It’s been a while since our beloved Recovery Audit Contractors (RAC) were on the front page of the trades every day, but they’re far from gone. In fact, CMS has started to get aggressive in a few new ways, according to the Fox Group:
- Meaningful Use Attestation Audits: So you’ve collected EMR data, you’ve attested, and you’re waiting for your check. All is well, right? Not necessarily. CMS has begun requesting documentation from providers that supports the attestation, largely data from your EMR but also possibly info from internal audits you’ve conducted to see that you’re meeting objectives. This is big stuff; if you fail your audit by CMS, there goes your money. And in the future, if you fail multiple audits, you could be seen as submitting false claims. Mega-ouch.
- MACs Look At Documentation: Medicare Administrative Contractors (MACs) have been auditing medical records for years to make sure documentation supports the services billed. Now, they’re going to start looking at “auto-generated data” produced by EMR medical record documentation systems. If the auto-documentation looks “cookie-cutter” and possibly out of line for some specific patients, providers could be in trouble.
And if you somehow get entangled with a RAC investigation, don’t count on carefully-spelled-out EMR documentation to save you. According to a recent study by the American Hospital Association, 77 percent of claims denied by RACs were restored upon appeal, suggesting that most of the time, claims targeted by the RACs weren’t bad to begin with. In other words, I think it’s fair to say that they’re out for blood, so prepare yourself.
An internal audit of your documentation can work wonders, Fox Group suggests. And keep an eye out for copy-and-paste documentation across bunches of patients; it’s gone from questionable to perilous.