we find ourselves buried in a debate regarding the future of health care in America. As a part of that comes response planning to epidemics. Emergency health response since 9/11 has focused on terrorist attack agents such as anthrax and radiation. It is wise to consider that the German outbreak shows in stark time that Nature isn’t waiting around for human-to-human brutality to thin our numbers. The preponderance of evidence in 2011, from tsunamis in Japan to tornadoes in the Southern United States and Massachusetts, and now to bacteria-laden sprouts, indicates that the Earth has grown tired of waiting of evolution to do the work necessary to cull humanity.

We can argue about Medicare remaining in its current form or as a voucher program, and we can pile on the “ACOs-Are-Bad” bus and worry how everyone is going to be paid under such a model. We can wring our hands about audits threatening small healthcare providers and ICD-10 and 5010 and a host of other issues, but as an amateur futurist and an observer of evolutionary trends and a visualizer of the impossible, I have a different challenge for the health care world. Take one minute a day, amidst the regulatory madness, and consider that the biggest threat to the American healthcare system may exist all around us.

The RAConteur: The Screaming Baby Behind You

Posted by J. Paul Spencer, CPC, CPC-H in The RAConteur™

To most of the country, I am clocking in just in time with this week’s observations on the continuing travails of the Medicare RAC program.

The reason for this is that for the past few days, I was a speaker at the 2011 Physicians RAC Summit in Houston. Today, I flew home. Air travel, as it is currently configured in the United States, is an activity only slightly less enjoyable to me than stuffing a scalpel blade-first under my big toenail. Today’s flight headed down the rating scale exponentially with a direct flight back to Milwaukee that featured two crying children in the row of seats directly behind me. Thanks to a storm front that just passed over our area, the plane teetered onto the runway during final approach, as distressed travelers sunk their finger nails into their armrests. If I have anything to say about it, I believe I experienced my last plane ride today.

If there was one takeaway from the RAC Summit that I can share with each of you, it is the fact that medical providers feel that they are akin to my flight experience today. If you are enrolled in a government health care plan, and you accept payments from these plans, you have become an unwitting hostage to audit programs and structures such as the RACs. A provider these days is very much like an exhausted man returning home from a business trip in a sealed mode of transportation as the children around him scream, only in an allegorical sense, the screaming is actually in the form of additional documentation requests.

When such a gathering of professionals occurs in one place, such as what occurred at the RAC Summit, the largest lesson that can be gleaned is that it doesn’t have to be that way. The analytical tools are available to defend providers from these types of audits. In addition, as the RACs are currently configured, odds are very strong that the provider has the upper hand with regard to appeals. The numbers from independent organizations reveal that the RACs are on a learning curve as they ramp up operations.

Think of the RACs as a baby hydra. Their dangerous, serpent-like heads are not fully developed, which gives the experienced swordsman ample opportunity to severely injure one of the heads, but it will eventually heal itself. To put it another way, the cabin door to the airplane isn’t completely sealed, and providers are not permanently trapped, with a rocky flight being the result. Time remains before the RACs increase their workloads to include every provider it can possibly bring into their universe. The skills to survive and thrive are available, while the screaming baby briefly naps.

An Easy Budget Fix For Medicare

Posted by J. Paul Spencer, CPC, CPC-H in Health Care Reform

I was, perhaps unfortunately, born into a political family. Because my early childhood memories revolve around assorted family members watching the evening news and commenting loudly, sometimes using the off-color language of prejudice that was the hallmark of bygone generations, I continue to be sucked into political discussions as an adult.

There are only a few differences between the political junkie and the heroin junkie, not the least of which is that I lived beyond 30. While the actual junkie can usually be found in a dank room without furniture, huddled around a candle with a needle, a spoon and their latest bag of potential death to get them through the next six hours, the political junkie can be found in a different kind of shooting gallery (probably a Starbucks), huddled around a laptop, reading an opinion blog, with the latest cup of cream-softened caffeine to keep them going for the next four hours. The only physical similarity is the sunken eyes, one from walking death, the other from absorbing too much information, with both self-constructed prisons ensuring that they’ll never live carefree and happy again.

With this in mind, and with more than a little information about America’s health care situation in my mind, I wade into the morass that is our country’s current slouch towards debt default. Ironically, I’m due to be in Canada when the default is scheduled. Judging from the idiocy I see scattered among the people placed in charge of preventing the default, I might have to stay there. Why wouldn’t I? They have wonderful people, cold weather, intelligent public discourse, hockey, beer and doughnuts, all in abundance, which those who know me can tell you is a pretty sexy package in Spencerland. My wife is one-half Canadian, so I’m practically there already.

As the latest posturing about the federal budget drags on, I was struck by Senate Minority Leader Mitch McConnell recently stating that unless something is cut from Medicare, Republicans will not compromise on raising the country’s debt ceiling. Being the paragon of common sense that I am (at least during work hours), I’m here to accept Mr. McConnell’s challenge, and I can do it in three words.

End Medicare Advantage.

Federal contracting, in every Cabinet department, is a vast, apocalyptic land of waste, fraud, overpayment for everyday products and services, political back-scratching, and unfulfilled promises. Within the Department of Health and Human Services, there is no more salient example of a program that exists to no benefit for the country’s citizens than Medicare Advantage, or Medicare Part C.

The idea behind Medicare Part C is that private insurance companies offer Medicare beneficiaries an alternative to traditional Medicare coverage which, in theory, would also offer other benefits not available under the original plan. The beneficiary pays the competitive premiums to the insurance company, and voila!, everything is rainbows, good fairies, dancing elves, candy buttons and fountains of strawberry milk and gumdrop trees.

Since this is a joint initiative of the federal government and the insurance industry, one cannot be surprised that the program is one big con job and money pit all rolled into one.

Let’s start with the accuracy of claims payment. The claims error rate for traditional Medicare is 10.5%. That’s a lousy number, but the error rate for Medicare Part C is 14.1%, meaning that if your claim is sent to a Medicare Advantage plan, and it waits in a virtual line for claims adjudication on a given day, and its number in that line is divisible by seven, it will be paid incorrectly. It doesn’t end there. The American Medical Association issues an insurance report card, showing the accuracy of claims payment of the largest insurance companies in the country. The results of these measurements is the finding that one out of every five claims sent to the big insurers is deliberately underpaid based on contracted rates with physicians. In addition, the amount of the underpayment is usually far less than the administrative costs on the provider end to collect the remaining money owed. If we combine the Medicare error rate with this set of facts, the picture painted is less Rembrandt and more Picasso.

Next, we look at the incentive payments we pay to Medicare Advantage as taxpayers. Each Part C plan receives extra dollars if the data received from claims indicates that the population they are servicing is sicker and consuming more resources. These payments are in addition to the financial benefits to the insurance company of syphoning off patients from the traditional Medicare program. If you’re on Medicare, you’re either 65 or older, or have a chronic disease. If an insurance company makes a business decision to offer a Medicare replacement plan for a population that common sense dictates is worse off in terms of health than the rest of the general population, why is this incentivized? Opening a store offering glass figurines is fraught with inherent risks, but the government doesn’t pay to keep it open simply because of what’s being sold inside. Old people and those with chronic diseases get sick more often. The Medicare program offers them coverage because the insurance industry looked at their actuarial tables and said “no dice”. Medicare Advantage is being paid a tribute just to provide coverage to the sickest beneficiaries under the plan to make up for the actuarial loss. Voiding Medicare Part C would end this circular logic once and for all.

As the infomercial says, “But wait! THERE’S MORE!”. When Medicare Part D, which offers coverage for prescription drugs, came into being in the last decade, the vultures circled. Insurance brokers used the selling opportunities for Medicare Part D to sign up traditional Medicare patients to corresponding Medicare Advantage plans, many without their knowledge. The best comparison for this practice was the long-distance “slamming” that went on in the late-’80’s and early-’90’s, where virtuous corporate paragons like MCI/Worldcom would sign up someone for their long distance service without their knowledge, with the first indication that it actually happened being an eye-popping bill to the slammed. Medicare recipients have been lured into Medicare Advantage plans, hypnotized by drug formularies, to the great financial benefit of the insurance companies behind the Advantage plans. The OIG is aware of these behaviors and has issued a few slap-on-the-wrist fines, but the practice continues.

Finally, the so-called “advantage” of Part C plans was that they offered benefits above and beyond what traditional Medicare offered. The most common of these was coverage for yearly preventive exams with the beneficiary’s primary care physician. As of 2011, traditional Medicare offers an annual wellness exam to all beneficiaries as part of the plan, which significantly diminishes the value of Medicare Advantage plans right out of the starting gate.

Medicare Part C has become a worthless boondoggle. It has value only to the insurance companies collecting premiums. It is the worst kind of corporate welfare, redirecting benefit dollars from the sickest of our citizens into the pockets of corporate America. It is a drain on the budget at a time when we can’t afford it. If you want to be serious about deficit reduction ahead of raising the debt ceiling, tackle the waste. Other than the continuing misadventures in Iraq and Afghanistan, I can think of no better example than Medicare Part C.

The RAConteur: Evidence of Physician Unpreparedness Mounts

Posted by J. Paul Spencer, CPC, CPC-H in The RAConteur™

I have an ongoing conversation going on with my friends and acquaintances about modern applications of the survival instinct.

The topic tends to come up when I see a news item about hikers getting lost and either dying or being rescued by park rangers after eating snow for 17 days in order to survive. I am an urbanized / sub-urbanized American. In addition to being allergic to virtually every natural thing on the planet after the outdoor temperature reaches 70 degrees Fahrenheit, I can look a person in the eye and tell them unabashedly that I do not like the woods, I’m not equipped to go hiking, and I’m not interested in the nutritional qualities of tree bark and wild berries. The more enlightened of my discussion partners tell me that knowing my own limitations, and the skills at which I do (and do not) excel, indicate that I have in large part passed the self-preservation test.

The topic of survival leads me to turn attention to the modern state of medicine. Physicians, especially primary care providers, are getting slammed in the modern age. A combination of rising caseloads, colleague shortages and changing insurance demographics have many front line providers operating at margins that are not sustainable. While it’s true that the Patient Protection and Affordable Care Act included incentives for current primary physicians, as well as plans to encourage more medical school graduates to enter primary medicine, the results of these proposals, if achieved at all, won’t be seen for roughly a decade.

All of these factors make it all the more important to monitor the financial health of the physician practice. The one constant with physicians is that they are lulled into a false sense of security with regard to revenue. The thought process that I have noticed is that as long as large insurance checks keep coming through the door, then all is well. I’d like to once again burst that bubble. Money isn’t a threat, but many things threaten your money.

This brings me to the subject of audits, RAC and otherwise. I was reminded again about the short attention spans of physicians with the release of the latest results from a service specific probe conducted by WPS Medicare. CPT code 99213 was probed for all specialties in the state of Wisconsin. This particular probe had an unusually low error rate of 30%, as compared to past probes of evaluation and management services. What was revealing to me was the fact that 80% of the claims found to be in error were due to lack of a physician response to the request for documentation from the probe. This demonstrates a continuing ignorance in the provider sector towards government audit processes.

The RAC contractors are fast approaching the day of reckoning for complex review of physician documentation. Unlike the popular board game Life, this will not consist of selling your blue and pink peg children and retiring to Millionaire Acres. With operating expenses nearly to the point of overwhelming practice profit, the beginning of expanded RAC review of physicians, if ignored, ensures the rapid demise of your bottom line, and eventually your practice.

A basic tenet of long-term survival is the ability to pay attention to and be prepared for threats. An example in the urban setting is looking both ways before crossing the street. In the woods, one would be best served by not waving and shouting ”HELLO!” to the bears. In the physician office setting, an easy stop on the road to long-term survival of the practice is to read all of the mail thoroughly. If processes aren’t in place to perform proper triage on the practice correspondence, it’s time to build them, and fast. If you’re a physician, your continued survival depends on it. You’ll be surprised how much easier it is than drinking melted snow.