A recent OIG report contains vital information for your revenue cycle staffs' telehealth billing practices.
Now more than ever, revenue cycle leaders should make sure teams are billing telehealth services correctly and are checking claims against the information found in the recent OIG data brief.
So, what if your back-end revenue cycle staff are finding errors in their billing? Healthcare attorneys told Part B news it isn't the end of the world if you take the right steps in response.
Revenue cycle leaders shouldn’t be surprised if errors are found. It's difficult to implement new coding and billing rules under ideal conditions, and most organizations in 2020 had to get up to speed on telehealth services during a public health emergency and keep track of a steady stream of new and revised coding and billing rules.
According to Part B News, there are six steps that revenue cycle leaders should take when your teams begin to review telehealth claims:
- Read the data brief. "The OIG data brief is a useful compliance roadmap for providers, and one that should inspire both providers and telemedicine companies to take a closer look at internal coding, billing, auditing, and monitoring practices, which serve as important checks and balances in any health care organization," says Amy Lerman, member of the firm with Epstein Becker Green in Washington, D.C. For example, the brief includes seven program integrity measures that the OIG created for telehealth services.
- Increase your red flag knowledge base. You should also use HHS' list of common telehealth billing mistakes when you review claims. Mistakes include using or reporting:
- The wrong codes. The wrong code can delay payments or cause improper payments. For example, confusion about when to report a telephone code versus an office/outpatient visit code may have caused improper coding.
- The wrong documentation. In addition to meeting the documentation requirements for the service, your practice must document whether the patient gave you verbal or written consent to conduct a virtual appointment, according to the HHS. In addition, the provider must clearly document whether the connection was audio and visual or audio-only.
- The wrong time. A common mistake made by organizations is the billing of time a patient spent with clinical staff, the HHS report says. Staff should only bill for the time spent with the patient.
- Probe if you find a problem. You don't need to drop everything and start a full-scale review of every claim if you find one error, but ignoring the error is not an option. You should find out what caused the mistake, figure out its scope and act on your findings, such as returning an overpayment.
- Conduct a thorough analysis into what caused the error. "Secondarily, the organization should conduct a root cause analysis to determine whether any bigger picture solutions need to be implemented," Lerman says. Those solutions could include better training, improving the practice’s coding and billing resources, and correcting behavior that could be fraudulent.
- Bring in outside help. If you discover a serious issue such as dozens of incorrect claims or signs that point to fraud, don't try to tackle the problem on your own. "This is one of those instances in which we recommend practices work with their counsel," says Sara Shanti, partner with Sheppard Mullin in Chicago. Fraud, waste, or abuse "may not be the only issue, so it is important to investigate," Shanti says.
- Document everything you do. The enduring maxim, if it isn't documented, it isn't done, applies to compliance efforts as well as providers' work. A written record of the steps your revenue cycle took will help build up a compliance plan, prevent mistakes in the future, and, if the worst happens and your health system is investigated, it will show the government that you tried to do the right thing.
Amanda Norris is the Revenue Cycle Editor for HealthLeaders.
The recent OIG data brief is a useful compliance roadmap for organizations, and one that should inspire revenue cycle leaders to take a closer look at internal coding, billing, auditing, and monitoring practices.
Revenue cycle leaders shouldn’t be surprised if billing errors are found once reviews are started, but there are solutions available to remedy errors.