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Make sure your physician practice is prepared for renewed scrutiny of Medicare claims. Medicare Part B post-payment, service-specific medical reviews resumed Aug. 17, 2020, after a brief hiatus due to the COVID-19 public health emergency. Prepare for time-sensitive Additional Documentation Request (ADR) letters by knowing what services Medicare Administrative Contractors (MACs) will be reviewing next. […]
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Neurosurgeon Medical Practice Director to Pay Over $ 1 Million
Neurosurgeon Medical Practice Director to Pay Over $ 1 Million to Resolve False Claims Act Liability Arising from Billing of P-Stim Devices. PHILADELPHIA – First Assistant United States Attorney Jennifer Arbittier Williams announced that neurosurgeon Sagi M. Kuznits, practice director Pnina Kuznits, and Neurosurgical Care LLC (collectively, “Kuznits”), have agreed to pay $ 1,017,375.03 to resolve liability under the False Claims Act for the alleged improper billing of electro-acupuncture devices called Stivax and/or P-Stim and a memory-loss device called eVox.
From February 2017 through July 2018, Kuznits billed Medicare, TRICARE, and the Federal Employees Health Benefit Program for the implantation of neuro-stimulators – a surgical procedure which usually requires an operating room and which is reimbursed by federal healthcare programs – when in fact the only procedures performed had been the non-surgical application of P-Stim and Stivax by a physician assistant.
In addition, Kuznits billed Medicare for a physician assistant’s application of an “eVox” device.
“We continue to work closely with our partners at CMS’s Center for Program Integrity, the Department of Health and Human Services Office of Inspector General, other federal healthcare programs, state partners, and sister U.S. Attorney’s Offices around the country to hold accountable any other providers who inappropriately billed this device and any product distributors or marketers who may have devised or carried out such a billing scheme,” stated First Assistant U.S. Attorney Williams.
“We thank our partners at the Department of Justice and Department of Health and Human Services Office of Inspector General for working hard with us to identify, investigate, and eliminate waste, fraud and abuse in our federal healthcare programs.”
“Accurately billing for services provided to Medicare beneficiaries is required of all health care providers,” said Maureen R. Dixon, Special Agent in Charge for the U.S. Department of Health and Human Services, Office of the Inspector General.
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Learn how the role of medical coder may change in the near future.
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A perspective of men in medical coding.
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Reduce your error rate for medical coding and billing.
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Find a medical coding job.
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Clinical trials have a place for medical coders. Research is a big job market for healthcare business professionals.
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The coding industry is chock full of companies offering a bevy of services, one of them being coding.
During our twenty five years in business, we have seen countless vendors in the healthcare revenue cycle industry add medical coding services to their service offerings. Their main focus is generally billing, scribe and documentation assistance, credentialing, or IT services.
They see coding as a natural extension of their business line and add a few generalist coders to help service the clients that ask for coding assistance. Coding isn’t their main focus and therefore doesn’t receive the high level of attention and scrutiny that is required to deliver an accurate and compliant coding service.
Coding is the key cognitive function within the billing cycle. Coding cannot be commodified like bandages or data entry services. Coding is a skill that requires a specialty specific knowledge of anatomy, physiology, and procedures that needs constant attention and updating.
Additionally, we have seen companies use generalist coders to provide their services. Just like a doctor selects a particular discipline and focuses on it exclusively to become an expert in their field, we likewise believe that a coder should target a particular area to specialize in. The code books are too vast for any one person to be an expert across multiple specialties and subspecialties.
If you’re using a company whose core business is not coding, there are some questions that you should ask to help decide if you should continue to utilize their coding service:
Who is doing your coding?
Is it outsourced to a coding company and if so, who?
Is your coding being sent offshore?
Are the coders you’re using specialty specific or generalists?
Do you test new coders in their specialty before they start working for you?
What does your coding QA program look like?
If you don’t like the answers to these questions it might be time to take your coding elsewhere!
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A troubling trend in the medical coding industry is a misleading split model where companies will have resources both onshore and abroad but not disclose which personnel are performing the services. Some use their domestic resources almost exclusively for client facing interactions, such as sales and operations, but send all of the coding work to be performed offshore to reduce their costs. This creates the illusion of a US based workforce, but it comes with the dangers of offshore medical coding.
The dangers of offshoring coding work are twofold: 1) accuracy, and 2) privacy. Coding is a highly specialized cognitive function that cannot be commodified. This isn’t bandages or simple repetitive tasks. It is a service that requires a great deal of specialized knowledge and critical thinking that takes years of practice to hone and constant education to ensure that the coder is kept abreast of updates to their field. As an external auditing provider, The Coding Network has audited a bevy of offshore coding vendors. Our overwhelming experience is that offshore coding is suboptimal and greatly concerning for organizations that utilize their services.
Additionally, there are no HIPAA laws outside of the United States, raising privacy and security concerns. A vendor might assure their clients that their overseas facility is secured, but if there is a breach of an organization’s PHI the only mechanism to protect themselves against the vendor would be a contractual claim, i.e. a breach of the terms of a BAA, not an enforcement action. Trying to sue an entity that maintains most of its operations and assets offshore makes any recovery incredibly difficult and the likelihood of recompense murky at best. You wouldn’t even know your information is leaked until it ends up in the wrong hands and since it would be impossible to trace without a candid engagement by the vendor, there is little that could be done.
Remember that the PHI in question is that of an organization’s patients. What would the patients think if they discovered their personal information was being sent abroad for no other reason than to save the organization money. This cost savings to an organization is nominal and more often than not the patients do not realize any of the savings in their billings. From a public relations standpoint, this will likely not go over well with a practice’s patient base and could result in a loss of business and/or reputational harm.
Whenever dealing with a coding vendor it is important to make sure they are doing the work in the USA. One tip is to ask for a clause in your contract that requires US-based coding. Additionally, look out for pricing that seems too good to be true. If you’re paying a bargain basement price for your coding work you will be getting bargain basement quality and security.
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Cross training sounds like it should work. A coder is a coder. Why pay a new coder to work on Orthopedics when you have two OB/GYN coders with extra capacity? The job title is the same, the job itself is the same, the software/system access/workflow are the same. Yet this thinking can get a practice in to trouble from both a compliance and revenue standpoint.
Like any job, the more you do it the better you should get at it. While this may hold true for a coder consistently seeing work in the same specialty, it doesn’t apply to the ability to code all specialties in general. How can spending 5 years coding cardiology procedures qualify someone to code neurosurgery cases? It doesn’t; there are too many differences in the codes being selected, the physiology and anatomy involved, and the rules and guidelines issued by the payors claims are submitted to for reimbursement. Likewise, if a coder is spending too much time touching an abundance of disciplines, they won’t have enough experience or specialized knowledge to be proficient coding any one thing.
Training a coder in a new specialty isn’t as simple as letting that coder code by trial and error. Proper training requires a thorough understanding of the medical specialty, all types of procedures and associated illnesses and conditions. This should all happen well before that coder is allowed to start coding. Once that coder is ready, they need to be treated as a freshly minted coder and undergo regular audits and reviews. This process takes time and effort from a management standpoint and diverts resources from your coders’ regular specialty.
All too often coding departments don’t have the time and resources to properly train their coders in the areas of work they regularly perform. Providing minimal additional training in another specialty is often a fools errand. There are no guarantees that your coder will be able to learn a new specialty and code at an appropriate accuracy level. Allowing a coder to attempt a new discipline while submitting those claims for reimbursement is a sure fire way to increase denials from payors, lower reimbursement due to undercoding, allow for providers insufficient or incorrect documentation to go unchecked, and possibly open up your organization to compliance exposure.
While cross training on its face may seem like a good idea, the results are often disastrous. Practices hoping to save money by reallocating unused or underutilized internal coding resources will find themselves harming the stability of their revenue stream, creating additional follow up work after the denial of claim submissions, and, as a result, end up costing more for the practice than having utilized an appropriate specialized resource in the first place.
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