Publication In Impact Magazine

I'm honored to say that I've authored an article published in the June issue of Impact, the journal of the private practice section of the APTA. My contribution to this  issue was to share the lessons learned from some of our experiences with compliance audits conducted by our Medicare Administrative Contractor, Noridian. Since many private practices have not had the experience of going through such audits, I decided to share a bit of practical knowledge with the PT community.

I cannot link from here to the article, but I do want to post right now some corrections that will appear in a future issue; so for those to have landed here from that article, here goes a dose of humble pie:

Dear Editor:
I wish to correct several factual errors in my article entitled “Preventive Medicine for Surviving a Medicare Audit.” None of the “Lessons” from the article change; those are still my recommendations. In the interest of complete accuracy, however, here are the corrections:

1. In my article, I stated that CERT audits are pre-payment, and that if the results of a CERT audit show a high error rate, there may be consequences. CERT audits are post-payment, and charts are selected randomly. In the Comprehensive Error Rate Testing Program (CERT) the purpose is to establish a Medicare FFS paid error rate, which is done through a small random sample of provider claims. If a claim has been found to be paid in error by the CERT contractor, the FI/MAC is responsible for initiating repayment activities.

2. I stated that my organization had been subjected to a CERT audit which found a high error rate, followed by another audit to validate that we’d changed our practices. In fact, those were probe audits, initiated by our MAC, and conducted on a pre-payment review basis. It is the probe audit that can result in consequences, including follow-up probe reviews to reassess the provider error rate. And it is the probe audit that, if compliance is not demonstrated, may result in being placed on a correction action plan as referenced in the Medicare Program Integrity Manual up to and including more serious sanctions such as a referral to the Program Safeguard contractor or the ZPIC, or in the most dire of circumstances to the OIG.

3. Also, for clarification, the error rate is calculated based on charges in error compared to total charges. "…the error rate is the dollar amount of submitted charges billed in error (minus any confirmed underbilled charges) divided by the total amount of submitted charges for the services medically reviewed”

I apologize for these errors, which are mine alone. And I would like to acknowledge Nancy Beckley, a fellow author in the June IMPACT for her collegial and professional assistance in clarifying these issues.

It demonstrates one more lesson for the readers: This stuff is very technical and complex. It’s best to get professional help in preparing your business for the inevitable audits that are coming, and in responding to audits that do occur.