Why are Internal Chart Audits Important?

Many people are intimidated by the word “audit” and run in the other direction. Why should every practice do chart audits? It is important to inspect and verify your charts and billing practices before an insurance company calls for medical records. Doing regular chart audits sets you up for a sense of calm when the auditors do come knocking. Audits help you learn more about billing, the hierarchy of treatment, and what to expect from an insurance company before you send the claim.

When a patient is finished with treatment, the documentation needs to be matched up with the billing. It is not unusual to perform ‘spot’ audits during a course of treatment and helps the final audit process go very smoothly. A billing ‘roadmap’ or guideline is a handy tool to have available. If you use a billing guide, be sure to exercise flexibility in auditing, due to patient factors. There are no hard and fast rules when billing radiation oncology services, because every patient is different.

Steps:

First, read the original consult notes to gain understanding of the patient history, the current diagnosis, medications, and the treatment plan. You are going to use this information to form a logical sequence of events.

Next, sort the billed charges by date and read over the CPT codes. They should follow a pattern, such as pre-planning stage, treatment weeks, boost planning, etc. The dates in billing should match the documentation in the patient’s chart. Exceptions to this are acceptable (within a day or two), as long as the practice consistently bills the same way for all patients.

Pay attention to the units billed and match the number of beams or tangents with dosimetry charges, or the number of blocks with units billed for the immobilization device(s).

Count the number of treatments that were expected to be given, the number that were billed, and the number reported in the final completion note. In a perfect world, all should match, but patients get sick, discontinue treatment, or other events can change a treatment course. Just document on a checklist or in the final treatment notes what caused the discrepancy so you will remember later.

Verify that every weekly treatment management charge that you billed has a doctor’s report, and that the number of treatments divided by five equals the number of treatment management codes billed. However, keep in mind that you may have three or more additional treatment deliveries at the end of the patient’s treatment course that would result in one additional weekly treatment management charge.  The date ranges for your weekly treatment management charges cannot overlap.

Also count any port films and weekly physics codes and match them to your documentation and the number of treatments received.  Many of these documents may come from different departments. Check that all documents have been signed, initialed, or electronically signed by the doctor who is overseeing treatment.

At this time, I also like to look at the payments and/or denials that have been received in the patient’s A/R’s. This gives me an opportunity to share any research that can guide my A/R or billing person as to the reason why a service was denied improperly or should not have been billed.  It becomes apparent which services will always be bundled if billed together, or which services may require a modifier.  Refund situations can also be quickly identified and you will be in the good graces of any insurance company when you voluntarily send a refund for a billing error.

Basically, when you perform a chart audit, you are making sure that every billed charge has a document to support its existence. If you use a billing guideline or checklist, it can be included in the chart with notes or exceptions that you would like to remember later, such as why a code was not billed or why a patient did not receive the number of treatments originally planned. This way, if a chart does get pulled for an external audit, the internal audit checklist can really take the pressure off and you are not scrambling to find explanations for any inconsistencies.  A typical internal chart audit takes only 15 – 20 minutes and is well worth the time in the long run.

Knowing the difference between global, professional, and technical charges

Medical practices are almost as diverse as people in regards to the arrangements and agreements that exist between physicians and facilities. The existence of different fiscal arrangements requires that medical entities bill their charges based on the specific level of service that the entity is providing to the patient.  CMS has created billing rules to accommodate these different scopes of service by standardizing medical billing for the entire insurance industry. When a biller understands the definition of the CPT-4 codes, and modifiers, they can then bill according to CMS’s requirements. This leads to fewer denials and better payment history.

The NHIC (National Health Information Center) conducted independent audits for CMS and found that more training was needed. Specifically, their findings showed that the medical industry continues to incorrectly bill (or not bill) modifiers that are required to distinguish between the global, professional, and technical components of services. The modifier codes that distinguish these services are ‘26’ for professional components, and ‘TC’ for technical components.

The explanation per CMS, in a nutshell, is this:

The professional component of a charge covers the cost of the physician’s professional services only.  When billing for the physician’s time and expertise, a 26 modifier is added to certain CPT codes.  For example: a patient has a CT scan and the doctor interprets the results. A biller may code 77014 – 26 to indicate the charge is for the professional services only.  By adding the 26 modifier, the biller is alerting the insurance company that the claim is requesting payment for the physician’s services only and not the use of the facility, the use of the CT equipment or other support staff’s services.

The technical component of a charge addresses the use of equipment, facilities, non-physician medical staff, supplies, etc. Technical charges do not include the physician's professional fees, but include the use of all other services associated with the visit. Using the same example, a patient has a CT scan and the results are sent to the doctor for interpretation. A biller may code 77014 – TC to indicate the charge is for the technical component only.  In this case the medical claim is seeking payment for the use of the CT equipment, the facility costs and the costs associated with all supplies and staff except for the physician.

A biller will bill global charges when there is no division of the costs associated with a medical service because the service was provided by a single entity. The global charge includes both the professional services as well as all ancillary services (like use of equipment, facilities, non-physician medical staff, supplies, etc.) associated with a patient’s care.  Global charges require no modifier.  For example: a patient has a consultation with the doctor.  A biller may code 99203 with NO modifier.

Many CPT-4 codes are intended to be billed globally and may not be separated. In the practice of radiation oncology, one example is 77414 which is the delivery of radiation (by the equipment and technician). This code is billed globally with no modifiers. If the physician has a special agreement with the facility allowing her/him to bill for this service, then it would be billed globally by the doctor and not at all by the facility.

The need to separate components can be difficult to remember when billing, but is easily achieved by the use of software that recognizes when to add a modifier, and which modifier to add. Iridium Suite, for example, may be configured to bill certain code modifiers based on the objective of the treatment course, or the place of service in the case of a physician who bills from several different facilities or offices. It is important, therefore, to understand the literal description of the code being billed, as well as the fiscal agreements between the physician and facility(ies) where the physician treats patients.

Separating codes into their components can be confusing to not only practitioners and billers, but to patients as well.  The insurance company sends EOBs showing what the patient may interpret as duplicate billing due to the facility and the doctor charging the same CPT codes.  Since the majority of patients do not understand the need to separate codes into their components, it is important to understand component billing so we can explain it to the patient. Insurance companies may also ‘miss’ a modifier.  Knowing when and how to use modifiers is important in resolving claims denials and results in a better payment history in the long run.

What is Real-Time Eligibility?

Historically, when a patient with insurance came into a medical office, the staff obtained a copy of the insurance card and, if there was time, they made a call to the insurance company for eligibility status, benefits, and stop-loss information. Today, medical technology is all about networking with other systems in order to save time and increase billing success. Real-time eligibility increases staff efficiency and affords us the most accurate up-to-date patient data by performing payer inquiries online.

Real-time eligibility verification streamlines the patient intake process. In Iridium Suite for example, Real-Time Eligibility is able to verify patient insurance coverage before a patient comes through the door. Personnel can use the payer’s eligibility response to auto-generate accurate patient demographics, thus removing the need to re-key patient information and eliminating possible errors in data entry.

Real-time eligibility information returns not only the effective start and end dates of the patient’s policy, but also provides detailed benefit information with important co-pay and deductible status. Thus, we aren’t relying on what the patient can remember about their benefit plan or which out-of-pocket costs have been met in other offices. We can know in many cases what the patient’s out-of-pocket cost will be for the visit, enabling the accurate collection of fees up-front.

Using real-time eligibility, billers won’t receive claims denials for eligibility anymore, which is very costly in both time and money. The biller who receives eligibility denials has to phone the patient or the insurance company, make adjustments to demographic and insurance data, re-submit claims, and potentially wait another 30 days for the insurance company to re-process. In this day and age, there is no reason to go through all that angst!

Setting up real-time eligibility in Iridium Suite is fast and painless, requiring only a few steps. It saves the busy medical practice hundreds of dollars and hours by averting eligibility errors. Real-time eligibility is worth the effort to implement.

Taking control through self-audit

A medical business should always be making steps toward improvement.  That is how we retain clients in all businesses.  Have you ever thought, “Every worker is busy. The appointment calendar is full.  The piles of work get bigger, but the money is shrinking.  It feels like everything is out of control.”  

These are common thoughts for many executives and employees when a business has grown to capacity.  How can we find areas that need improvement?  Self-audit is a tool that will help answer those questions.

The television show “Undercover Boss” depicts corporate executives in disguise traveling to different locations of their business. They want to discover the real truth about flaws in their company’s workplaces. Many are surprised by the loyalty of the employees who try hard and care about the company. Yet many employees feel disconnected from the ‘top’ because they have ideas about how to improve their jobs and their company that go unheard.

The owner of a company need not go undercover to get into the real workings of the business. Business owners should be encouraging employees to improve workflows and outcomes. Self-audit is a simple and proven method for finding better ways to work. Sometimes it takes another set of eyes to see obvious flaws in a workflow. Maybe it means giving an employee permission to take the time to stop and take time to reflect upon their work.

It is always better to find your own mistakes and correct them before an outside auditor comes in to point them out.  Set aside a small period of time daily or weekly to conduct a self-audit. Look over the goal of the project, and then get into the details.  Ask others to look over the work and give feedback.  Swap files and audit one another’s work.  If self-audit is done frequently, it need not take hours or days.  Learn to budget your time and include self-audit on your task list.  For instance, in our practice, I budget fifteen minutes a day to review charts and to compare treatment data to the charges billed. It keeps the files from piling up on my desk and helps me catch billing errors when they are fresh.

The first question to ask during self-audit or internal audit is “Why”.  Why did the biller choose that code?  Why did the treatment course change mid-stream?  Why does it take so long to answer the phone?

The second and most important question to ask is “How”.  How can we make our processes better?

Self-audit gives everybody power and control over their own work. The practice of self-audit will give employees confidence that their tasks are being completed with integrity as they see flaws and improvements that can be made in their own work practice.  It also gives employees proof of their abilities to manage their job duties, especially when they correct problems as they arise. Self-audit also gives the owner or CEO confidence that everything is under control.

I have received claims denials, now what?

Set aside a specific amount of time to work the denials received. The practice will be better off for this approach, because consistent data entry problems or billing errors can begin to show a pattern in poor workflow or training needs. Insurance companies also have time limits on adjusting and reviewing appealed claims, so time is of the essence.

When we receive a denial on a claim, we can use a logical approach to resolve the problem. Here are a few common reasons for denials and the steps toward resolution:

Eligibility or Coordination of Benefits –locate a copy of the patient’s insurance card and compare it carefully to the information coded in the system. Make sure data entry has been performed correctly for patient demographics including the spelling of name(s), birth date, etc. Compare the eligibility dates with the dates of service being billed. Check the insurer’s eligibility information by contacting the insurance company online or by phone. If you cannot resolve the problem, call the patient and ask them what information they have received from the insurance company regarding the denial. Sometimes the patient has the responsibility to clear up the issue.

Timely Filing - make sure the claim reflects the correct date of service. Call the insurance company and ask what the timely filing rules are for your practice (rules vary by state and contract). If everything is verified as correct, ask the insurance company to adjust the claim. They may ask for a timely filing report. If it was a paper claim, ask the insurance company if they accept a screen shot of when the claim was filed for proof.  Your billing system should be able to produce an EDI document of timely filing if you bill electronically. If there were extenuating circumstances that resulted in late filing, resubmit the claim with an appeal asking for leniency.

Bundling - check to confirm if billing was done correctly. Check NCCI (National Correct Coding Initiative) edits to see if another procedure was billed on the same day that superseded or included the procedure being denied.  Check also for whether a modifier should (or should not) have been added. Decide if the claim should be billed as a correction, appealed for special circumstances, or accepted as bundled.

Medical Necessity - insurance companies have system edits that alert staff to the necessity of further review. Many ICD 9, CPT, and HCPCS codes are programmed to stop during processing to allow review of the claim by the insurer’s staff. Some codes may automatically reject.  Make sure the billing submitted is correct, including the diagnosis. If necessary, correct the claim and re-bill according to that insurance company’s rules on corrected billing. If the insurance company is asking for medical records, send all documents asked for; especially anything that supports the decision to provide the treatment. Act on this as soon as possible, because most appeals take up to 60 days.

Not a benefit – as always, make sure the diagnosis and procedure codes are billed correctly. If the insurance company has ruled a service as not medically necessary, there is no benefit available to anyone under their membership. If an individual policy does not offer the benefit (such as maternity, elective surgery, etc.) then the patient’s specific policy is the determining factor. Either way, the service will not be paid. Review previously billed services to detect any errors on the insurance company’s part. If it was a benefit last week, it should be acceptable this week. Call the insurance company for an adjustment to their error. If a call or online review reveals the patient does not have coverage for that service, accept the denial and make a note for the future. Be sure to alert the physician and staff as well to prevent future denials.

Duplicate-review  the patient’s charges to identify a duplicate billing, previous payment, or if the claim has been submitted more than once. Pay attention to professional, technical, and global fees for the same code.  Look for any other diagnosis that the patient could have been billed under. If there is nothing to indicate a similar charge was billed, check the insurance company records to see what they have that could be bumping against the service. Perhaps they just paid on another claim and the denial reached the office before the check did. If you cannot find a duplicate, ask an insurance representative to check other providers on the same date. If nothing can be resolved, ask the representative to prove that the charge is a duplicate by researching further and either adjusting the service to pay, or sending a letter in writing explaining why the service cannot be paid.

It is easy to make mistakes in data entry and billing, even when we are taking great care. Sometimes there are many different elements in decision making, or possibly several people are entering data on the same chart. Once a claim has been sent, it has moved on to other systems outside of our control with the potential for additional mistakes in data entry or guidelines.  Being diligent in following up on claim denials can teach us a lot about best practices in our own office.

How to handle secondary insurance denials

Secondary insurance plans often pay deductibles, co-pays, or coinsurance that is due after the primary insurance plan has paid on the claim. Secondary claims process through the insurer’s regular claims progression, so it may be somewhat of a surprise when a denial EOB shows up for a secondary claim. Remember, a patient’s secondary insurance plan has its own benefits and coverage policies that cover that member.  So, for example, while a patient may have coverage for a certain procedure under their primary insurance, that procedure might not be included in the patient’s benefits under the secondary policy.

Let’s examine a recent claim for radiation therapy that crossed over from Medicare to a secondary insurance company and was denied by the secondary payer for “place of service incompatibility”. Radiation therapy is routinely performed in free standing facilities and in this case was billed as such, per Medicare coding guidelines. Upon phoning the secondary insurer to point out a possible denial error, it was discovered that this particular patient’s plan falls within a small group for which radiation therapy is only payable as an inpatient procedure.  Therefore, in this instance the denial is correct since the treatment was performed as an outpatient procedure, disqualifying it from secondary coverage for this particular patient.

However, secondary insurer denials often prove to be an error on the payer’s part and an adjustment to the claim is warranted. The accounts receivable manager’s first step is to compare the service line to other claims that have already processed. If the same procedure code has been paid by the plan in the past, a quick phone call to point this out will often result in an adjustment to the denied service. Sometimes an accounts receivable manager has to be confident and persistent to get a denial error reversed. Your persistence may cause the insurance company to retrain its claims processors or may result in the correction of an error in their system so that future services are not denied improperly.  It is always worth pursuing secondary denials that you believe are erroneous.

The importance of a good medical claim scrubber

Coding claims is tricky. Radiation oncology is especially difficult because of the planning and staging processes that occur prior to treatment. On a bad day a coder can create future problems that are difficult to remedy.  Fortunately, Iridium Suite offers a safety net to help you avoid the pitfalls of improper coding.

A claim scrubber is a built-in editor, like spell check, except it is automatic. Iridium Suite features a scrubber that has many capabilities, so if a biller is having a bad day coding, he or she can rest assured that many billing violations will be caught by the claim scrubber before the claim is generated.  The claim scrubber is present and active in the background during billing work, whether during the importing of charges from outside systems (such as record and verify systems or EMRs/EHRs) or while manually coding charges.

Here are a few examples of the functions of Iridium Suite’s claim scrubber:
The claim scrubber offers suggestions for converting old, outdated codes to newer ones, or requests permission to add a modifier to an E & M (evaluation and management) code that conflicts with other codes billed the same day, such as 99204 with 77263.  The biller has the option of re-evaluating the code and overriding the warning edit or allowing the scrubber to change it.

The claim scrubber sets a warning status on service lines that may be correctly coded but which conflict with other services according to NCCI (National Correct Coding Initiative) edits. A pop-up window shows the NCCI conflict and rule regarding the services billed. The biller has the option of choosing to override the warning status or the biller can change the date on the service that is being billed to avoid the conflict. The service line may also be deleted and a more appropriate service can be coded.

PQRI/PQRS is a potential ‘miss’ on any patient having Medicare or Medicaid.  If a medical practice activates the PQRI scrubber, then the scrubber is configured to automatically request that the physician sets up PQRI measures for each patient whose treatment qualifies for PQRI. The claim scrubber also recognizes which billing codes are potential PQRI denominators and automatically suggests the PQRI numerator codes that should be added to the claim. The biller simply accepts these suggestions and the claim scrubber automatically adds the proper PQRI charge codes to the claim.

In addition, the Iridium Suite claim scrubber makes every radiation oncology biller’s life better by automatically adding up the patient’s daily treatments and applying the management code 77427 with its corresponding dates. This feature is a fantastic time saver and ensures that this often-forgotten code is billed out properly.

Iridium Suite’s claim scrubber is without a doubt the most helpful tool for a biller coding for a radiation oncology practice. It saves time and money and prevents potential errors that cost further time and money to remedy.