Medicare Audit Atlanta

Medicare Audits – “Reasonable and Necessary”

With the Federal government contracting and double-checking its spending, healthcare practitioners are under the microscope for their billing practices. If you have been contacted for a Medicare audit or are currently undergoing a Medicare audit, there are a few things you want to know.

What Are They Looking For?

Billing and coding beyond the actual services performed is the crux of a Medicare audit.

Providers that could be audited include:

  • Hospitals

  • Physical therapists

  • Nursing homes

  • Private physician practices

Essentially, any entity that bills Medicare.

In 2017, the USDOJ, in joint efforts with the FBI, uncovered fraud worth $1.3 billion, where medical practitioners were overbilling their patients. At times, some medical practitioners were even driving around trying to find homeless individuals and paid them cash to use their cards to bill Medicare.

Physical Therapists and Common Audit Triggers

Use of the KX Modifier

Physical therapists are commonly targeted for billing related to the KX modifier. This modifier signals an automatic exception to the therapy cap on the basis of normally accepted necessity.

It is also scrutinized when providers bill an unusually high number of codes for each patient visit.

Documentation Issues

Simple oversights can raise red flags:

  • Missing practitioner signatures

  • Use of a rubber stamp or electronic signature

  • Insufficient documentation supporting the level of billing

These issues may suggest the absence of a practitioner and potentially invalidate the services billed.

Plan of Care Compliance

Practitioners should:

  • Rectify a plan of care when time has lapsed since the onset of care

  • Ensure there is sufficient documentation to support claims, especially after a claim denial

Signature and Billing Clarifications

The issue of signatures matters because billing rates differ depending on whether services are provided by a physician or a nurse.

Additionally, billing separately or “unbundling” services, such as dressing and warm packs, should comply strictly with Medicare rules.

 

Frequently Asked Questions

What is the main purpose of a Medicare audit?

The main goal of a Medicare audit is to verify that providers are billing only for services that are medically reasonable and necessary. Auditors check for overbilling, improper use of modifiers, and documentation inconsistencies.

Why are physical therapists frequently audited?

Physical therapists often use the KX modifier to bypass therapy caps, which triggers scrutiny. Additionally, billing a high number of codes per visit or failing to meet documentation standards increases the likelihood of an audit.

What documentation issues raise red flags during a Medicare audit?

Auditors closely examine missing or improperly applied signatures, rubber-stamped or electronic-only approvals, and insufficient documentation that doesn’t support the billed services. These can all suggest that services were improperly claimed.

How should providers handle a lapse in a plan of care?

Providers should update and rectify plans of care promptly when there’s a delay in treatment continuity. Documentation must justify the necessity of ongoing treatment, especially after a denied claim.

What is “unbundling” and why is it a concern in Medicare billing?

Unbundling is the practice of billing individual components of a service separately instead of as a package. Medicare considers this improper if the separate services aren’t allowed under their guidelines, and it may result in repayment demands or penalties.

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